Date: 28 April 2008 Item 7

Report by: The Hampshire Director of Environment, Portsmouth Head of Planning Services and Southampton Executive Director of Development and Sustainability

Hampshire County Structure Plan: Policy H4 Monitoring Paper 2008

Written by: Sue Clark, tel: 01962 845890 email: [email protected]

Purpose and Summary:

To inform the Panel of the conclusions arising from the Hampshire County Structure Plan Policy H4 Monitoring Paper 2008 and the outcome of consultation on the document. The Paper concludes that the forecast dwelling supply 2007-2011 exceeds the requirement in Regional Planning Guidance (RPG). The total supply exceeds the RPG requirement by over 12,000 dwellings. This overall figure was subject to adjustments in recognition that not all potential housing will ultimately be developed within the timescales expected. The results show an adjusted figure that is still over 9,000 dwellings above the RPG requirement. On the basis of this year's monitoring there is no compelling justification to release any of the Structure Plan reserve housing provision.

Eighteen organisations and individuals commented on the Monitoring Paper. Only two respondents - planning consultants - were critical of the Paper. There were no other responses from the development industry or the Home Builders' Federation. Other interested parties, such as local planning authorities, parish councils and local interest groups, were generally supportive of the Paper and its findings and most supported the general conclusions of the report. No response has been received from the Government Office for the South East (GOSE).

The South East Plan is expected to be finalised during early 2009. When this happens it will supersede the `saved' Structure Plan policies, bringing an end to this process of monitoring housing land supply in relation to Policy H4 of the Structure Plan. This is therefore likely to be the final iteration of this annual monitoring.

RECOMMENDATIONS:

That the three Strategic Planning Authorities be recommended to:

(i) note the points made by consultees;

(ii) resolve that no reserve sites should be released; and

(iii) write to all consultees to thank them for their comments, enclosing a copy of this report and appendices and informing them of the decisions made by this Panel.

1. Introduction

1.1 The policies of the Hampshire County Structure Plan 1996-2011 provide a `baseline provision' for new homes and a `reserve provision' which will be released if, and when, the strategic and local planning authorities decide it is needed. Policy H4 identifies the broad locations of the reserve provision and describes, in general terms, how decisions will be made on releasing the reserve provision. The process is explained in greater detail in the Supplementary Planning Guidance `Implementing Policy H4'.

1.2 Policy H4 states that "The strategic authorities will only support the release of individual greenfield allocations to meet this reserve provision where monitoring of the Structure Plan and Local Plans indicates there is a compelling justification to do so". The separate Supplementary Planning Guidance called `Implementing Policy H4', adopted by the Strategic Planning Authorities in 2004, sets out the process for annual decision-making on whether there is a need to release any of the Structure Plan's reserve provision. That process includes publication of an annual monitoring report and consultation thereon.

1.3 As a consequence of changes to the planning system the Hampshire County Structure Plan ceased to have any effect from 27 September 2007, with the exception of 24 policies. Those 24 policies remain in force due to a Direction issued by the Secretary of State for Communities and Local Government under Schedule 8 of the Planning and Compulsory Purchase Act 2004. Policy H4 is one of those `saved policies' and so continues to be applicable.

1.4 The Policy H4 Monitoring Paper 2008 was published on 11 January 2008 for a six week consultation period.

2. Aims and Visions of Corporate and Community Strategies

2.1 This report supports the aims and visions of the three strategic planning authorities' corporate and community strategies by helping ensure that sufficient new homes are made available whilst securing the regeneration of existing urban areas and avoiding unnecessary development on greenfield land.

3. The 2008 Monitoring Paper

3.1 The 2008 Monitoring Paper shows that house building between 2001-2007 did, as expected, exceed the RPG figure. Dwellings supply for the period 2007-2011 is also forecast to exceed the RPG figure.

3.2 The number of dwellings with planning consent at the start of April 2007 was 500 higher than the position a year earlier, despite the high levels of completions during the preceding 12 months. Some 81% of all permissions (26,360) are in full, which means there are no planning obstacles to these homes being built.

3.3 The total supply potentially available from 2007-2011 is 12,400 dwellings above the residual RPG requirement.

3.4 However, not all of this supply will actually be built in this period for a variety of reasons (eg planning, ownership and market factors). The total supply has accordingly been adjusted to take account of this. Adjustments applied were small for dwellings with planning permission, higher for local plan allocations and urban capacity sites and highest for Major Development Areas (MDAs). The forecast of completions based on these adjustments indicates that house building in 2007/08 should exceed the RPG figure and remain above the RPG for the rest of the Structure Plan period.

3.5 The adjusted supply for the period 2007-2011 is forecast to exceed the RPG requirement by about 9,700 dwellings - some 46% in excess of what Hampshire is required to build. The Monitoring Paper concludes that there appears to be no compelling requirement to release any of the Structure Plan housing reserve in the forthcoming year.

4. Consultation

4.1 The 2008 Monitoring Paper was sent to 90 consultees representing a wide variety of interests (including developers, planning consultants, local authorities, Government agencies and Departments, parish councils and conservation groups). The Monitoring Paper was also available on Hampshire County Council's website.

4.2 Comments were received from 18 respondents:

(i) 2 Planning Consultancies;

(ii) 4 Hampshire District Councils/National Park Authority;

(iii) 3 Parish Councils;

(iv) 4 environmental/conservation organisations;

(v) 2 residents' groups;

(vi) 2 Government Agencies; and

(vii) 1 Individual.

4.3 The number of responses this year is slightly higher than last year (18 this year, 12 last year). There was no response from any developers, GOSE or the Home Builders' Federation. Only two of the respondents disagreed with the Monitoring Paper's conclusion.

4.4 A summary of the main points arising from consultation responses with a response by the Strategic Planning Authorities is attached as an appendix. The following section summarises the key themes arising from the responses.

5. Main Points Arising from the Comments

Support for the Plan, positive comments and congratulations for Policy H4

5.1 The most frequent comment made by the District Councils, Government agencies and environmental and conservation groups was support for the Monitoring Paper's conclusions. Environmental and conservation groups also made positive comments regarding the Policy H4 process and its role in protecting greenfield land from development. The Strategic Planning Authorities were commended for adopting the policy in the first place and appreciation was expressed to the staff who have worked on the process.

Officer's Response

5.2 Support for the Monitoring Paper's conclusion and all positive comments are welcomed.

Comments from Planning Consultants

5.3 Planning consultants responded with concerns regarding the conclusions set out in the Monitoring Paper, relating to several issues. One consultant felt that there was conflict with Government guidance as he considered that the need for a "compelling" requirement to release the reserve sites was too onerous in the context of PPS3. It was also suggested that unrealistic assumptions have been made regarding housing delivery and by including windfall sites in the calculation. The consultant considered that there was a need to provide certainty for the delivery of housing land and with the delays in the progression of the South East Plan, Policy H4 should be used to facilitate the delivery of housing land in the period to 2011 and beyond. Both consultants considered that there was a need to look at the supply at a more local level within Hampshire and release reserve sites where there was a shortfall in supply.

Officer's Response

5.4 It is not considered that there is a conflict with Government guidance. Policy H4 was `saved' by the Government as recently as September 2007. This policy would not have been `saved' if it had been in conflict with Government policy. Housing targets in Hampshire have been exceeded and this is forecast to continue, so there is no need to release the reserve provision in order to meet current housing targets for Hampshire as whole.

5.5 The data used in the report is the best available and the adjustments to the supply are intended to ensure that estimates are realistic. The Government's guidance on assessing land availability and delivery was only published a few months prior to the collection of the data for this report; it was therefore too early to expect that all sites would have been subject to the detailed assessment set out in the guidance. It should be remembered that there are over 21,000 dwellings in Hampshire with full planning permission, that on their own could satisfy the residual RPG requirement.

5.6 The Government has been slow in publishing proposed changes to the draft Regional Spatial Strategy, but it would not be appropriate for the Strategic Planning Authorities to use this as a reason to release reserve sites.

5.7 It is agreed that in some parts of Hampshire there is less housing supply than in others. Whilst there is no need to release reserve provision to meet the current RPG requirement for Hampshire as a whole, individual districts will need to ensure that they have sufficient housing supply to meet their local requirements and manage the release of land as appropriate.

6. The Future

6.1 The South East Plan will supersede the remaining Hampshire County Structure Plan policies when it is finalised, which is currently expected in early 2009. With the demise of the remaining Hampshire Structure Plan policies, the Plan's reserve housing provision will also disappear, and with it the need to monitor housing land supply in relation to Structure Plan reserve housing releases.

6.2 In preparing their local development frameworks, Hampshire District/Borough Councils will need to identify sites to meet the housebuilding totals in the South East Plan. As part of this, they will decide whether to include in these site allocations the sites which comprise the Structure Plan's reserve housing provision.

7. Impact Assessments

7.1 Assessment of the Race Relations (Amendment) Act has been considered in this response but no adverse impact has been identified in terms of race, creed or gender.

8. Conclusion

8.1 The Policy H4 Monitoring Paper 2008 concludes that the forecast dwelling supply 2007-2011 exceeds the requirement in RPG. The total supply exceeds the RPG requirement by over 12,400 dwellings. This overall figure was subject to adjustments in recognition that not all potential housing will ultimately be developed within the timescales expected. The results show an adjusted figure that is still 9,700 dwellings above the RPG requirement. On the basis of this year's monitoring there is no compelling justification to release any of the Structure Plan reserve housing provision. The majority of the consultees supported the Monitoring Paper's conclusion, so on this basis the Panel should recommend the Strategic Planning Authorities not to release any of the reserve sites this year.

1638Rpt/SC

APPENDIX

POLICY H4 MONITORING PAPER 2008

Summary of main points arising from consultation

List of Respondents (in order of receipt)

1. Highways Agency

2. Rowlands Castle Parish Council

3. The Fareham Society

4. Old Basing & Lychpit Parish Council

5. Havant Borough Council

6. East Hampshire District Council

7. Winchester Meadows Conservation Alliance

8. Ron Tate (Planning Development Regeneration)

9. New Forest National Park

10. Oakley and Deane Parish Council

11. Environment Agency

12. Save Barton Farm Group

13. Campaign to Protect Rural England (CPRE)

14. Winchester City Residents Association

15. Lee-on-the-Solent Residents Association (LoSRA)

16. Fareham Borough Council.

17. Turley Associates

18. Mrs Jan Anderson