Frequently asked questions regarding the Havant Borough Local Plan 2036.
Central Government requires all areas of the country to have a Local Plan. Havant Borough Council, in consultation with residents and businesses, is developing a Local Plan for the borough up to 2036.
It is also clear that there is an urgent need for new homes across the country. It is therefore essential that the council plans for the borough’s need for new housing over the next 20 years.
Once adopted, the plan will provide a blueprint for future development in the borough up until 2036.
This means as well as guiding the development of new housing, the plan will include proposals for commerce and community facilities such as schools and shops. Importantly the plan will make sure that the necessary infrastructure is provided to support new development and that the environment is protected.
Further information about the process can be found in the Local Plan 2036: What is it, how far we’ve come, how will it help our communities? booklet.
The Pre-Submission is the version of the Plan which the council considers to be ‘sound’ having taken on on-board extensive research, advice and public feedback, before it is formally submitted for examination by an independent inspector appointed by the Government.
The consultation on the Draft Local Plan highlighted the need to further consider the principle of development at Westwood Close (H10), land south of Lower Road (H22) as well as Northney and Sparkes Marina (H30).
This has resulted in the deletion of the proposed site allocation at Westwood Close which was included in the Plan at draft stage.
This is because the Environment Agency has confirmed that the land is needed for a River Ems Flood Alleviation Scheme to help adapt and mitigate the impact of climate change as well as addressing the wider flood risk issues in Emsworth. The land is proposed to be safeguarded for a flood alleviation scheme accordingly.
Land south of Lower Road and Northney & Sparkes Marina have been taken forward as site allocations in the Pre-Submission Plan.
These site allocations, together with any additional information submitted through the Draft Local Plan consultation have been further assessed through the council’s Site Screening work, Strategic Flood Risk Assessment and Sustainability Appraisal, and have been considered suitable for an allocation.
This consultation is for you to formally tell the Government Inspector whether or not you consider the council has prepared a sound and legally compliant Local Plan.
Parties wishing to submit their view must ensure their comments specify whether the Plan is sound and/or legally compliant.
The law requires comments are made in a certain way. We have designed a form to help you follow the Government’s requirements, and we have published a completed example as part of the guidance notes which accompany the form.
Additional support is available online. We are also running a series of drop in events where officers will be on hand to help you fill out the specific paperwork that is needed.
The borough’s existing Local Plan is out of date. As a result, it does not have as much weight in taking decisions and so policies on topics such as the environment and design cannot be applied as rigorously.
Without a new up-to-date Local Plan in place, development will happen in a piecemeal way without the necessary infrastructure to support the development.
At Pre-Submission stage, the plan can be given greater weight in decision-making. This means that the council is in a stronger position to sure that the necessary infrastructure can be provided alongside development, as well expecting new developments to be of a high quality.
This will include standards and requirements such as the nationally described space standard for new homes, and requiring development to be energy efficient and achieve carbon reductions.
Following consultation on the Pre-Submission Plan, the council will review all of the responses received and consider whether any changes are needed to the Plan before it is formally submitted to the Secretary of State for independent examination. In practice, this is an independent Inspector appointed on their behalf.
The independent Inspector will read and consider all of the supporting documents and comments made in response to the Pre-Submission consultation.
These will help the Inspector decide the matters they wish to explore in more depth at the examination hearings. At these hearings, the Inspector will invite the council and any other interested parties to be present to explore these matters in more detail.
Following the hearings, there may be changes proposed by the Inspector that could be subject to consultation.
At the end of the Examination, the Inspector issues a report setting out whether they consider the Local Plan to be legally compliant and sound and whether any changes are needed to make it so.
On the basis that it is legally compliant or sound, the plan will be considered by full council prior to adoption. Further information about the process can be found in the Local Plan 2036: What is it, how far we’ve come, how will it help our communities? booklet.
Is there really a need to deliver this much housing? The latest household projections show that the population will not grow as quickly as first thought
Central Government has made it clear that there needs to be a significant boost in the supply of new homes across the UK through the National Planning Policy Framework (NPPF).
This includes a commitment to deliver 300,000 homes a year on average by the mid-2020s. The NPPF expects every area of the country, including Havant Borough, to meet its local housing need.
The Government proposed a standard method of assessing local housing need in September 2017. The proposed methodology indicates the need for housing in the borough is 463 new homes a year. Since then, the Office for National Statistics have published new national population projections which indicate that the population is predicted to grow less rapidly than previously thought.
The Government has however subsequently confirmed that this does not mean that fewer houses are needed and that councils should continue to use the September 2017 figure (463 for Havant Borough) as a starting point for calculating housing need.
The Pre-Submission Plan therefore includes the development of 10,231 new homes across Havant Borough between 2016 and 2036. This will meet the borough’s housing need and a buffer of 971 homes to provide flexibility to accommodate changing circumstances which is a requirement of the NPPF.
The NPPF also expects the council to work together under the ‘Duty to Cooperate’ to address the need for housing across the Portsmouth housing market area. This housing market area includes all of Havant, Portsmouth and Gosport and parts of East Hampshire, Fareham and Winchester.
The council is committed to delivering regeneration and investment in high quality new homes, business, facilities and our town centres so the borough continues to be an attractive place to live, work and invest.
So this can be achieved, the Pre-Submission Local Plan proposes the development 10,231 dwellings and 96,759 square meters of commercial floorspace. It also includes a number of thematic policies which will help to guide development and make sure that it is delivered in a sustainable manner.
To help meet the planned level of development, the council is proposing a bold strategy. This will include substantial development in Havant, Waterlooville and Leigh Park centres, and Hayling Island Seafront and marinas to reinvigorate these areas and regenerate the borough as a whole.
The Pre-Submission Plan promotes development on brownfield sites as far as practicable, but brownfield sites will not be enough to meet the overall need for development. Extensive development on greenfield sites will also be necessary.
As mentioned above, the Pre-Submission Plan can start to be given greater weight in decision-making. Following its publication, there is additional weight than simply having a Draft Local Plan.
However, following this consultation and before it is adopted, the Plan will need to be scrutinised by an independent Inspector whom is appointed on behalf of the Government.
The Inspector will examine whether the Plan has been prepared in line with legal and procedural requirements and meets a number of specific ‘soundness’ criteria set out in national guidance.
It cannot be afforded the same weight at the council’s Adopted Local Plan until it has been adopted by the council. The plan cannot be adopted until the Plan has been found ‘legally compliant’ and ‘sound’ by the independent Inspector.
A review of infrastructure has taken place through work on the Infrastructure Delivery Plan and has been a significant area of focus since the adoption of the Local Plan Housing Statement.
The council has been working closely with infrastructure and service providers, across thirty infrastructure areas, to understand the impacts of development on the borough’s infrastructure, to identify what is needed to mitigate the impacts and when.
This work has informed the production of the Pre-Submission Local Plan and the evidence base that supports it. This extensive analysis can be found in the Infrastructure Delivery Plan (IDP).
Two transport assessments have also been produced to assess the impact of development on the borough’s highway network. These can also be found at the link above. See also “What about the impact on our roads?” below.
The Infrastructure Delivery Plan forms part of the evidence base for the Local Plan. It assesses the infrastructure capacity and needs of the borough and provides an overview of the way infrastructure is planned and the organisations involved in its delivery.
The IDP examines the current situation with infrastructure capacity and identifies the improvements and/or upgrades which are needed in order to maintain the borough’s infrastructure network as a result of the planned levels of growth in the Pre-Submission Local Plan.
It also looks at costs and likely funding mechanisms for infrastructure and forms the basis for assessing contributions that would be sought to meet the needs for new development. The IDP has been updated to take account of the results of the transport work.
This has involved detailed discussions with infrastructure providers and an assessment of what investment may be needed in a particular network in order to accommodate development.
Together with Hampshire County Council, the Local Highways Authority, we have considered the impact of the proposed development in the Pre-Submission Local Plan on the local road network through the production of two Transport Assessments.
The mainland provides a high-level analysis of the impact on the road network using a Sub-Regional Transport Model (SRTM). It looks at what level of traffic congestion would occur anyway, without any further development taking place. Traffic likely to result from new developments has then been added to assess the impact on the borough’s highway network.
In addition to the above, the Hayling Island Transport Assessment and its associated modelling goes into a huge amount of detail regarding the island’s transport network.
In a number of cases, these studies have shown that development needs to secure specific highway schemes are needed in order to make development acceptable in planning terms. The Pre-Submission Plan identifies key schemes which are needed in order to mitigate and support development proposals.
Previous consultations have highlighted the need for the council to investigate specific infrastructure issues on Hayling Island.
This has included analysis of the sustainability of future development in the borough through the Infrastructure Delivery Plan (IDP), as well extensive transport studies, notably the borough-wide Transport Assessment and the Hayling Island Transport Assessment.
The latter study in particular provides a more detailed analysis of the entire highway network on the island using a model designed for this purpose.
It is more detailed than the SRTM and will enable the council to look at detailed mitigation measures to
maintain and improve the functionality of the island’s highway network. This work has been used to identify key schemes which are needed to mitigate and support development proposals.
I don’t agree with the mitigation presented in the Local Plan Transport Assessment. What is the status of the mitigation measures in the TA?
The Transport Assessment (TA), together with the rest of the evidence base supporting the plan, is subject to consultation on the soundness and legal compliance of the Local Plan.
If commenting on the TA, please bear in mind the status of the mitigation package presented in the Mainland Transport Assessment (though it is also relevant on Hayling Island) document:
It is the function of the Local Plan TA to assess the impact, as a whole, of the development proposed through the Local Plan. The junctions considered in the Local Plan Transport Assessment are those identified by a sub-regional transport model as most likely to require works to accommodate the Local Plan development.
It is important to note that the mitigation presented is to demonstrate that the overall level and broad distribution of development proposed is capable of mitigation.
It is not intended to present a preferred package of works or to advocate specific junction designs. It also does not necessarily represent an exhaustive list.
The TA demonstrates that the overall Local Plan development, if accompanied by a mitigation measures proposed, can be accommodated on the network without causing severe traffic impacts within the borough.
It is not designed to test or propose mitigation to deal with the effects of individual development sites. The local transport impacts of each of the Local Plan developments will still have to be addressed in Transport Assessments accompanying planning applications in accordance with guidance in the National Planning Policy Framework (NPPF) 2018.
The council, with its partners, will also continue to consider what mitigation measures are required, and work to deliver them.
The council has looked carefully at the impact on the local road network through the borough-wide Transport Assessment (TA).
The Transport Assessment suggests that the development may not need direct access onto the A27 but also caveats that due to the nature of the model it is not
possible to isolate the impact on the highway network from any particular sites. Before any planning application is submitted, the Pre-Submission Plan is therefore clear that it will be necessary to test in further detail as to whether there is a need for access from the strategic site directly onto the A27.
The Local Plan also safeguards land (Policy IN2) for such an access, until such time that it is irrefutably demonstrated that it is not required. If further testing shows that it is required, the policy for the Strategic Site (KP5) requires the delivery of the junction and the link road through the site.
The Pre-Submission Local Plan proposes sites which are sufficient to provide 10,231 new homes.
This will address the borough’s objectively assessed need for housing (9,260 new homes) and provide a surplus of 971 homes, about 10% of the borough’s overall housing need.
The surplus will make sure the plan is flexible to accommodate unforeseen circumstances in accordance with national guidance. Importantly it will allow for a rapid response to changes in the economy such as growth and recession.
Housing need is made up of natural changes to the population and migration, both domestic and international. However 95% of the borough’s residents are British. The population is naturally rising and together with an increasingly elderly population, this creates additional housing need.
The Government’s new standard methodology to calculate housing need is based on past trends. The latest projections show that the population is not expected to grow as rapidly as first thought. However, the Government have confirmed that local
population growth is not necessarily an indication of housing need, and local planning authorities should continue to significantly boost the supply of housing. This will not change as a result of Brexit.
When considering which greenfield sites are suitable for allocation, the council has sought to prioritise sites of a lower agricultural quality.
However, the available evidence is that the majority of land in the borough is of the best and most versatile quality (BMV).
Therefore the allocation of housing sites on BMV is unavoidable if the borough is to meet its housing need.
Where it has been necessary to allocate larger greenfield sites, the Pre-Submission Local Plan identifies a need for the development to include community growing provisions such as allotments as part of the open space provision.
The council considers this necessary to offer additional benefits in order to outweigh the loss of greenfield land.
What about separation between settlements – the Pre-Submission Plan is proposing to build on the only gap left between Havant and Emsworth
The council has prepared a policy which sets out an overarching framework for the delivery of the Southleigh strategic site.
This is based on the masterplan which has been developed following two design workshops with residents in early 2017.
The design workshops guided the masterplan process to identify a proposed form of development, with a settlement weighted toward Denvilles but with its own identity and separated from Denvilles by a landscape corridor.
Before planning permission is granted, the council will expect the developer to take the 2017 published Framework Masterplan as a starting point and continue community engagement through further detailed masterplanning.
Providing all parties to the original agreement signed in 1991 are happy, the legal agreement can be amended to allow development to take place.
For example, this recently took place to allow the development of the Oaks Crematorium on Bartons Road.
The council recognises that smaller homes can affect both the physical and mental health of occupants.
The Pre-Submission Plan requires new homes to meet a minimum gross internal floorspace area based on the number of occupants, as well as size requirements for bedrooms, storage and the height of rooms from floor to ceiling.
As part of making sure new homes provide sufficient space for basic daily activities and needs, the Pre-Submission Plan makes it clear that new homes should benefit from outdoor amenity space.
The council considers these provisions necessary to support a good quality of life, and help occupants to lead healthier lifestyles and improve wellbeing.
The Pre-Submission Local Plan sets out a clear requirement for development to consider climate change, particularly through design and layout, using simple ideas like the orientation of buildings to maximise solar gain, and ensuring that new buildings are energy efficient and make use of natural ventilation.
Specifically new homes will be required to emit 19% less carbon emissions than the national standard.
Proposals will also be expected to reuse existing buildings on a site and building materials wherever possible.
We need more affordable homes, not just market housing. Isn’t this requirement usually just argued away?
The borough’s large need for affordable housing will have to be met primarily through securing a proportion of affordable housing as part of schemes brought forward through the market.
The Pre-Submission Plan sets outs an overall requirement for developments of 10 or more homes to provide 30% affordable homes (outside our town centres).
The Pre-Submission Local Plan sets out a robust approach to negotiating affordable housing.
However, the council are required to negotiate with developers if providing the full amount of affordable housing would render a development unviable. If this would be the case, the applicant will be expected to demonstrate that the maximum amount of affordable housing which is feasible is provided.
Affordable housing is defined by the Government and principally involves homes rented at 80% of market value, discounted market sales and part-rent-part-buy shared ownership products.
The Government have also introduced a requirement for 10% of major sites (10 dwellings or more) to provide affordable home ownership products.
Starter homes (discounted homes for purchase by first time buyers) are included as a kind of affordable home ownership at national level. However, the average levels of earnings and savings in the borough mean that starter homes would not be within reach for the vast majority of those registered with Help to Buy South (the local Help to Buy agent).
The Pre-Submission Plan makes clear that affordable home ownership products should be provided as shared ownership.
There is generally a need for smaller properties in the borough, particularly one and two bedroom homes. However, in the council’s experience one bedroom properties are quickly outgrown in a relatively short timeframe.
The Pre-Submission Local Plan sets out a requirement for 35% of new homes to be 2 bedrooms on larger sites (10 dwellings or more).
This should form part of a range of mix and types of new homes which will meet local housing needs, which should help to facilitate downsizing and release under occupied homes for families.
More than 49% of the borough’s population will be aged 60 or above by 2036. Housing for older people takes many forms including care homes, nursing homes, and supported living accommodation.
It includes annexes and extensions to existing housing, as well as adaptations to existing homes.
The Pre-Submission Local Plan includes a number of provisions to support the delivery of homes which meet the needs of older people:
- Standards for adaptable housing to make sure that new homes can easily be changed to accommodate the needs of a wide range of occupants, including older people.
- A requirement for 2% of housing on larger developments to be wheelchair accessible
- New developments for retirement or institutional housing for older people will be supported provided they meet a local need. Alongside this, the plan identifies a number of sites which are considered to be suitable for older persons’ housing.
- A requirement for 35% of new homes to be 2 bedrooms on larger sites (10 dwellings or more) as part of a mix of home types and sizes will increase the supply of smaller properties, and help those looking to downsize from family housing.
The Pre-Submission Plan contains specific policies to manage flood risk and make sure that drainage infrastructure provided as part of new development is effective.
Specifically these policies will mean that planning permission will only be granted where development is safe over its lifetime and will not increase flood risk elsewhere.
This will also mean ensuring that there is no net increase in surface water run-off rates as a result of development, as well as making sure that drainage systems meet the needs of the development in full, over its lifetime
The importance of protecting wildlife in the borough is specifically highlighted in the Pre-Submission Plan which contains specific policies that address biodiversity.
This recognises the different levels of protection for sites and species according to their status in law, and sets out how the impact on each would be avoided and managed.
The policies in the Pre-Submission Plan have been put together in collaboration with Natural England, the government’s statutory advisor on nature conservation.
It is essential there is a balance between housing and employment (jobs).
Dunsbury Park will deliver substantial new employment floorspace alongside other supporting uses, including a hotel. There is also a significant opportunity to bring in new jobs and investment with the redevelopment/refurbishment of Langstone Technology Park in Havant town centre.
The redevelopment and regeneration of established employment areas will also help support the borough’s long-established manufacturing base, whilst delivering modern business and industrial accommodation fit for the 21st century.
Marina sites will also be protected recognising their specific locational requirement.