Comment
How the revised standard method for assessing housing need is impacting the Fareham Local Plan
The Fareham Local Plan 2037 has been published for consultation under Regulation 19. Fareham Borough Council (FBC) has been affected by the Government’s proposed changes to the standard method for assessing local housing need, with a suggested reduction in need speeding up the plan-making process.
Consultation on the Government’s proposed planning reforms, which include proposals on the new standard method for assessing local housing need, have seen a mixed response across the country, with a number of councils ‘dismayed’ with the proposed increases in their housing numbers (see our previous commentary). However, for a number of councils, including Fareham, the proposed changes theoretically see a suggested reduction in housing need that has meant that contrary to the trend of plan production being delayed, plan-making has sped up.
Fareham Local Plan 2037
The Fareham Local Plan 2037 has today been published, with consultation under Regulation 19 taking place from 7 November to 18 December 2020, more than three years after the council issued their initial Regulation 18 Draft Local Plan (in October 2017), and two subsequent consultations before reaching this stage. For context, the current Core Strategy was adopted in 2011, and consequently precedes the NPPF and planned for a much lower housing requirement for the period up to 2026.
The council put the delay in preparing a replacement plan down to changing national policy, which has altered the annual number of homes the plan needs to accommodate. The housing requirement rose from 420 dpa to 520 dpa when the standard method was first published in 2018, which required the council to look for additional sites. However, when the Government proposed a potential lower housing requirement of 403 dpa in the revised standard method this summer, the council wasted no time in issuing a draft Plan for Regulation 19 consultation within a matter of weeks of the closure of the national consultation.
Continued reliance on a single new settlement
Not surprisingly, the new Local Plan is conservative in its ambitions for growth in the borough. It does little to allocate new sites and instead relies heavily on sites that are already within the planning system. Of the nearly 8,400 homes that the plan provides for, around two-thirds (5,400) already have permission or a resolution to grant, with nearly half the total supply during the plan period (4,020 dwellings) due to be delivered at a new settlement at Welborne.
This means that the Plan itself only actually allocates sites for approximately 1,750 homes for development over the period to 2037, which is around 20% of the total requirement, despite many years of under delivery in the borough.
The council is heavily reliant on development coming forward at its flagship Garden Village at Welborne, which was of course allocated in the 2011 Core Strategy, and has only just achieved a resolution to grant an outline planning permission.
Its projected housing supply for the next five years includes 450 homes being delivered at Welborne. However, this development has recently run into problems as the funding made available for improvements required to the M27 is due to expire in March 2021. Council leaders have written to the PM pleading for additional funding to expand the nearby junction 10 of the M27, estimated to cost more than £75 million. The development cannot take place substantially before this major upgrade to the strategic road network is completed.
Nutrient neutrality
Like most of the rest of Hampshire, Fareham has been unable to grant permissions for new housing for the last 18 months due to impacts on protected sites within the Solent. The issue of ‘nutrient neutrality’ in the Solent has had a significant impact on the delivery of new homes in Fareham and FBC are unable to demonstrate a five year housing land supply, and have failed to do so for a number of years. The council are working with Hampshire and Isle of Wight Wildlife Trust (HIOWWT) to bring forward mitigation land at Little Duxmore Farm on the Isle of Wight. Securing this land will enable the council to grant planning permission for a number of residential schemes, which have been stalled for a considerable period of time.
The trouble with plan-making
The planning White Paper was adamant that the planning system remains, at its heart, plan led. But unlike Fareham, a number of council’s are stalling, with their plans being held back whilst certainty is awaited.
A number of plans in areas of high housing need are also failing the ‘duty to co-operate’ test (including Chiltern and South Bucks, Sevenoaks, Tonbridge and Malling). FBC are likely to be seeking backing from Partnership for South Hampshire to demonstrate compliance, and have already committed to accommodate around 850 dwellings to meet Portsmouth’s unmet housing need. Going forward, there could be additional pressure from other constrained authorities along the south coast who are facing a higher housing requirement.
Taking all this into account, it is likely that the council’s lack of a five year housing land supply will persist in the short term. This provides an ideal opportunity for those with small and medium sized sites to submit residential planning applications, taking advantage of the tilted balance in national policy.
We will wait with bated breath to see if Fareham manage to adopt their Local Plan in autumn/winter 2021. Or if further delays will be inevitable when the housing number that underpins it is yet to be confirmed by Government. Watch this space.
For more information, or to discuss opportunities arising from this for small and medium sized residential sites, please contact Aaron Wright or Alison Young.
6 November 2020