🧭 What Is a Planning Position Statement (PPS)?

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A Planning Position Statement (PPS) is a non-statutory document issued by a Local Planning Authority (LPA) to clarify how it interprets planning policy or evidence in the short term — particularly during periods of policy uncertainty or when a Local Plan is under review.

A PPS is not part of the statutory development plan, but it is a material consideration under planning law. That means it can influence decisions on planning applications and appeals.

It is legally supported by:

• Section 70(2) of the Town and Country Planning Act 1990
• Section 38(6) of the Planning and Compulsory Purchase Act 2004
• Paragraph 48 of the National Planning Policy Framework (NPPF), which recognises the relevance of emerging and interim policies

A PPS is especially important when:

• A five-year housing land supply cannot be demonstrated
• The “tilted balance” in NPPF Paragraph 11(d) is triggered
• The harms of development are not being properly accounted for in planning decisions

⚖️ Paragraph 11(d): What Was It Really Meant to Do?

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Paragraph 11(d) of the NPPF introduces a presumption in favour of sustainable development when local policies are out of date or a five-year housing land supply is missing.

But crucially, it includes a safety valve:

Planning permission should be granted unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework as a whole.

This clause was designed to ensure that planning decisions still reflect the public interest, not just housing targets. It was never meant to reward unplanned sprawl, unchecked landbanking, or speculative development that exploits technical shortfalls in supply.

Yet that is exactly what is happening.

🏗️ The Inverse Impact of Speculative Development

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Note: The term “inverse harm” is used here to describe how speculative development and landbanking not only cause adverse impacts, but actually reverse the intended outcomes of national planning policy — particularly the sustainable development aims of the NPPF. In policy terms, these are adverse impacts under NPPF Paragraph 11(d)(ii), and must be treated as such in decision-making.

When the tilted balance is triggered without safeguards, it:

• Encourages speculative applications with little regard for cumulative harm
• Enables landbanking, where permissions are secured but not delivered, inflating perceived supply gaps
• Overburdens infrastructure with no mechanism for timely mitigation
• Erodes public trust in planning

These effects are not neutral. They are demonstrable harms.

If the NPPF requires decision-makers to weigh adverse impacts, then speculative behaviour and its systemic consequences must be part of that assessment.

These effects:

• Undermine the delivery of actually sustainable development
• Distort land value and delivery patterns
• Prevent democratic, plan-led growth
• Delay meaningful infrastructure upgrades

This is precisely the kind of situation Paragraph 11(d)(ii) was built to prevent.

📌 Why a PPS Is the Fastest, Legally Defensible Response

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A Planning Position Statement can:

• Define speculative development and landbanking as adverse impacts with measurable consequences
• Provide interim criteria or saturation thresholds for assessing cumulative harm
• Clarify how EHDC interprets the “significantly and demonstrably outweigh” test under current evidence

Because it is evidence-based and locally relevant, it qualifies as a material consideration in decision-making. It empowers the council and the Planning Committee to reject harmful schemes — even under tilted balance.

And crucially: it can be published quickly, without requiring examination or full Local Plan adoption.

🚨 It Is Against the Public Interest Not to Act

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To allow speculative development to go unchecked — when its harmful consequences are known and preventable — is to subvert the very purpose of national policy.

• Paragraph 11(d) was never designed to bypass planning.
• It exists to balance the need for housing with the right to protect communities, landscapes, and services from unplanned strain.

Not using available tools like a PPS — when harm is demonstrable and growing — is not neutrality. It is a failure to act in the public interest.

🧭 Who Has Been Formally Asked to Act — and Why

We have submitted a formal request for a Planning Position Statement (PPS) to the following elected representatives, all members of the Conservative Party, who hold key responsibilities within East Hampshire District Council (EHDC) and at national level:

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The request has also been formally shared with all three ward councillors for Four Marks & Medstead — Cllr Roland Richardson (also a Planning Committee member), Cllr Ilena Allsopp, and Cllr Neal Day.

As our elected representatives, they are expected to respond to the concerns of their constituents and take a public position on the call for a Planning Position Statement. Their support could help push EHDC to act decisively .

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📣 The Ask

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EHDC must urgently issue a targeted Planning Position Statement recognising:

• That speculative development and landbanking constitute adverse impacts
• That the cumulative effects in places like South Medstead significantly and demonstrably outweigh the benefits
• That clear thresholds or local impact triggers are necessary for fair decision-making under tilted balance

Doing nothing is not passive. It is permission by silence.

This is the lawful, rapid, proportionate intervention our district needs — and it is long overdue.