📘 Disclaimer: This document is a conceptual proposal prepared for consideration by East Hampshire District Council (EHDC). It does not represent current policy but outlines an optional framework that EHDC could choose to adopt, pilot, or develop further. It has been designed to be implementable in its current form or used as a foundation for future formal guidance or policy inclusion.
| Fair Scoring System for Housing Applications in a Land Supply Crisis |
When a local council can’t show that enough land is available to meet housing targets — known as a Housing Land Supply Shortfall — national planning rules require a more flexible approach. This is called the tilted balance (as set out in Paragraph 11(d) of the National Planning Policy Framework1, or NPPF).
The purpose of the tilted balance is to ensure that councils continue to approve housing where it’s needed, even if their Local Plan2 is out of date — typically due to not being reviewed within five years, not aligning with national planning policy, or because the council cannot demonstrate a 5-year housing land supply3 — a target the council’s leadership must be willing to own and deliver on by taking responsibility as the accountable leadership team — so that housing delivery doesn’t stall.
It means that planning permission should usually be granted unless the negative impacts of a proposal clearly and significantly outweigh the benefits.
But that doesn’t mean any development should be approved, anywhere, at any scale. Without proper and fair policies in place, it becomes the wild west.
Don’t worry — the sheriff is in town: Points-Based Evaluation Framework for Tilted Balance Applications.
🧩 What is the Framework, and what are its Components?
The scoring framework is similar to the points-based immigration systems used in Canada or Australia — where multiple factors such as contribution, readiness, risk, and fairness are weighed to determine whether an application should succeed.
The Points-Based Evaluation Framework is the overall system or logic used to evaluate tilted balance applications. It ensures that each planning proposal is judged fairly, consistently, and transparently, especially when the Local Plan is out of date. It does so through structured criteria, clear scoring, and rules about proportionality and fairness.
🧰 Analogy
Think of the framework as the full toolbox.
- The scoring matrix is the main tool.
- The EIA thresholds and quotas are special attachments that make the tool adapt to the job. They are not side ideas — they are essential functional components of the framework.
Within this framework, there are two critical policy instruments that shape how the scoring matrix operates:
🔸1. Proportionate EIA Threshold Guidance – by Settlement Type
This is a supporting rule that helps determine whether a proposed development is “major” for a given settlement type (village, town, etc.) — and whether an Environmental Impact Assessment (EIA) or cumulative audit should be required.
✅ How it fits into the framework:
- It helps trigger the Adverse Impact Multiplier in the scoring matrix.
- It reflects scale sensitivity, so smaller villages aren’t hit by disproportionate risk.
- It ensures fairness in how ecological and infrastructure capacity is judged.
| Settlement Type | Population Range | Suggested EIA Trigger | Rationale |
|---|---|---|---|
| Small Village | < 1,000 | 30+ dwellings OR >10% population growth | High relative impact on infrastructure and character. |
| Large Village | 1,000–4,999 | 50+ dwellings OR >7% population growth | Moderate impact; infrastructure may be strained. |
| Town | 5,000–10,000 | 75+ dwellings OR >5% population growth | Risk of local congestion or infrastructure lag. |
| Large Town / Urban | 10,000+ | 100+ dwellings OR >3% population growth | Only large proposals expected to trigger EIA. |
This tiered structure helps ensure that growth is scrutinised proportionally, aligning with both national policy intent and local planning equity.
📘 Note on Growth Period Calculation: Growth percentages used to trigger Environmental Impact Assessments (EIAs) or influence scoring (e.g. under Cumulative Development Pressure) should be calculated using a rolling 10-year baseline. This aligns with Local Plan methodologies and national planning practice. EHDC may measure growth by comparing the population or dwelling figures from 10 years ago (e.g. using Census or mid-year estimates) to current or proposed development levels. This ensures growth assessments remain consistent, current, and proportionate across different settlement sizes.
🔸2. ⚖️ Fairness, Quotas
This introduces a quota-based logic for sharing the burden of new housing development fairly across the district — based on each settlement’s population.
✅ How it fits into the framework:
- It informs the “Exceeded Local Tilted Balance Quota” category in the matrix.
- It prevents overloading some areas while others under-deliver.
- It ensures solidarity, proportionality, and public trust.
A key feature of this system is the implementation of quota-based modules, similar to fishing quotas, ensuring each settlement receives a fair share of tilted balance development annually. This approach prevents any single area from being disproportionately burdened by new, potentially riskier developments — especially during periods when delivery obligations are not being met elsewhere due to the use of the tilted balance route. It protects communities while the tilted balance workaround remains in use.
This approach reinforces solidarity and proportional political accountability — since population is linked to the number of councillors representing each area. If tilted balance developments concentrate in areas with fewer councillors, it undermines democratic fairness. This system ensures the burden of addressing housing shortfalls is shared fairly across EHDC by embedding the quota module into the tilted balance evaluation process.
📝Calculating Local Quotas
| Example 1: Medstead | Example 2: Alton |
| Population: 3,016 District population: 125,700 Shortfall-based cap: 2,036 dwellings Calculation: (3,016 ÷ 125,700) × 2,036 ≈ 49 homes per year | Population: 17,800 District population: 125,700 Shortfall-based cap: 2,036 dwellings Calculation: (17,800 ÷ 125,700) × 2,036 ≈ 288 homes per year. |
As of April 2024, East Hampshire District Council (EHDC) has reported a shortfall of 2,036 dwellings, representing only a 2.7-year housing land supply. In the absence of updated deliverability data, this full shortfall may be used as a provisional guide for calculating the annual tilted balance quota. This figure should be reviewed annually in line with updated housing monitoring reports.
Population figures used here are based on the 2021 Census, which recorded approximately 125,700 residents in East Hampshire District. These figures are factual and not modelled, and are therefore updated only once every ten years.
📊 Fair Distribution Method
To ensure a proportionate and community-led approach, each settlement’s share of the tilted balance quota can be calculated using the following formula:
Settlement share of the quota = (Settlement population ÷ District population) × District tilted balance allocation
This method ensures fairness based on the relative size of each settlement and promotes a more balanced distribution of housing delivery across the district.
Where detailed settlement-level data is unavailable or unclear, parish boundaries may be used as a practical proxy for administrative purposes.
🧮 Example Allocations
- A village with 1,300 residents (approximately 1% of the district population) would be assigned a tilted balance quota of 5 homes per year.
- A larger town with 10,000 residents (around 8% of the district population) would have an annual quota of approximately 38 homes.
📊 Sample Quota Table (based on a 500-unit district-wide annual tilted balance cap)
| Settlement | Population | % of District | Annual Quota |
| Medstead | 3,016 | ~2.32% | 12 homes |
| Four Marks | 4,000 | ~3.08% | 15 homes |
| Alton | 17,800 | ~13.7% | 69 homes |
| Liphook | 8,600 | ~6.62% | 33 homes |
| Whitehill & Bordon | 14,000 | ~10.77% | 54 homes |
| Village A (1,000) | 1,000 | ~0.77% | 4 homes |
🧮 Scoring Matrix
The BETA version of a scoring matrix below provides a table that assigns numerical values (scores) to key planning criteria used to evaluate housing applications submitted under the tilted balance.
Each scoring range corresponds to specific planning factors and helps ensure that decisions are consistent, transparent, and defensible. This method supports officers, councillors, and developers in understanding how benefits and harms are balanced under the tilted balance policy.
| Category | Scoring Range | Example Criteria |
|---|---|---|
| Undeveloped Allocated Land | –17 or 0 | –17 if the developer controls allocated land elsewhere in the district that remains undeveloped without valid reason (e.g. access, ownership, contamination). If there is a valid reason, it must be logged by EHDC at this point with a remediation deadline. No progress by the next Local Plan review may trigger deallocation. Score 0 if no such land is held or valid constraints are documented. |
| Exceeded Local Tilted Balance Quota | –17 or 0 | –17 if a settlement has already reached its annual tilted balance quota (based on population and EHDC’s district-wide shortfall, e.g. 2,036 units in 2024), or if a single planning application proposes more dwellings than the total annual quota for that settlement. EHDC may request resubmission in phases or apply conditions to align delivery with the annual quota. Score 0 if the quota has not yet been reached elsewhere. |
| Affordable Housing Contribution | –2 to +5 | +5 for exceeding policy requirements by 30% or more. |
| Delivery Speed and Certainty | –1 to +4 | +4 if full build-out achievable within 3 years with no major constraints. |
| Infrastructure Pressure | –3 to +2 | –3 if severe GP/school congestion identified and unmitigated. |
| Biodiversity Net Gain / Land Use | –2 to +3 | +3 for 20%+ biodiversity gain or brownfield remediation. |
| Developer Track Record | –2 to +2 | +2 for consistently timely delivery on previous local schemes. |
| Local Community Objection Level | –3 to 0 | –3 if majority of consultees raise unresolved material concerns (e.g. transport, infrastructure, overdevelopment) not addressed by updated evidence or mitigation. |
| Adverse Impact Multiplier | Multiplies total negative score by 1.5 only if: (1) the cumulative threshold for triggering an EIA was already met prior to this application, (2) no EIA or equivalent cumulative evidence was produced during previous developments, and (3) statutory consultees now face a data gap that prevents proper assessment. | |
| Land Supply Contribution (5YHLS) | –2 to +4 | +4 if the proposal contributes positively to the district’s 5-year supply (up to the quota limits for the tilted balance application). Score 0 if neutral. Score –2 if the development is proposed in a parish or ward that has already met or exceeded its Local Plan delivery targets (regardless of whether the plan is outdated), in order to protect communities that have already delivered their expected share. |
Total possible score range: –34 to +25
✅ Total possible score range varies depending on multiplier status. Scores are designed to guide — not automate — decisions. However, any significant departure from the scoring framework must be supported by clear, proportionate reasoning. Failure to do so may expose the decision to legal challenge. This is precisely what makes the system strong: it provides EHDC with a structured, transparent and legally defensible tool for decision-making, while preserving councillor discretion — provided that discretion is accountable and properly justified.
Category Summaries:
- Undeveloped Allocated Land: Considers whether the applicant is already holding undeveloped land within the district and whether valid constraints exist.
- Exceeded Local Tilted Balance Quota: Evaluates whether the proposed number of homes exceeds the local quota for tilted balance development.
- Affordable Housing Contribution: Rewards developments that exceed minimum affordable housing requirements.
- Delivery Speed and Certainty: Favors developments with a high probability of delivery within 3 years.
- Infrastructure Pressure: Penalizes developments likely to stress healthcare, schools, or transport infrastructure without mitigation.
- Biodiversity Net Gain / Land Use: Recognizes strong environmental gains or brownfield redevelopment.
- Developer Track Record: Considers the applicant’s reliability in delivering on previous local developments.
- Local Community Objection Level: Penalizes where material concerns remain unresolved by residents or community groups.
- Statutory Consultee Objection Level: Reflects unresolved concerns raised by statutory consultees such as the Environment Agency or Natural England.
- Land Supply Contribution (5YHLS): Rewards schemes that contribute positively to the district’s housing supply — but protects communities that have already delivered.
- Adverse Impact Multiplier: Applies a 1.5x penalty if cumulative impact thresholds were previously exceeded but no cumulative EIA or mitigation evidence was gathered.
| Component | Points-Based Evaluation Framework for Tilted Balance Applications |
| What It Delivers | A legally robust, transparent tool for evaluating tilted balance applications. Uses a scoring matrix, quota logic, and proportionate EIA thresholds to ensure consistency, fairness, and public accountability. |
| Function | Scores key planning criteria (e.g. land banking, delivery speed, infrastructure pressure, public objections). Applies quotas to prevent overburdening settlements and triggers multipliers where EIA safeguards were bypassed. |
| Legal Basis | Paragraph 11(d) of the National Planning Policy Framework (NPPF); Administrative discretion under planning law; Principles of fairness and proportionality; aligns with best practice case law. |
| Completion Criteria | Framework piloted in major out-of-plan applications submitted under the tilted balance. Matrix scores published with officer reports. Quota tables and EIA thresholds embedded in the assessment process. |
| How to Implement | Internally draft matrix, quota tables, and EIA thresholds. Pilot using current shortfall data. Publish template with explanatory guidance for officers and developers. |
| Timeline | Draft within 2–3 months. Run 6-month pilot phase. Evaluate and integrate into planning guidance. |
| Owner | Planning Policy / Development Management Officers / Legal Services. Coordination with Monitoring & Housing Delivery teams. |
Footnotes
The National Planning Policy Framework — or NPPF — is the government’s main set of planning rules and principles. It guides how decisions should be made on housing, transport, design, environment, and sustainability across England. Local planning policies are expected to follow it.↩︎A Local Plan is a council’s strategic planning document — it sets out where development should take place, what should be protected, and how local growth will be managed over the next 15–20 years. It must be reviewed at least every five years to remain valid.↩︎What does it mean if a council "cannot demonstrate a 5-year housing land supply"? A council is required to show that it has enough deliverable housing sites to meet at least five years' worth of housing need, based on government-assessed targets.↩︎