📑 What Is an Annual Monitoring Report (AMR) — and How Windfall Approvals Can Mask Planning Gaps

The Annual Monitoring Report (AMR) is a document that each local planning authority — including East Hampshire District Council (EHDC) — must publish at least once per year. Its purpose is to track the council’s performance in delivering planning objectives and housing targets.

Think of it as EHDC’s “planning report card”, offering transparency about whether it is meeting the commitments set out in its Local Plan.

The Annual Monitoring Report (AMR) is a yearly publication required by all local councils. It tracks housing delivery, Local Plan progress, and whether the council is meeting national planning targets. One of its most influential roles is confirming whether the council has a five-year housing land supply — a key measure used to determine how much control it retains over planning decisions.

In this article, we explain how the AMR works — and how windfall housing approvals (homes approved outside planned allocations) are sometimes used to improve headline figures. While this can help councils meet short-term targets, it can also mask deeper planning problems, such as overdevelopment in rural communities, underinvestment in infrastructure, or failure to deliver allocated sites.

🧾 What Does the AMR Include?

The AMR typically reports on:

  • 📦 Progress on the Local Plan: Has the council delivered what it promised?
  • 🏡 Housing completions: How many homes have been built each year?
  • 📉 5-Year Housing Land Supply (5YHLS): Does the council have enough land to meet demand over the next five years?
  • 🧮 Housing Delivery Test (HDT) performance

The Housing Delivery Test (HDT) is a national measure of how many homes a council has actually delivered, compared to how many it was expected to deliver over the past three years. If delivery falls below key thresholds (e.g. 85%, 75%), it can trigger penalties such as action plans or tilted balance.

  • 🏘️ Affordable housing delivery
  • 🧭 Windfall trends and development outside planned allocations
  • 🌿 Environmental and infrastructure indicators
  • 📆 Whether the Local Plan still meets national policy requirements or needs updating

🗓️ When Does EHDC Publish the AMR?

  • EHDC typically publishes its AMR between May and July each year, covering the previous financial year (e.g. 1 April 2023 to 31 March 2024).
  • The most recent version as of early 2025 is the 2022/23 AMR, released in summer 2023.

📌 What Is the Legal Duty?

Under Regulation 34 of the Town and Country Planning (Local Planning) (England) Regulations 2012, councils must:

  • Publish a monitoring report at least annually,
  • Make it publicly available, and
  • Keep it relevant to Local Plan performance.

⚠️ Why It Matters

  • The AMR helps determine whether EHDC has maintained a 5YHLS and met its housing targets.
  • If shortfalls are revealed, the tilted balance is triggered, weakening local control over speculative development.
  • The Housing Delivery Test (HDT) uses AMR figures to assess whether local planning authorities are delivering enough homes. Failing the HDT can:
    • Trigger an action plan,
    • Require an early Local Plan review, or
    • Engage the presumption in favour of development (tilted balance).

🚨 Pressure to “Patch the Numbers” Before the AMR Cut-off

Because AMRs rely on data captured as of 31 March each year, there is a risk that councils under pressure to meet housing targets might approve borderline or windfall applications in Q1 (Jan–Mar) to artificially boost completions before publication.

This creates a risk that:

  • Windfall approvals are rushed or strategic rather than properly assessed.
  • Councils may cut corners on cumulative impact, environmental risk, or consultation.
  • Settlements like Medstead — which already absorbed disproportionate growth — may be further burdened to “make up the numbers.”

🧾 Windfall allowances hide structural failure

NPPF Paragraph 71 allows councils to count windfall sites in their housing supply — but without any spatial limit.

👉 Result:

  • Councils can use windfalls to fill the numbers,
  • Even if growth is unplanned, disconnected from infrastructure, and overloads specific settlements (like Medstead).

This makes it look like delivery is working, while masking the failure to deliver plan-led, equitable growth

🚨 When the AMR Becomes a Trigger to Cut Corners

Although the AMR is designed to promote transparency, it can also create perverse incentives when councils are under pressure to meet housing delivery targets. Because each AMR captures housing data up to 31 March, local authorities may feel compelled to approve marginal or windfall developments in the final months of the year — even in unsustainable locations — simply to boost their numbers before publication.

In reality, this pressure can begin well before the AMR deadline. If internal tracking or draft housing completions reports indicate that delivery may fall short, councils like EHDC may accelerate approvals in Q3 or earlier, particularly for windfall or tilted balance schemes that can be counted toward annual totals.

This is especially risky when:

  • The council anticipates failing the Housing Delivery Test (HDT),
  • The Five-Year Housing Land Supply (5YHLS) position is already weak,
  • Or the tilted balance has been triggered and used to justify approvals.

🎙️ In the LPC meeting on 20 March 2025, EHDC’s Development Manager confirmed that the 2016 Ashwoods (Medstead) development was approved during a period when the council lacked a five-year housing land supply and was relying on an Interim Housing Position Statement. It was a windfall development, not part of a planned allocation.

📉 Every year, EHDC must report on housing delivery. When it appears that targets may fall short, windfall approvals can play a role in closing the gap. While this helps meet district-wide numbers, it also risks obscuring underlying planning weaknesses — with communities like Medstead absorbing the real-world impacts of unplanned growth.

In such moments, settlements like Medstead — which have already absorbed high levels of growth — may be exposed to rushed or speculative approvals without cumulative safeguards, long-term infrastructure planning, or meaningful local scrutiny. The AMR, intended as a tool for accountability, can unintentionally incentivise short-termism and overdevelopment, particularly in rural communities that lack formal delivery caps.