Contact: Sue Clark, ext 5890 email: [email protected]

1. Summary

1.1 The following decision is sought:

That the Office of the Deputy Prime Minister be informed that the response set out in attached Appendix 2 is the County Council's response to the Consultation Paper "Planning for Housing Provision".

1.2 The Environment Policy Review Committee considered this item on 8 September 2005 and Members' comments will be reported orally at the meeting.

2. Reason

2.1 This decision supports Aims 2 and 3 of the Corporate Strategy (Stewardship of the Environment and Achieving Economic Prosperity) by influencing proposed new planning policy for housing provision.

3. Other Options Considered and Rejected

3.1 Decline to provide a response.

4. Conflicts of Interest Declared by the Decision Maker or Other Executive Member Consulted - None.

5. Dispensation granted by the Standards Committee - Not applicable.

6. Reason(s) for the Matter being dealt with if Urgent - Not applicable.

Approved by: Date:

Councillor J K Glen

481Decn/SC

APPENDIX 2

PROPOSED RESPONSE TO CONSULTATION

PLANNING FOR HOUSING PROVISION CONSULTATION -

QUESTIONS ON WHICH WE WOULD LIKE YOUR VIEWS

Name: Sue Clark

Organisation: Hampshire County Council

Address: The Castle, Winchester, Hampshire. SO23 8UD

E-mail address: [email protected]

Telephone number: 01962 845890

1. Consultees are invited to put forward their views on the proposed approach. Section 2 introduced some specific questions on which we are grateful for consultees views and experience.

Hampshire County Council Response

Hampshire County Council is disappointed that a relatively short period of time was allowed for this consultation, over the summer holiday period. This has made it difficult to give a response which has been agreed by elected Members in the time allowed. The consultation paper is an important document and sufficient time should have been allowed for organisations to give a properly considered response.

The key concern for Hampshire County Council is that once sites are allocated as part of the five year supply, developers will be able to bring forward the land at any time regardless of whether it is brownfield or greenfield land. This is likely to result in increased development on greenfield sites as these are likely to be more attractive to developers than brownfield sites. In Hampshire, if a five year supply of land is allocated, there will actually be a 10 year supply available to developers as 50% of all completions in Hampshire in recent years have been on small sites (which are not allocated) or on brownfield windfall sites. (21% completions on small sites, 29% completions on large brownfield windfall sites.) The proposed approach would lead to an over supply of land compared to housing requirements, housing requirements would be exceeded by a significant amount and the proportion of house building on brownfield sites will fall significantly. The target of 60% development on brownfield sites may not be met if the proposals are implemented as urban brownfield sites in the South East are often not able to be developed immediately. They are not normally vacant and awaiting development. It takes time for a site to be released by a Government department or for a business to relocate and therefore most of these sites could not be included in the first five years supply. If the proposed approach is implemented there should be more incentive to develop brownfield sites and all areas, not just metropolitan areas, should be able to include a realistic windfall allowance as part of the five year supply.

It is not necessary to make the proposed fundamental changes to the planning system. The changes which have been made in the past to increase the amount of building on brownfield land are working and the total number of housing completions has risen considerably in the last few years. In Hampshire where the regional planning requirement is 6,030 dwellings per annum net housing completions were as follows: 4,815 were built in 2001/02, 5,600 in 2002/03, 6,762 in 2003/04 and approximately 7,400 in 2004/05. The annual average RPG requirement has now been exceeded and this position is forecast to continue for the next six years. At the same time the proportion of housing on brownfield sites has also increased, from 50% in 1996/97 to 70% in recent years.

In order to have any significant impact on the price of housing in the South East, a huge number of additional new houses would have to be built, this would have a significant adverse environmental impact as well as very large infrastructure costs. The best way to help those in genuine housing need would be to ensure that there is a net gain in the amount of affordable housing available, ie more affordable housing is built than is lost under `right to buy'.

One of the key impediments to bringing development forward in a timely fashion is lack of infrastructure. Roger Tym & Partners have provided detailed evidence of the scale of the problem and the Institute for Public Policy Research's (ippr) Commission on Sustainable Development in the South East states, in its final report, "sustainable development requires new investment in the region's infrastructure - particularly in its transport, affordable housing and flood defences".

Nearly four years ago, when publishing the Planning Green Paper, the Government stated that it would be undertaking an urgent review of the system of planning obligations in order to simplify the way contributions can be collected. However, nothing substantive has been forthcoming; the new Planning Obligations Circular published on 18 July leaves things substantially unchanged. The expectation that planning gain will meet affordable housing needs means that the provision of other services, such as transport improvements, libraries and schools, is likely to be called into question.

Planning for new housing provision should be coordinated with planning for new infrastructure, transport, regeneration and employment. It is therefore considered that planning for future development should take place on a sub regional basis (as in the SE Plan) rather than a sub regional housing market area basis.

2. Consultees are invited to highlight good practice that would deliver the collaborative approach to planning for housing markets set out here, or to suggest particular structures, mechanisms and incentives that would support planning and decision making at the level of the housing market.

Response

In response to the need for a sub regional strategy for South Hampshire in the South East Plan, the local authorities in the area have been working collaboratively. The Partnership for Urban South Hampshire (PUSH) authorities are working together on a variety of matters including the distribution of district-level housing figures and intend, in the future, to produce a common policy framework for affordable housing. Planning for the housing market area would involve the same authorities, and could therefore be undertaken fairly easily.

A collaborative approach can only succeed if the authorities choose to work together. Joint working is complicated where authorities have different aims or priorities and where there are different timescales for preparing development plan documents. It is almost inevitable that there will be difficulties and delays when the housing market area includes several districts with differing characteristics. (There are 10 local planning authorities in the South Hampshire Housing Market Area.) It will be difficult to get consistent local housing assessments and assessments of housing land availability unless a single organisation is undertaking or coordinating the work. If local housing assessments and wider housing market assessments are to be used to determine the level and distribution of housing provision, it is important that well thought out, clear guidance is consulted on and then issued well in advance of the work being done so that these assessments are undertaken on a similar basis by each authority.

3. Consultees are invited to give their views on how a tailored approach to planning for housing could work or whether a single approach, but in the context of different levels of growth, is preferable.

Response

There are difficulties associated with both approaches. In areas of high housing demand/high house prices where housing numbers are treated as a minimum that could be met earlier in the plan period if the assessment of housing markets indicate this to be appropriate, there would seem to be no real limit on the number of dwellings that might be built. This sits uncomfortably with the notion that a Regional Spatial Strategy covering 20 years and a 15 year Local Development Framework gives some certainty to the public, businesses and developers, whilst making planning for infrastructure provision even more difficult.

4. Consultees are invited to give their views on how assessments of land availability covering sub regional housing markets could best work and provide examples of existing practice that achieves this.

Response

Hampshire County Council works with the local planning authorities in Hampshire (including the unitary councils of Portsmouth and Southampton) to monitor the supply of housing available on an annual basis; this collaborative work is undertaken on a district-wide basis for the whole of Hampshire. It would be possible to undertake an assessment for a group of several whole districts, but it would be significantly more complicated to undertake the task on the basis of housing market areas as these do not follow district boundaries. Several districts in Hampshire would be in two different housing market areas and this would necessitate them taking part in two assessments of housing land availability. This would be considerably more time consuming than undertaking an assessment for each whole district. The disadvantages of this approach may be greater than the benefits.

5. Consultees are asked to give views on the best means to manage windfall in different areas in order to deliver sustainable development.

Response

Brownfield windfalls are an important source of housing supply which help to deliver sustainable development. In Hampshire, monitoring shows that about 50% of new housing supply is from windfall development. It is sometimes difficult to predict the amount which is likely to come forward during the plan period, particularly if this is extended by another five years, but there are already existing mechanisms, such as binding inspector's reports for development plan documents, which should ensure that the amount of land supply expected from windfall sites is not over optimistic. Phasing of the supply, which gives priority for development on brownfield windfall sites in sustainable locations over allocated greenfield sites would help to deliver sustainable development.

In areas where there is a high level of demand for housing, where there is uncertainty about a very large brownfield windfall site coming forward (eg MOD site at Bordon/Whitehill in Hampshire - up to 5,000 dwellings), plans should be made to meet requirements for new housing without including the brownfield site which may not be released. If subsequently a large brownfield site does become available in a sustainable location, an action plan can be prepared and if appropriate a revision made to the regional spatial strategy. In these circumstances the local authority should be permitted to exceed its housing requirement by up to the amount of the additional housing. This may not give certainty about additional housing supply but could result in significant amounts of additional housing in areas of high demand.

6. Consultees are invited to give their views on how far monitoring market information such as house prices could add value to ensure that the judgements local authorities make about rolling forward are soundly based.

Response

Discussions with house builders are useful but experience in Hampshire shows that they are generally very optimistic about how soon applications will be submitted and also about the timescale for completions on their sites, yet collectively sceptical about whether the forecast total house building will be achieved.

The monitoring of house prices has limited value as price is influenced by many factors, supply has only a small impact on house prices in the South East. The rate of house price increase accelerates or slows in response to a variety of factors such as the buoyancy of the national economy, mortgage rates, etc even when land supply remains steady.

7. We would welcome views on whether the RIA highlights the key costs and benefits - and whether these impacts can be quantified.

Response

The regulatory impact assessment appears to highlight the main costs and benefits.

The assessment of the options states that the proposed policy approach is likely to result in increased development on greenfield sites. Hampshire County Council agrees that this is one of the key disadvantages of the proposed approach. Once sites are allocated as part of the five year supply developers will be able to bring forward the land at any time regardless of whether it is brownfield or greenfield land. This is likely to result in increased development on greenfield sites as these are likely to be more attractive to developers than brownfield sites.

Hampshire County Council is also concerned about the increased burden on local planning authorities and regional planning bodies which would result from the proposed policy approach. Undertaking joint (or consistent) local housing assessments and assessments of housing land availability for each housing market area and maintaining a five year rolling land supply will involve more work and will be significantly more costly for those authorities involved in undertaking two assessments.

The other economic costs associated with the preferred approach relate to infrastructure provision. If these proposals are to be implemented the effects would be greatest in the South East where pressures on resources and infrastructure are most acute. It is one thing to recognise infrastructure issues and it is quite another to actually do something about it. These proposals should not be implemented in advance of issues relating to infrastructure provision being resolved.

8. We would welcome views on whether any another groups are likely to be affected of the proposals.

Response

No comment.