Archived decisions

Agenda Item: 11

HAMPSHIRE COUNTY COUNCIL

Decision Report :

EXECUTIVE SUMMARY

1) Summary of Decision Area:

1.1. This report sets out the key changes proposed by the Government to the draft South East Plan. Some of the Government's Proposed Changes take forward the recommendations in last summer's report of the independent panel which conducted an Examination-in-Public (EiP) into the submitted Plan; in other areas the Government is taking a different approach. The report recommends how the County Council should respond to the Proposed Changes.

2) Issues Covered in Report:

2.1. Key Government proposals which relate to Hampshire are:

a) endorsement of the submitted Plan's proposals for South Hampshire including the employment floor space totals, the housebuilding proposals and the two Strategic Development Areas;

b) general endorsement of the development strategy for the other parts of Hampshire but proposed additional housebuilding in five boroughs/districts;

c) proposed removal of the conditionality of development on the provision of infrastructure; and

d) proposed deletion of the region-wide and South Hampshire-specific policies on strategic gaps.

2.2. How the Government's Proposed Changes would implement EiP Panel's recommendations, notably those which the County Council regarded as unwelcome, and how for the districts affected it will be a challenge to accommodate the additional development.

2.3. The even higher regional housebuilding figure which the Government is requiring the Regional Assembly to consider during the coming review of the South East Plan.

3) Recommendations:

3.1. That:

(i) the Cabinet resolves to lodge objections to the Proposed Changes relating to increased housebuilding (with the exception of qualified support for the increase at Whitehill/Bordon), the conversion of the housebuilding targets into minimum figures, removal of the conditionality of development on the provision of infrastructure and the deletion of the Gap policies;

(ii) the Leader approves the formal documentation necessary to register these objections and objections/representations on more minor matters; and

(iii) the Leader writes to the Minister for Housing and Planning and to Hampshire MPs to express grave concerns over the Government's intention to promote even higher rates of housebuilding through the forthcoming Review of the South East Plan with apparent disregard for the independent assessment that the Region is approaching its environmental limits.

Agenda Item: 11

MAIN REPORT

1) Purpose of the Report:

1.1. This report sets out the key changes proposed by the Government to the draft South East Plan, to enable the Cabinet to decide on the County Council's response to the consultation on those proposed changes.

2) Contextual Information:

2.1. In March 2006 the South East England Regional Assembly (SEERA) submitted the South East Plan to the Government. It is the inaugural Regional Spatial Strategy (RSS) for the South East Region and is for the 20 year period 2006-2026. The South East Region extends from Hampshire northwards to Oxfordshire/Milton Keynes and eastwards to Kent, and also includes the Isle of Wight. When finalised, the South East Plan will replace all the Structure Plans in the Region.

2.2. An independent panel of three planning inspectors was appointed by the Government to conduct a type of public inquiry, called an Examination-in-Public (EiP), into the submitted Plan. The EiP took place during winter 2006/07; the Panel submitted its report to the Government in summer 2007 when it was also published. The report included recommendations on how the Plan should be amended in the light of the discussions at the EiP.

2.3. There was no consultation on the EiP Panel report, but the October 2007 meeting of this Cabinet resolved that a submission be made to the Government before its proposals for the South East Plan were published, detailing the Cabinet's:

(i) support for affordable housing whilst urging the Government to intervene in terms of adequate direct funding;

(ii) commitment to a plan, manage and monitor approach to development;

(iii) concerns about the Panel's recommendation for a major new development area on the western edge of Reading and how traffic would impact within Hampshire's borders;

(iv) strongly held view that infrastructure should precede, not follow, housing development;

and that the submission be copied to all Hampshire MPs.

2.4. The Government has now considered the EiP Panel's report and on 17 July 2008 published the changes which Ministers propose to make to the submitted Plan. Some, but not all, of the Proposed Changes mirror the EiP Panel's recommendations. There is a 12 week period of public consultation on the Proposed Changes which ends on 24 October 2008. Consultation is limited to the Proposed Changes only: the Government will not consider any comments made on those parts of the submitted Plan which it does not propose to change. After the close of consultation the Government will consider the comments received and then issue the definitive Plan, probably early next year.

2.5. The Proposed Changes are accompanied by an independent Sustainability Appraisal undertaken by consultants, which identifies and evaluates the impacts of the Plan if finalised in the way currently proposed by the Government. The Appraisal covers the economy, the community and the environment - the three dimensions of sustainable development - and suggest measures for improving the Plan's sustainability performance.

3) Key Issues:

3.1. Essentially, the submitted Plan has two components: a strategy and policies for the whole Region and, secondly, more detailed sub-regional strategies and policies for selected areas. The sub-regional strategies usually deal just with the economy, housing and infrastructure; other topics such as heritage conservation and green space are dealt with solely in the region-wide policies. Two sub-regional strategies cover parts of Hampshire: one for South Hampshire and the other for the Western Corridor and Blackwater Valley Sub-region of which North Hampshire is part.

3.2. In summary, the Government has endorsed the submitted Plan's proposals for South Hampshire including the employment floor space totals, the housebuilding proposals and the two Strategic Development Areas. It has generally endorsed the development strategy for the other parts of Hampshire but proposes additional housebuilding in five boroughs/districts. The Proposed Changes would remove the conditionality of development on the provision of infrastructure and would also delete the region-wide and South Hampshire-specific policies on strategic gaps.

Housebuilding

3.3. The EiP Panel recommended that provision for housebuilding in Hampshire (including Portsmouth and Southampton) should be increased from the 6,100 new homes per annum in the submitted Plan to 6,415. The Government's Proposed Changes go further, by proposing 6,685. The latter is a 9.6 per cent increase from the submitted Plan, but is less than proposed for all other South East counties except Buckinghamshire: for example, West Sussex up 29%, Surrey up 25%, Berkshire up 17% and Kent up 14%.

3.4. The Government's figures would mean 133,700 new homes built in Hampshire including Portsmouth and Southampton during 2006-2026, compared to 122,000 in the submitted Plan. The additional 11,700 homes would be in five districts: Basingstoke and Deane (2,400), East Hampshire (5,500 - all at Whitehill/Bordon), Hart (400), Test Valley (1,100 - all in the northern part of the Borough), and Winchester (2,300 - at Winchester city itself).

3.5. The Proposed Changes stipulate (as did the submitted Plan) that housebuilding provision at Basingstoke is subject to phase two of the studies now underway into wastewater treatment capacity, and that the housebuilding at Whitehill/Bordon - in the form of a new Strategic Development Area - will not need to be met elsewhere in East Hampshire District if a site of this size cannot be released at Whitehill/Bordon.

3.6. These qualifications echo a wider picture of the Region approaching its environmental capacity to accommodate more development. The Sustainability Appraisal which accompanies the Proposed Changes concludes that the Plan in the form now proposed by Government will have significant environmental costs, approaching environmental limits in parts of the region with regard to water quality, water resources, air quality, biodiversity and increased flooding.

3.7. The largest new housing proposal by the Government is 5,500 new homes at Whitehill/Bordon in the form of a Strategic Development Area (SDA). The objectives for this SDA include new employment, green infrastructure and enhanced town centre facilities. This would complement the proposed designation of Whitehill/Bordon as an Ecotown - a designation for which East Hampshire District Council and the County Council have expressed support. It is vital that new housing in the town is complemented by new jobs, infrastructure and town centre facilities, so the proposed new policy should require land to be allocated for these uses - as it does for the housing - instead of just expressing these as aspirations. This would avoid any risk of landowners/developers focusing solely on the more lucrative housing development.

3.8. A small but very significant proposed change is that the housebuilding figures for all districts should be minima rather than targets, raising the very real prospect that the housebuilding actually planned for in Local Development Documents may be required to be even higher than the figures in the Government Proposed Changes. At a time of economic downturn and when the housing market is severely affected by the availability and cost of credit, this approach seems at odds with reality. Apart from the potential environmental impacts of even higher housebuilding - bearing in mind the findings of the Sustainability Appraisal that the Region is approaching its environmental limits (see paragraph 3.6 above) - it will add to the burdens on already stretched infrastructure.

3.9. Moreover, as the Sustainability Appraisal states, this would mean a "changing, uncertain situation which does not provide a clear steer to infrastructure providers and does not provide them with the ammunition needed to negotiate adequate long term funding for infrastructure". The County Council, for example, plans for the future provision of school places on the basis of population forecasts which are themselves based on the amount of housebuilding planned. If there is uncertainty on the latter, due to the targets being minima, then reliable population forecasting will be impossible.

3.10. There are some elements of the Government's package which are to be welcomed. One is the endorsement of the affordable housing target (although actually achieving the target will require an increase in Government funding on which no assurances have been given), the other is the intention not to proceed with the EiP Panel's recommendation for a new SDA on the western edge of Reading (on which this Cabinet expressed concern - see paragraph 2.3 above).

Employment and Economy

3.11. The submitted Plan incorporated the advice provided by PUSH that 2 million square metres of new employment floor space should be provided for in South Hampshire 2006-2026, and the advice submitted by Hampshire County Council that 40-60 hectares of new employment land could be needed in North Hampshire during the same period. (The Plan did not quantify employment land/floor space provision in Central Hampshire and New Forest.)

3.12. The Government has endorsed the South Hampshire figures and, despite opposition from other local authorities at the EiP, proposes to retain the reference to the 40-60 hectares estimate. In addition, the Government intends to include the following statement in the final Plan in relation to employment land provision in the Western Corridor and Blackwater Valley Sub-region: "sufficient existing and allocated land may be available to meet the short term needs of the sub-region .... Local Authorities need to check this is the case but also to look beyond 2016".

3.13. That statement mirrors the uncertainty which the County Council had about whether the existing employment land supply would be adequate for requirements over the next 20 years; uncertainty which led the Council to commission a study of employment land needs in North Hampshire in conjunction with the three borough/district councils. That study has concluded that there is sufficient land in aggregate but it may not all be of the right mix to meet business requirements nor in the right locations to reflect Basingstoke's role as a regional hub. What is clear however is that the Government's reference to "40-60 hectares of new land being required in North Hampshire" is now out-of-date and officers of the County and Borough/District Councils are formulating a suitable form of words for inclusion in each authority's response to the South East Plan Proposed Changes (it is proposed that the Leader be authorised to approve this wording - see paragraph 5.1 below).

3.14. More widely, the Government has recognised the inadequacies of the economic dimension of the Plan. A new headline economic policy has been introduced highlighting the need to maintain the South East's contribution to the UK's long term competitiveness by ensuring that the spatial requirements for market flexibility are fully met in all parts of the region. The Government has also endorsed the EiP Panel's recommendation for an early partial review of the Plan to provide more robust guidance on the amount and location of employment land and floor space required.

Infrastructure

3.15. The County Council's population forecasting model predicts that the additional housebuilding proposed by the Government (paragraph 3.4 above) will result in about 25,000 more people living in Hampshire than under the submitted Plan. This model shows that all the additional housing will be for in-migrants (the majority from within the UK). The extra population will place additional demands on infrastructure and public services, yet the Government has refused to give any assurances on infrastructure funding for the housebuilding set out in the submitted Plan, let alone the extra which is now proposed.

3.16. The Government intends to proceed with the EiP Panel's recommendation to delete the submitted Plan's `Plan, Monitor, Manage' policy and the clause which would have made land releases for housebuilding conditional on the provision of the necessary infrastructure. However, the Government proposes to include a revised region-wide policy (CC7) on Infrastructure and Implementation which contains some positive statements, including (emphasis added): "The scale and pace of development will depend on sufficient capacity being available in existing infrastructure to meet the needs of new development. Where this cannot be demonstrated the scale and pace of development will be dependent on additional capacity being released through demand management measures or better management of existing infrastructure, or through the provision of new infrastructure. Where new development creates a need for additional infrastructure a programme of delivery should be agreed before development begins." It also states: "Funding will be provided by a combination of Central Government, Local Government and Private Sector partners, including substantial contributions from Central Government."

3.17. The Proposed Changes would also delete the equivalent policies in the sub-regional chapters of the Plan - including the South Hampshire and Western Corridor & Blackwater valley Sub-regions - in favour of this region-wide policy.

3.18. Whilst this evidence of the Government's recognition of infrastructure requirements is helpful, the deletion of the conditionality clause suggests that delivery of housing targets is a paramount consideration for Government and that the absence of infrastructure provision should not hold back development. The Government's own advisors who undertook the Sustainability Appraisal endorse the case for this conditionality; their report states "At the very least, the Plan should make clear that housing cannot and should not be delivered without adequate infrastructure being in place."

Other Topics

3.19. Strategic and Local Gaps have helped shape the pattern of new development in the Region outside Green Belts for at least two decades. The submitted Plan included a region-wide policy which set out criteria for the (re)designation of Gaps together with a South Hampshire-specific policy which listed seven locations where there should be Strategic Gaps. The Government proposes to delete both these policies, on the grounds that national Planning Policy Statements make no provision for such designations. However, the supporting text of the South Hampshire chapter states that Local Development Documents may put forward proposals for Local Gaps. The practical effect overall will be to undermine the longstanding protection of individual settlement identity with a heightened risk of coalescence of towns and villages.

3.20. It is suggested that the County Council should object to the deletion of the region-wide and the South Hampshire-specific Gaps policies, recognising that the region-wide policy is critical to the future of the Gaps which already exist in North Hampshire - between Fleet and Aldershot/Yateley, and between the latter and neighbouring settlements in Surrey (the Blackwater Gap). At the very minimum, there should be a similar statement in the Western Corridor and Blackwater Valley chapter of the Plan, to that which the Government proposes to add into the South Hampshire chapter (described in paragraph 3.19 above).

3.21. There are other Proposed Changes of a more detailed nature which it is not appropriate to deal with in this report. It is suggested that approval of these be delegated to the Leader.

Review of the Plan

3.22. Despite the Sustainability Appraisal's finding that the Region is approaching its environmental capacity, the Government remains set on even higher rates of housebuilding through a review of the South East Plan in order to achieve the Housing Green Paper target of 240,000 new homes per year nationwide. A partial review of the South East Plan was initiated by the Minister for Housing and Planning in a letter in July to the Chair of the Regional Assembly. It included a requirement that the Review should take account of the recently published advice from the National Housing and Planning Advisory Unit (NHPAU) on the number of new homes which are needed to cope with predicted household growth and to make housing more affordable.

3.23. NHPAU urges a particularly large increase in building rates in South East England: 30-72 per cent more than in the draft South East Plan. If this were to be spread evenly across the Region, housebuilding in Hampshire would rise to between 7,900 and 10,500 per year, compared to the draft Plan's 6,100. Many organisations have dismissed the NHPAU figures as unreal, and argue that building additional affordable housing is a more effective way to help people onto the housing ladder. Even NHPAU's own calculations show that a 50 per cent rise in housebuilding will have little effect on house prices.

4) Conclusion:

4.1. The Government's Proposed Changes would implement EiP Panel recommendations which the County Council regarded as unwelcome: increased homes, removal of their conditionality on infrastructure provision and deletion of the Gaps policies. This constitutes an unpalatable combination of increased development plus less certainty on associated infrastructure and reduced protection from urban sprawl. It is some consolation that the housebuilding increase proposed in Hampshire is less than in most other South East counties, but for the districts affected it will be a challenge to accommodate the additional development. Even more worrying is the still higher regional housebuilding figure which the Government is requiring the Regional Assembly to consider during the coming review of the South East Plan. In the context of the Sustainability Appraisal's assessment that the Region is approaching its environmental limits, this poses real fears for the future.

5) Next steps:

5.1. This report has set out the main changes on which it is suggested that the County Council should focus its response. If endorsed by Cabinet, these would need to be transposed onto the prescribed reply form with the addition of detailed reasoning to support them. It is proposed that the Leader approves this official documentation.

6) Recommendations:

That:

(i) the Cabinet resolves to lodge objections to the Proposed Changes relating to increased housebuilding (with the exception of qualified support for the increase at Whitehill/Bordon), the conversion of the housebuilding targets into minimum figures, removal of the conditionality of development on the provision of infrastructure and the deletion of the Gap policies;

(ii) the Leader approves the formal documentation necessary to register these objections and objections/representations on more minor matters; and

(iii) the Leader writes to the Minister for Housing and Planning and to Hampshire MPs to express grave concerns over the Government's intention to promote even higher rates of housebuilding through the forthcoming Review of the South East Plan with apparent disregard for the independent assessment that the Region is approaching its environmental limits.

1579Rpt/SR

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