STRATEGIC PLANNING JOINT ADVISORY PANEL

Section 100 D - Local Government Act 1972 - background papers

The following documents disclose facts or matters on which this report, or an important part of it, is based and has been relied upon to a material extent in the preparation of this report.

NB the list excludes:

1.

Published works.

2.

Documents which disclose exempt or confidential information as defined in the Act.

TITLE

LOCATION

Consultee responses on Policy H4 Monitoring Report 2005

File D3/1.39(ii), Spatial Strategy Group

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

4,8,9,14,21

The Strategic Planning Authorities failure to acknowledge or take into account the performance during the first 5 years of the plan period creates an inaccurate picture of housing supply within the county.

The RPG issued in 2001 supersedes the RPG issued in 1994. GOSE has confirmed that there is no requirement to make up any shortfall prior to 2001.

4,8,10,13

Paper fails to address the backlog arising at the beginning of the Structure Plan period.

See above.

8,9,20

With the exception of the odd year, including 2003/04, Hampshire has consistently failed to perform in the delivery of housing completions. Concern that last year was a one-off and rates will not sustained.

The number of completions in Hampshire has increased steadily each year since 2001/02. The high level of completions in 2003/04 was part of this trend. An increased number of planning permissions supports the view that completions will continue in excess of the annual RPG requirement.

4,14

Paper fails fundamentally to accurately monitor housing completions in the County by not providing annual forecasts for each district.

The decision was taken to focus this year's paper on the information needed to determine whether there is a need to release any of the reserve provision.

This information is available in other published documents.

23

Welcome significant improvement in completions on previous years and also an increase in planning permissions.

Noted.

20

Undersupply has worsened 2001-2004 despite the policy H4 monitoring paper.

It is recognised that completions 2001-2004 were only 95% of the RPG requirement. However completions in 2003/04 were above the annual RPG requirement and this situation is forecast to continue over the next few years.

10

Paper omits a review of completions to date (in last years paper) and a sub-area breakdown which allowed various trends to be identified and highlighted the underperformance of North Hampshire.

The decision was taken to focus this year's paper on the information needed to determine whether there is a need to release any of the reserve provision.

This information is available in other published documents.

1

A bar chart showing how each authority's completions related to their annual requirements has been useful in previous papers.

Noted.

21

Figures should include the reduction in empty homes since 1996, believed to be in excess of 3,000 homes county-wide.

The number of empty homes is not included as it will not influence the decision on whether to release the reserve provision. However information is included in the Structure Plan Monitoring Report 2004.

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

4,8,14,20

Need to deliver baseline and reserve 1996-2011.

The only way a surplus can be demonstrated is by focussing on RPG requirements and ignoring the Structure Plan requirement.

Hampshire is required by Regional Planning Guidance to complete an average of 6,030 dwellings per annum. GOSE has confirmed that there is no requirement to make up any shortfall prior to 2001.

8,20

In the future, rates will have to be substantially higher than achieved in the past and will have to be sustained over 7 years; this is unlikely and will not be achieved unless there is a release of reserve sites. The sooner action is taken to address this the more likely future under-delivery problems will be avoided.

The Strategic Planning Authorities consider that the forecast level of housing completions is achievable. The Policy H4 Monitoring Paper shows that even with substantial discounting there is still sufficient supply to enable the RPG target to be satisfied up to 2011.

4,8

Even if all the constituent authorities in Hampshire were to meet their baseline requirements, there would still be a significant shortfall in housing provision in Hampshire compared to the RPG requirement.

The target is to meet the RPG figure. If as a minimum, all authorities built their annualised baseline requirement, the additional completions in some areas over and above that would ensure that the county as a whole exceeded the RPG figure.

13

There is every reason to believe that the future rates required will need to be higher than current experience. There seems to be no harm in enabling individual districts to meet their own targets even if this results in a short term over-run on current targets.

The target at the present time is to meet the RPG figure. Ever district must at least provide for its Structure Plan baseline figure.

15

Figures for housing supply to 2011 have not been produced on a comparable basis to 2004 paper which did not include the West of Waterlooville and Andover MDAs.

Agree that the MDAs have been included in the figures for identified sites this year. Comparable figures are available on request from the report author.

14

Table 3 should differentiate between `Local Plan Allocations' and `Other Commitments'.

This table provides a general summary of identified housing supply.

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

2,8,9,14

Support discounting and sensitivity testing and in general the adoption of a fairly cautious approach.

Welcomed

10,15,16,19

Discount rates appear arbitrary with no credible justification provided and it is impossible to properly consider these rates.

The discount rates to be applied were subject to consultation before analysis was begun on the monitoring paper. The lowest discount (5%) was applied to the category most likely to be built - large sites with detailed planning permission. A higher discount (10%) was applied to housing on large sites where only outline planning permission had been granted as it was considered that the likelihood of these being completed by 2011 was slightly less certain. The highest discount (20%) was applied to Major Development Areas as it was considered that the greatest risk of the supply not being built by 2011 was on these sites. The Housebuilders Federation agreed that this level of discount was appropriate for the MDAs. The risk of the remaining supply not being completed by 2011 was considered to be less than in the MDAs but greater than sites with planning permission and therefore a discount of 15% was applied to this source of supply.

8,14

Unadjusted supply figures for MDAs, large identified sites and urban capacity/windfall sites are unrealistically high, especially when compared to past completions. The way the requirement has been calculated has skewed the figures.

It is acknowledged that some of the unadjusted supply figures are optimistic. For this reason the supply was reduced by over 1,000 dwellings before the discounts were applied

23

There remains a risk over unidentified large sites.

The adjusted supply figure for 2004-2011 appears reasonable when compared with past completions on this type of site (see Table 6 of Monitoring Paper)

4,5

The surplus identified (Table 7) will not necessarily equate to a similar completions figure due to difficulties bringing forward certain identified sites.

Discounting was applied to reflect that not all of the available supply will be developed by 2011.

14

Sites that continue to be relied upon as identified components in successive monitoring reports repeatedly fail to deliver completions for example Popley Fields and Binfields in Basingstoke.

Some sites have not come forward as quickly as we would like, for a variety of reasons, however it is still expected that they will make a contribution to housing supply before 2011.

10

Discounting should only be applied to identified land - windfalls are only estimates and so should not be further discounted.

The adjustments made to urban capacity and windfall sites reflect the uncertainty about when building will commence and the rates achievable and therefore the delivery of housing by 2011.

10

Sites are identified if a red line can be drawn around it on an OS base, planning status and availability are separate matters.

It is considered important that `identified sites' have some planning status such as planning permission or allocation in a local plan. It is recognised that the location of much of the `unidentified housing supply' is known to the local authorities.

21

The County Council should not be making pessimistic but realistic forecasts. Hampshire should be working towards achieving targets and not exceeding them.

Views noted.

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

9,16,20

The ability of local authorities to deliver continued rates of brownfield sites is questioned. There has been a hardening of attitudes in Local Authorities in the light of opposition from local residents against development on brownfield sites.

The paper could find no evidence of a slowdown in this source of supply at present. On the contrary, it highlights a significant increase in the number of dwellings built on large brownfield windfall sites in 2003-04.

8

There is no way of assessing the research into urban capacity as this has not yet been made public.

This is correct. Each urban capacity study has or will be scrutinised in the public arena of a Local Plan Inquiry.

14

The paper assumes a major contribution from unidentified supply without strong justification. It lacks basic or raw data, particularly important given the apparent inconsistency with the districts urban capacity studies.

The paper highlights the increasing proportion of completions on windfall sites since 2001. In addition, an audit of urban capacity studies was undertaken in order to establish whether the estimates for each district were realistic.

10

Planning applications have been submitted on some urban capacity sites and therefore the report should not describe these as `unidentified'.

These sites become `identified' when there is a resolution by the local authority to grant planning permission.

5,21

Question decision to only make allowances for districts where urban capacity has been over-estimated, not the remaining 10 districts where it was underestimated.

The purpose of the adjustments made to housing supply was to ensure that the supply was not over estimated. The monitoring report deliberately errs on the side of caution. However, it would have been difficult to make an allowance for the underestimation of supply from this source as the audit of urban capacity studies did not quantify any underestimation in urban capacity .

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

9,14,20

It cannot be relied on that applications for MDAs will be submitted and resolved in time for the housing to be completed prior to 2011.

It is recognised that there is some uncertainty about the commencement of development and the building rates achievable in the MDAs. In recognition of this a discount of 20% has been applied. Local authorities and developers are working to implement the MDAs and it is reasonable to expect a significant number of completions before 2011.

14,16

It is essential to provide figures for separate MDAs instead of a combined figure. Further data is required to justify the adopted supply rates.

All the discounts to the dwellings supply are applied on a county-wide basis.

14,20

West of Waterlooville MDA completion figures are from 2005-06 but no application has been submitted as yet. The release of the reserve will not provide any housing completions by 2011.

The Housing Land Supply monitoring information 2004 shows a small number of dwellings to be delivered by 2005/06. When making adjustments to the supply, the estimated supply from this source was reduced by 300 dwellings (from 1600 dwellings to 1300 dwellings) before the discount was applied. This recognised that the level of completions in the early years was optimistic.

8

A discounting of MDAs by 20% may be overoptimistic.

The discount applied reflected the testing undertaken on very large sites.

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

13,14

Consideration of housing supply for the county as a whole does not absolve each district from the requirement to meet its baseline supply figure.

Agreed.

9

Hampshire Action Plan action PA10 requires the County to identify where H4 releases could be made when the adjusted supply is within 5% - this assessment has not been undertaken.

The adjusted supply exceeds RPG + 5% by almost 3,000 and therefore no assessment is required.

9

Adjusted housing supply does not provide a sufficient margin to ensure that the Structure Plan and Regional Planning Guidance requirements will be met by 2011.

The adjusted figure for total available supply to 2011 exceeds the RPG requirement by 5,000 dwellings.

16

Tables 8 and 6 are inconsistent.

Disagree, the tables have been misunderstood.

16

A small downwards adjustment to supply 2004-07 is required in Table 8 as the figure stated is more than the outstanding permissions at April 2004.

Disagree. The adjusted estimate of dwelling completions for 2004-2007 is 19,744. The total number of outstanding planning permissions (including those subject to section 106 agreements) at 1 April 2004 was 26,674. The estimated supply 2004/07 (controlled by the number of planning permissions for each district) is 20,397. As this figure is higher than the adjusted estimate, no further adjustment is necessary.

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

6,11,12,19,

22,24

Support overall conclusions.

Noted.

5,8,13,15,1821

A more detailed breakdown of the information, including the situation in individual districts and 3 sub-areas is required.

This year's paper is shorter than previous years and focuses on the information needed to determine whether there is a need to release any of the reserve provision. Further information is available on request.

4,10,15,16

Report does not convincingly demonstrate that sufficient completed dwellings will be produced by 2011. There are issues of deliverability and the conclusions reached cannot be justified.

The conclusions are based on the information available and assumptions set out in the Monitoring Paper. These include steady increases in both planning consents and housing completions since 2001.

4,10,13,19

Paper should go further in its conclusions.

It is not considered necessary to do this as the Monitoring Paper concludes there is no need to release any reserve this year.

8,10,16

There is insufficient information available in the report to allow proper consideration of the issue and in order to determine whether the conclusions are correct.

This year's paper is shorter than previous years and focuses on the information needed to determine whether there is a need to release any of the reserve provision.

23

It is not possible for the Secretary of State to agree with the conclusions reached in this paper until the progress report on the Action Plan has been received and considered.

Progress report has been sent to GOSE and their comments are awaited.

18

Find it deplorable that the County Council can conclude that the housing situation is healthy when Eastleigh BC can run contrary to Structure Plan policy in failing to identify reserve provision.

The Inspector's report on the Eastleigh Borough Local Plan is due to be published shortly and will consider these points. Eastleigh Borough Council is required to meet its baseline provision in full and to identify its reserve provision. The SPG makes clear that non-identification of the reserve will not be a barrier to its release if/when that is justified.

Respondent reference

Nature of comment

Response by Strategic Planning Authorities

1,2,6,12,19

Report is well presented, easy to read and understand and provides an in-depth analysis.

Noted.

10,16

Report suffers from a lack of detail, transparency and objectivity with some statements confusing and not properly justified. It has too narrow a focus on the Structure Plan housing requirements and falls short of the high standard of monitoring required.

This year's paper is shorter than previous years and chose to focus on the information needed to determine whether there is a need to release any of the reserve provision. The Forward to the Paper makes clear that it is not a general monitoring paper and that there are other monitoring reports available.

16

Report does not follow the H4 SPG requirement that a comparison be made between Structure Plan and Regional Planning Guidance in each district and Hampshire as a whole.

The SPG only requires a county-wide assessment, unless it is concluded that some of the reserve should be released. Information about completions and housing supply by district is included in the appendices.

10,12,13,15

Housing supply should be placed in the context of the options emerging in the South East plan. There is potential for confusion with local plans and Regional Spatial Strategy being approved concurrently with different targets.

At the time of the completion of this paper, final options for housing supply were not confirmed. In any event, they are not relevant to decisions on whether to release the Structure Plan's reserve provision and would only confuse the picture.

1,10,20

Reference should be made to the Action Plans. Comments on the ability of the Action Plans to deliver sufficient housing.

A progress report on the action plan is the subject of a separate report to JAP.

14,17

There is a strong case for releasing the Winchester City (North) MDA and bringing forward sites in the New Forest.

Structure Plan Policy H4 states that the reserve will only be released when there is a `compelling justification to do so'. Based on the available information and assumptions set out in the Paper, there is no compelling justification at the present time to release any of the reserve.

9

Releases should be targeted where sites are readily identified in LPs either under H4 or not and are directly and readily able to contribute to housing supply.

Revised SPG on Implementing Policy H4 2004 provides details on determining in which district(s)/MDA(s) to make the release.

3,6,21

The paper ignores affordable housing and the potential to increase the percentage on new sites instead of releasing the reserve. The real issue is how to meet the housing needs of the people of Hampshire.

The paper does not present data on affordable housing because the SPG states that affordable housing need will not influence decisions on the release of the reserve provision. Such information is included in the Structure Plan Monitoring Report 2004.

2,12

Concerns about the provision of infrastructure should be included within the policies for reserve housing sites.

This is an important issue but is outside the remit of this report which compares the supply of land for future housebuilding with the requirements of RPG to assess the need to release reserve housing provision.

7

Paper makes no reference to flood risk which should affect the release of the Winchester City (North) MDA.

This is outside the scope of the Monitoring Paper.

18

Monitoring paper places pressure on those authorities that accept their legal requirement to provide housing whilst facilitating an avoidance of this responsibility in others.

Disagree. All local authorities are expected to meet their Structure Plan baseline housing requirement.

12

Concern about the time lag between the date when monitoring was completed and when JAP will consider it.

The time lag is considered reasonable. A considerable amount of staff time is required to collect information on completions and housing supply for 13 districts, collate, check and analyse it, write the report, allow sufficient time for consultation, analyse the results of the consultation and write a report for JAP.

23

It would be helpful if the assumptions underlining Appendix 5 were made available as seem figures appear optimistic.

Noted.

19,21

Question the requirement for reserve provision on large Greenfield sites to be retained in sub-regional and district planning in view of the papers findings.

It is necessary to retain the reserve provision as a safeguard in order to meet the RPG housing requirement.

12

More emphasis could be given to the evidence that any lag in completions would not be attributable to the planning authorities in Hampshire.

Noted.