Dear Sir / Madam
Please find attached submissions made on behalf of Portsmouth Estates in respect of the Council’s Local Plan Update Reg18 Consultation.
Submissions are made in respect of:
- Emerging Policy SPS1: Scale and Distribution of Development
- Emerging Policy SPS5: Sites Allocated for Housing Led Development
- Emerging Policy SPS5.5 Popham Garden Village
- The Emerging Infrastructure Delivery Plan
- Emerging Policy SPS5 - Omission site submission
We have completed the submission forms with a skeleton case and have attached a more detailed evidence-based representation containing full details.
Please can you confirm receipt?
Kind regards
Mark
Basingstoke and Deane Local Plan Update 2021 to 2040 Draft for Regulation 18 Consultation January 2024
Policy SPS1: Scale and Distribution of Development
Object
We welcome the use of the Standard Methodology as the starting point for determining the housing requirement over the emerging plan period subject to confirmation that the housing needs of different groups in the community (as defined in Paragraph 63 of the NPPF) can be met within that figure and that account is given to the unmet needs of adjoining authorities, should they exist.
We also support the spatial strategy’s focus at Basingstoke; the place that generates the majority of the Borough’s housing requirement. Basingstoke also being the most sustainable and generally unconstrained location for strategic levels of development. Fundamentally, Basingstoke generates the greatest need for housing within the Borough, and as such it is correct to place the bulk of the Borough’s housing requirement at the town and its immediate environs.
Windfalls
In terms of delivering the level of housing development necessary to meet the needs of the community, we note that an allowance is made for small scale (less than 10 units) windfall sites and acknowledges that evidence of historic delivery of such sites is available and that Policy SPS1 provides a reasonable framework for such development to continue and, therefore, we would expect an Inspector to concur.
However, we would respectfully guide against any suggestion that any identified shortfall due to delivery rates/viability of the emerging allocations might be plugged by the introduction of an additional housing supply assumption based on large scale windfalls. From experience, we believe the Examination into a large-scale windfall allowance is likely to conclude such an approach to be unsound. We say this mindful of the historic circumstances behind the decisions to allow large scale windfall site/planning applications over the past 6 years or so. Particularly as over 650 dwellings have been granted on appeal on large scale sites, since 2018 while the Council has been unable to demonstrate sufficient housing land supply.
We also note that the Spatial Development Policies establish an approach to encourage regeneration proposals and opportunities within Basingstoke town (Policies SPS2 and SPS3) for some 600 dwellings as well as opportunities within neighbourhood plans (Policy SPS6) such that there is no need for an allowance for other windfalls.
Stepped Trajectory
We note that the NPPG states:
‘A stepped housing requirement may be appropriate where there is to be a significant change in the level of housing requirement between emerging and previous policies and / or where strategic sites will have a phased delivery or are likely to be delivered later in the plan period. Strategic policy-makers will need to identify the stepped requirement in strategic housing policy, and to set out evidence to support this approach, and not seek to unnecessarily delay meeting identified development needs. Stepped requirements will need to ensure that planned housing requirements are met fully within the plan period. In reviewing and revising policies, strategic policy-makers should ensure there is not continued delay in meeting identified development needs. (our emphasis).
We are concerned that, at present, there is insufficient evidence to support such a stepped trajectory in Policy SPS1 and believe there is a high risk that the plan may be found unsound if a stepped trajectory approach is maintained.
Concentrated, imbalanced distribution of development.
We are concerned that, as drafted, the emerging Local Plan update is reliant upon an excessively concentrated, imbalanced, distribution of development focused on a small geographic area. Nationwide evidence suggests such concentrations negatively impact on delivery rates. Approximately two thirds of the assumed housing delivery in the plan period, some 8,150 new homes, is forecast to come from four sites in a single geographic area (Basingstoke Golf Club; Hounsome Fields; Northern Manydown; and Southern Manydown).
No apparent consideration has been given to the fact that a concentration of housing land supply in such a constrained geographic area will limit the achievable delivery rates due to market absorption issues. This will have the effect of reducing the number of homes that could be delivered compared to if these sites were spread over a wider geographic area.
From a supply perspective, a house builder is less likely to invest in opening a second outlet on an adjoining development site as it is likely to compete directly with its existing offering, thus limiting supply to the market. This would not be a consideration if the development sites were more geographically spread across Basingstoke and perceived as attracting a different market share. Similarly, purchasers are driven by choice and location. If most of the housing supply is concentrated in one location, it is inevitable that the level of buyer demand is limited as that location will not be attractive to all buyers.
We believe this to be an important matter on which the Examination is likely to conclude results in the plan being unsound. It also places greater reliance on the key shared infrastructure that is required to deliver these sites, as any delay in said provision will significantly impact on the plan’s timely delivery of new homes.
We are aware of the Competition and Markets Authority’s final report on the ‘Housebuilding Market Study’ (published on 26 February 2024). The conclusions being that build-out rates are determined by housebuilders in accordance with the incentives to maximise the price at which they sell homes rather than to aim for higher volumes. The report notes that there is strong evidence ‘…that housebuilders generally respond to the incentive to maximise prices by building homes within a local market at a rate that is slower than the pace at which they could otherwise build them. This evidence shows that instead of seeking to sell homes as quickly as possible, housebuilders tend to sell them at a rate that is consistent with the local absorption rates – the rate at which houses can be sold without housebuilders needing to reduce their prices (‘Housebuilding market study’ Final Report paragraph 4.108). This reinforces our assertion, that housebuilders are likely to slow down delivery in areas where there are risks of market absorption to protect their margins.
Please see the attached evidence based submission for further details.