Draft Housing and Employment Allocations
a. What is the Housing and Employment Allocations Plan?
1.1 The East Hampshire District Local Plan: Housing and Employment Allocations will form part of the statutory Development Plan for East Hampshire District. Its primary purpose is to allocate greenfield land for housing and employment and to set out guidance for the development of these sites. It should be read in conjunction with the other parts of the Development Plan which, on the adoption of this document, will comprise the following:
- Saved Policies of the East Hampshire District Local Plan: Second Review (March 2006)
- East Hampshire District Local Plan: Joint Core Strategy (adopted by East Hampshire District Council (May 2014) & South Downs National Park Authority (June 2014))
- East Hampshire District Local Plan: Housing and Employment Allocations
- Hampshire Minerals and Waste Plan (October 2013)
1.2 Housing and employment site allocations are currently the main priority in the planning system that is why this Local Plan focuses on these issues. In the future another part of the Local Plan that updates the Saved Policies of the East Hampshire District Local Plan: Second Review will be created and form part of the statutory Development Plan. This will consider revisions to Settlement Policy Boundaries, Gaps between settlements, Special Character Areas and other Development Management Policies.
1.3 For the remainder of this document this version of the East Hampshire District Local Plan: Housing and Employment Allocations will be called the Draft Site Allocations Plan.
1.4 The Draft Site Allocations Plan directly takes forward Policy CP3: New Employment Provision and Policy CP10: Spatial Strategy for Housing in the Local Plan: Joint Core Strategy (JCS). Policy CP10 of the JCS sets an overall target of 10,060 new homes to be built over the plan period (up to 2028). The majority of that target is accounted for in existing planning permissions, existing undeveloped allocations from previous plans and from estimates of development on small sites (windfalls). The Draft Site Allocations Plan is focused on identifying specific sites to meet the residual requirement after existing permissions etc. have been taken into account; these specific sites will normally be on green fields.
1.5 The Draft Site Allocations Plan is the first formal stage of the plan making process as set out in Figure 1 below. Evidence gathering has been continuing from the Local Plan: Joint Core Strategy process. East Hampshire District Council has also undertaken early community engagement through the Local Interim Planning Statement (LIPS) events.
Figure 1: Illustrates the formal stages the plan is taken
through to adoption
in accordance with the Town and Country Planning (England)
1.6 It must be noted that the Draft Site Allocations Plan only covers the area of East Hampshire outside the South Downs National Park (SDNP) as shown in Map 1 below. Within the SDNP the Park Authority is the Local Planning Authority and will be producing a separate Local Plan for the whole of the South Downs National Park. For all information about planning in the National Park please see their website www.southdowns.gov.uk/planning.
b. National Planning Policy
1.7 National planning policy is set out in the National Planning Policy Framework (the Framework). Local Plans must be prepared within the context set by the Framework that embodies a 'presumption in favour of sustainable development' (defined as 'meeting the needs of the present without compromising the ability of future generations to meet their own needs')1.
1.8 The Framework states that all plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally.
c. The East Hampshire Context
1.9 The JCS sets out the Council's overall approach towards the local application of sustainable development through its objectives and core policies. The JCS was jointly prepared by East Hampshire District Council and the SDNPA. The National Park covers 57% of the District and splits the area managed by East Hampshire District Council into two halves, one south of the National Park known as the southern parishes and an area to the north of the National Park. The splitting of the district into two separate Local Planning Authorities creates some added complexity for place shaping for example the main towns of Petersfield and Liss are both part of East Hampshire as a place but in planning terms are dealt with independently by the SDNPA.
1.10 The JCS is the overarching planning policy document for the District. It sets out the strategy for the future development of the District over the period to 2028 and was prepared and examined as complying with the requirements of the Framework. The JCS identifies the overall spatial vision and economic, social and environmental objectives for the District and the amount, type and broad location of development needed to fulfil those objectives. The Draft Site Allocations Plan identifies and allocates specific sites suitable for development in order to meet the JCS's requirements for housing and employment and in so doing makes a major contribution to delivering the objectives within the JCS. The Draft Site Allocations Plan covers the same plan period as the JCS for the 43% of the District outside the South Downs National Park.
1.11 The Draft Site Allocations Plan sets out what type and level of development will be promoted throughout East Hampshire’s planning area. The Plan will provide more certainty for local communities, landowners, developers and infrastructure providers about the future pattern of development. Specific development proposals for the sites identified in the Plan will, however, need to gain planning permission before development can take place.
1.12 Within the area to the north of the National Park is Whitehill & Bordon, the second largest town in the district and currently a base for the military who are in the process of relocating. It is identified in the JCS as a strategic allocation for up to 4,000 dwellings (2,725 over the Plan period to 2028). The strategic allocation does not form part of this Draft Site Allocations Plan and is proceeding on the basis of policy guidance provided in the JCS and through a masterplan and a series of planning applications.
1.13 Other significant settlements to the north of the National Park identified in the JCS include Alton, Liphook, Four Marks/South Medstead and Grayshott, each providing a range of facilities for their local populations.
1.14 The area to the south of the National Park has three significant settlements, Horndean, Clanfield and Rowlands Castle.
1.15 In East Hampshire as a whole the JCS includes provision for a minimum increase of 10,060 new dwellings in the period 2011-2028 and for about 21.5ha of additional employment land. In terms of residential development, this breaks down into 8,366 dwellings (492 dwellings per annum (d.p.a)) in the East Hampshire local planning authority area and 1,694 dwellings (100 d.p.a) within the SDNPA. In terms of employment, the total requirement is apportioned between Whitehill & Bordon (9.5ha), Alton (7ha), Horndean (2ha) and Petersfield (3ha). Some of these requirements have already been met through development that has taken place and through planning permissions granted since 2011.
1.16 The spatial strategy specifically for housing is set out in Policy CP10 of the JCS and requires allocations to be made to meet the following levels of housing in East Hampshire District (outside the National Park):
- a minimum of 700 dwellings at Alton and Horndean;
- a minimum of 200 dwellings at Clanfield;
- a minimum of 175 dwellings at both Liphook and Four Marks/South Medstead;
- a minimum of 150 dwellings at Rowlands Castle;
- a minimum of 150 dwellings at other villages outside the National Park.
1.17 The use of ‘minimum’ targets does not mean that there is no ceiling to the housing targets. The Inspector’s report into the JCS was clear that, whilst the 10,060 new homes target for the whole of the district over the plan period was the minimum needed to meet the objectively assessed need, the figure of 10,370 would meet all the need. Therefore a relatively small degree of flexibility is needed around the housing targets.
1.18 A key challenge for the housing targets for the District is the provision of affordable housing. Policy CP13 of the JCS seeks a 40% element of affordable housing (35% in Whitehill and Bordon) to be provided on all new housing sites. Therefore affordable housing will be sought on all the sites allocated in the Draft Site Allocations Plan. Policy CP14 of the JCS also allows the allocation of sites specifically for affordable housing at those settlements with a settlement policy boundary that have a specific local need. Whilst that has been considered in the assessment of the sites it has not been possible to identify any specific sites to provide for this form of housing.
1.19 Employment provision and distribution in the District is set out in Policy CP3 of the JCS which requires the provision of land for employment use in East Hampshire district (outside the National Park) for:
- about 7ha of employment land in Alton;
- about 2ha of land in Horndean for industrial (B2) and business use (B1).
The Draft Site Allocations Plan contains specific site policies to meet these requirements.
d. Neighbourhood Planning
1.20 Neighbourhood planning is a new element of the planning system introduced in 2012 through the Localism Act. A fundamental principle of neighbourhood planning is that it is community-led, with the community establishing local planning policies for development and use of land within its neighbourhood. Neighbourhood Plans enable local people to play a leading role in responding to the needs and priorities of the local community.
1.21 In East Hampshire District, the appropriate bodies for producing Neighbourhood Plans are the Town and Parish Councils. Production of a Plan is at the discretion of those Councils. A Neighbourhood Plan must generally conform to the District’s Local Plan and can promote more but not less development than the Local Plan. Once a Neighbourhood Plan is adopted it will become part of the Development Plan for the District and will be used to assess and determine planning applications within the Neighbourhood Plan’s designated area.
1.22 In East Hampshire; Alton, Bentley, and Medstead and Four Marks are the three areas currently designated as Neighbourhood Plan areas. There are also Neighbourhood Plans evolving within the South Downs National Park part of the District. Where a community is developing a Neighbourhood Plan the District Council is working with the group to integrate their emerging proposals and their local community engagement into the Draft Site Allocations Plan. This is to ensure that as our plans progress the District Council can progress allocations at the settlements if the Neighbourhood Plan fails to progress, for example at the referendum. The guiding principle will be that the Draft Site Allocations Plan contains the latest Neighbourhood Plan proposals and the Neighbourhood Plan takes precedence where it is positively progressing. If further settlements gain designation as Neighbourhood Plan areas, and alternative sites are identified through that process, then they take precedence over the allocations in this draft Plan.
e. How have policies in the Draft Site Allocations Plan been formulated and allocated sites selected?
1.23 Local Plans provide a framework for everyone involved in planning and development to use to understand the future and reduce uncertainty. The policies in plans therefore need to be sound. A robust evidence base is the technical bedrock of a plan, which is tested through sustainability appraisal and subjected to community engagement and the democratic processes that ultimately decide the content of the Submitted Local Plan. That Submitted Local Plan will then be examined to assess whether it is positively prepared; justified; effective and consistent with national policy2.
1.24 Evidence Base: As the Draft Site Allocations Plan follows on from the JCS the significant amount of evidence used to justify the soundness of that plan has formed the basis of this plan. The JCS evidence has been reviewed to ensure that it remains up to date, relevant and proportionate to justify the soundness of the Draft Site Allocations Plan in accordance with the Framework and the Town and Country Planning (England) Regulations 2012. Where new evidence has been required it has been subject to rigorous technical assessment and consultations with the relevant professionals and organisations. The creation and updating of evidence is an ongoing process throughout the evolution of the Draft Site Allocations Plan with the most important considerations being:
- the Strategic Housing Land Availability Assessment (SHLAA) - the pool of sites from which specific allocations are selected,
- the Employment Land Review (ELR),
- Viability Assessments,
- the Infrastructure Delivery Plan,
- Transport Assessments,
- the Habitats Regulations Assessment (HRA), and
- the Strategic Flood Risk Assessment (SFRA).
1.25 Sustainability Appraisal (SA): The Draft Site Allocations Plan has been prepared alongside and integrated with a Sustainability Appraisal (SA). This is in order to both meet the requirements of the Strategic Environmental Assessment (SEA) Directive and provide a methodological framework tool to demonstrate how the plan evolves. The sites and policies identified in the Plan have been appraised against the SA’s sustainability objectives (social, environmental and economic) on an iterative basis with recommendations during the process as to how sustainability can be improved and in particular which sites rise to the top of the SHLAA site pool.
1.26 Consultation on the evolving SA is undertaken alongside the consultation on the Draft Site Allocations Plan as part of the iterative sustainability appraisal process. Further iterations will be made as the plan making process continues. The SA will provide a narrative of how it has influenced changes and decisions on the Draft Site Allocations Plan through the different iterations.
1.27 Community Engagement: The programme for the Draft Site Allocations Plan is being accelerated as a Council priority in response to the market, national policy and local political context in East Hampshire. The housing targets adopted in the JCS for East Hampshire are a significant increase over previous local plan targets. This coincides with the Framework’s presumption in favour of development, government financial incentives to stimulate house building and a confidence in communities to embrace localism through Neighbourhood Planning. These factors have resulted in the Council receiving the largest amount of major housing proposals it has ever faced and increasing community scrutiny.
1.28 The Framework is clear that we have a 'Plan led system'. However, that is caveated that where there is no full Local Plan then the presumption in favour of sustainable development takes precedence. Therefore all the individual planning applications that the Council has received are being considered on their individual merits rather than comprehensively through the plan making process. The Draft Site Allocations Plan will provide communities and developers the opportunity to engage with the overall picture of sustainable development in the District. However, it must be recognised that a number of sites that may have evolved or not as allocations in the Draft Site Allocations Plan will already have planning permission before this plan is formally adopted.
1.29 In order to inform communities of the ongoing planning situation in East Hampshire the Council has undertaken preliminary community engagement on the housing and employment site options covering the whole area outside the SDNP. A commentary of the events has been produced into Local Interim Planning Statements (LIPS). The LIPS events have kicked off the plan process and stimulated significant community interest, particularly where sites are already subject to planning applications. Attendees to the events were able to select site preferences and these have fed into the Draft Site Allocations Plan. Community engagement will continue to be integrated into the Draft Site Allocations Plan and where Neighbourhood Plans are emerging the results of their community engagement will be taken on board.
1.30 Development Delivery: It is important to ensure there is a reasonable prospect that the Draft Site Allocation Plan’s proposals can be implemented over the Plan period and that a sufficient amount of land is readily available to meet short term needs. An increasing number of the potential housing sites in the Draft Site Allocations Plan are already subject to planning applications. Planning applications provide a greater level of detail about the deliverability of a site than would normally be the case in a Local Plan. Where there are applications there is therefore a strong indication about the deliverability of the site.
1.31 Whilst the sites subject to planning applications provide good evidence on deliverability the Council has contacted the owners of allocated sites in order to obtain an indication of the time frame within which sites could be made available for development. The Council has also, as part of its site assessment process, investigated any likely barriers to the development of sites to establish realistic assumptions about the likely timing of development. The cost of requirements likely to be applied to development proposals, such as contributions towards additional infrastructure have been taken into account through the Council's work on the Community Infrastructure Levy to ensure that overall the Plan's proposals are economically viable.
f. Duty to Co-operate
1.32 The Draft Site Allocations Plan follows directly on from the JCS that was produced in partnership with the South Downs National Park Authority (SDNPA) and was examined and found to be sound and compliant with the Duty to Cooperate. Although no longer producing a joint plan the partnership with the SDNPA continues to be fundamental to the future place shaping of the District. Partnership working continues to evolve as each planning authority develops its local plan and work with its communities on Neighbourhood Plans.
1.33 East Hampshire District Council is committed to partnership working and is developing wider relationships on significant cross border development issues through the Enterprise M3 and Solent Local Enterprise Partnerships and the Partnership for Urban South Hampshire (PUSH). A statement will be Submitted with the Site Allocations Plan setting out how the Duty has been met.
1 The NPPF sets out the government's definition of sustainable development and the three dimensions of economic, social and environmental roles of planning 2 See paragraph 182 of the NPPF