| Phase 1 |
📚 Background and Rationale
This policy proposal is informed by lived experience of the planning process in East Hampshire — specifically, how infrastructure capacity is assessed and communicated in relation to new development.
In reviewing multiple planning applications for major residential development within the same settlement, it became apparent that the infrastructure consultee feedback — particularly from NHS bodies regarding GP services — was identical or nearly identical across different applications, even when submitted around the same time. These responses lacked numerical data and made no reference to cumulative population growth or actual capacity conditions in the affected area.
This raises a serious procedural concern: it suggests that there is no requirement within EHDC’s planning process for infrastructure consultees to provide quantified, accountable, or cumulative-aware responses.
The result allows one to imply that if one consultee is permitted to respond without numerical or contextual accountability, a wider cluster of process defects likely exists across all types of infrastructure consultees.
- No requirement for numerical capacity data (e.g. patient list sizes, safe service thresholds, population yield from developments)
- No assigned ownership of the accuracy or adequacy of the infrastructure assessment
- No accountability if consultee responses are vague, generic, or reused across unrelated applications
- No public explanation of whether developer contributions (e.g. to NHS infrastructure) will result in any measurable local benefit
As a result, mitigation measures — where proposed — are not accompanied by any assurance of what they will deliver. For instance, there is rarely any information provided about:
- Whether the funding will benefit the local settlement where development is proposed
- What form the mitigation will take (e.g. physical expansion, staff capacity, mobile clinics, digital triage, etc.)
- What increase in service capacity the funding is designed to support
- How the delivery of this infrastructure aligns with the timing of housing occupation
This creates a situation where development can be approved on the assumption that impacts are mitigated, but there is no mechanism to verify that capacity will actually increase, or that service improvements will be delivered in the right place, at the right time, and in proportion to the demand being created.
Additionally, in the consultee responses reviewed, there was no indication that the NHS body was aware that the applications in question were located outside the Local Plan’s planned development boundaries. This is a crucial distinction, as out-of-plan proposals are typically not accompanied by pre-assessed infrastructure support, and their approval can significantly accelerate unplanned demand in areas where capacity has not been strategically accounted for.
Equally concerning is the complete absence of any reference to the actual size or growth of the settlement affected by the proposal. In the cases reviewed, no consultee response referred to the population size of the settlement, the number of households already approved since the last Census, or the cumulative increase in population that had already occurred or was underway.
Furthermore, there is no indication that infrastructure consultees are required to provide any evidence of whether capacity improvements have been made in proportion to past population growth. For example, if a settlement experienced significant growth between the 2011 and 2021 Censuses, a credible infrastructure response should include a reference to whether GP capacity, school places, or drainage systems have been expanded to meet that increased demand. Without such a requirement, consultees can issue standardised “no objection” responses without acknowledging existing strain — and without offering any evidence that investment has kept pace with population growth. This undermines the credibility of the planning process and makes it impossible for EHDC or the public to assess whether essential services are expanding in line with housing delivery.
This suggests one of two things:
- Either consultees are not being provided with this information by EHDC at the point of consultation, or
- They are not required to demonstrate that their assessment takes these contextual figures into account
In either case, it represents a serious flaw in the process. Without this local context — including whether a site is plan-compliant, and what cumulative growth has already occurred — infrastructure consultees cannot meaningfully assess capacity or risk, and their feedback becomes functionally detached from the real-world conditions on the ground.
This absence of procedural safeguards — input requirements, output expectations, and defined responsibility — allows infrastructure constraints to be systematically overlooked or papered over. It undermines public confidence, prevents transparent planning, and disconnects development from the real-world services needed to support it.
This policy seeks to close that gap by introducing mandatory numerical assessment requirements, tied to cumulative local growth, and backed by clear expectations for what mitigation must deliver, where, and when.
To further address this, EHDC should design its consultee process so that when multiple applications are active in the same settlement, each consultee is informed of any pending or validated applications already on record, and must account for these in their response. A first-come, first-assessed principle should apply — meaning that applications submitted earlier are assumed to be approved, and later consultee responses must assess the impact as if those schemes are already part of the local infrastructure load.
This requirement will apply equally to all statutory and non-statutory infrastructure consultees. It is essential that each response reflects a realistic and evolving picture of service pressure, based not only on a single proposal, but on the collective development pipeline within that locality.
🔧 Policy Mechanism
As part of the planning application process, any major residential development (10 or more dwellings), or any development in a settlement identified as exceeding its fair share of housing growth, must be supported by a numerical infrastructure capacity assessment. This requirement applies to all relevant statutory and non-statutory infrastructure consultees and must include:
- Primary healthcare (GP surgeries)
- Education (local primary and secondary schools)
- Surface water drainage and foul sewage capacity
Each assessment must reflect the cumulative impact of all approved and pending applications in the settlement and must assume that earlier-submitted applications will be approved, in line with the “first-come, first-assessed” principle.
📊 Required Content of Infrastructure Responses
🏥 GP Services:
- Current patient list size of local GP practice(s)
- Ideal or safe capacity threshold (e.g. based on NHS England guidance)
- Estimated population yield from the proposed development
- Cumulative population added by recent and pending developments in the practice’s catchment area
- Statement on whether capacity will be exceeded, and if so:
- What mitigation is proposed
- What the funding will deliver (e.g. rooms, staff, digital access)
- Whether it directly serves the affected settlement
- Expected delivery timescale
🎒 Education:
- Current and forecast school capacity (primary and secondary)
- Pupil numbers currently on roll
- Estimated pupil yield from the proposed development
- Summary of pressure from other nearby or concurrent applications
- Statement on required mitigation and what it will deliver (e.g. expansions, mobile units)
💧 Drainage and Foul Water:
- Confirmation from the LLFA and sewerage undertaker on system capacity
- Details of any known flooding or overload history
- Assessment of whether the proposal, combined with other proposals, will trigger a requirement for upgrades or risk exceedance of existing systems
🛠️ Data Providers
| Infrastructure Type | Data Provided By |
|---|---|
| GP Services | NHS Hampshire & Isle of Wight Integrated Care Board (ICB); Local practices as fallback |
| Education | Hampshire County Council – School Planning Team |
| Drainage | Lead Local Flood Authority (EHDC or County); Southern Water (or relevant utility) |
✅ Implementation
- These requirements will be incorporated into EHDC’s Local Validation Checklist
- Applications lacking this data will be deemed invalid until complete
- EHDC will maintain and publish a Settlement Infrastructure Tracker, updated annually, showing housing approvals, pending applications, and known service pressures
- Infrastructure responses will be made public as part of each planning file and referenced in officer reports and decision notices
- All consultees will be issued with cumulative development summaries and must adjust their assessments accordingly
📝 Response Format and Accountability Requirements
To ensure consistency, accountability, and data integrity, all infrastructure consultee responses must be submitted using a standardised response form issued by EHDC, which includes:
📋 Required Format:
- Pre-filled Contextual Data from EHDC, including:
- Location of the development
- Whether the site is within or outside the Local Plan
- Number of dwellings proposed
- Estimated population yield (based on EHDC’s standard household size)
- Number of dwellings approved and pending in the settlement since the 2021 Census
- Cumulative growth figure (% increase in population or households)
- Mandatory Numerical Fields for Completion by the Consultee, including:
- Current service capacity (e.g. patients per GP, school places, system flow capacity)
- Actual usage or list size / roll figures
- Thresholds for service strain or breach
- Projected impact of the development (standalone and cumulative)
- Description of any service upgrades or mitigation already delivered since 2011 or 2021
- Mitigation Details (if applicable):
- Description of any proposed mitigation
- Estimated delivery timescale
- Whether mitigation directly serves the affected settlement
- Whether additional development can be supported before mitigation is in place
- Consultee Identity and Accountability:
- Named individual completing the form (or identifiable team reference)
- Contact email or phone number for clarification
- Organisation name and official capacity
- Signature or digital reference ID of consultee response (for tracking and audit purposes)
- Final Summary Position (tick-box with written explanation required):
- ☑️ Unconditional support — infrastructure has capacity to support this development
- ☑️ Conditional support — mitigation required before or alongside development
- ☑️ Objection — infrastructure cannot support this development, and mitigation is not feasible or deliverable within a reasonable timeframe
This structured approach will:
- Prevent vague or recycled feedback
- Ensure cumulative growth and real-world capacity are acknowledged
- Clarify who is responsible for each response
- Make all responses easier to assess, track, and reference during public consultation or legal challenge
| Component | Numerical Infrastructure Capacity Requirement (N-ICR) |
|---|---|
| What It Delivers | Quantifiable, accountable assessments of infrastructure pressure and capacity based on cumulative development |
| Function | Ensures planning decisions are based on up-to-date, evidence-based service capacity data, supporting sustainable growth |
| Legal Basis | Planning and Compulsory Purchase Act 2004; National Planning Policy Framework (NPPF); EIA Regulations 2017 |
| Completion Criteria | All required data fields submitted; mitigation identified where needed; signed, accountable response with clear summary position |
| How to Implement | Include in Local Validation Checklist; issue standard forms; require use by all statutory and non-statutory consultees |
| Timeline | Form development: 3 months; Policy inclusion: 6 months; Full rollout: within 1 year of adoption |
| Owner | East Hampshire District Council Planning Policy and Development Management Teams |