Objection – 20240623 – 01 — Core.pdf



Material Considerations Used in the Objection, Grouped by Main Categories


Cumulative Environmental Impact: Highlighting the absence of comprehensive Environmental Impact Assessments (EIA) for cumulative impacts due to significant population growth and development in Medstead.

Impact on Local Infrastructure and Services: Continuous development without comprehensive EIAs, impacting local infrastructure and community quality of life.

Context-Specific Thresholds: Suggesting lower EIA thresholds for rural villages like Medstead.

Absence of Full Environmental Impact Assessments (EIA): Despite significant development, there has been no comprehensive EIA to assess the cumulative impacts, failing to address the overall significance of multiple developments.

Accuracy and Transparency of Housing Supply Data:

  • Discrepancies in Housing Supply Estimates: Issues with the Council’s calculation of deliverable housing supply, as pointed out by the Pegasus Group’s Housing Land Supply Assessment.
  • Council’s Position on Deliverable Supply: Inaccuracies and insistence on using incorrect figures, questioning data accuracy and procedural integrity.
  • Misleading Housing Supply Figures: Lack of transparency in providing accurate figures regarding population increases.

Need for Independent Audit: Given the significant procedural deficiencies identified, there is a need for an independent audit of the EHDC’s planning application procedures. This audit should assess data accuracy, transparency, procedural integrity, and the impartiality of assessments provided by developers.

Procedural Errors and Paragraph 11 of the NPPF: The procedural errors and inaccuracies undermine the ability to properly execute Paragraph 11, which aims to support sustainability. The adversity of impact must be assessed against the NPPF as a whole, which is currently impossible due to the described issues.

Draft Local Development Plan Classification Error: Misclassification of the plot of land affecting planning considerations.

Re-purposed NHS Comment: Concerns about the relevance and accuracy of the repurposed NHS comment.

Lack of Supervision: Issues with impartiality and oversight in developer assessments.

Functional Integrity of the Planning Application System: Errors and systemic issues undermining the planning process’s robustness.

Conflict Among Councillors: Conflicts caused by housing targets affecting balanced decision-making.

Community Involvement: Engaging the local community and addressing their concerns is crucial for the success and acceptance of the development.

Safety and Accessibility: Assess the safety measures in place for future residents, particularly regarding flood risk and emergency access routes.

Impact on Quality of Life: Evaluating how the development will affect the living conditions of nearby residents and the general ambiance of the area.

Drainage Systems: Assess the adequacy of the proposed surface water and foul drainage systems. Ensure they can handle peak flows and have appropriate maintenance plans.

Water Quality: Evaluate measures for protecting water quality, particularly regarding surface runoff and foul water discharge.

Safety and Accessibility: Assess the safety measures in place for future residents, particularly regarding flood risk and emergency access routes.


Impact on Quality of Life: Evaluating how the development will affect the living conditions of nearby residents and the general ambiance of the area.

Sustainable Development: Ensuring that the proposed development meets sustainability goals, including long-term ecological balance, resource efficiency, and quality of life.


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Objection to Planning Application 55318/001 – 20240618-01



Objection Summary


  1. Insufficient Detail in Outline Applications
  2. Cumulative Impact of Piecemeal Developments
  3. Precedent and Consistency
  4. Location and Policy Considerations
  5. Need for Up-to-Date Information

Material Planning Considerations


Paragraph 11 of the NPPF:

The developers are using Paragraph 11 to justify their application, which sets the presumption in favour of sustainable development. The objection argues that this should require a full planning application rather than an outline application due to the need for comprehensive details to ensure compliance with sustainability requirements.

Interim Local Development Plan:

The site is not included in the recently updated Interim Local Development Plan, which questions its suitability for development under current planning policies.

Consistency in Policy Application:

The objection highlights the need for consistent application of planning policies, referencing the precedent set by the appeal decision at Mount Royal, Four Marks. It points out discrepancies in the housing supply calculations and stresses the importance of thorough verification.

Outside Settlement Boundaries:

The proposed development is outside the defined settlement boundaries of the village, which impacts land use decisions and policy compliance.


Requirement for Full Planning Application:

Given the location and policy considerations, the objection argues that a full planning application is necessary to adequately evaluate the sustainability and impacts of the proposal, rather than proceeding with an outline application.

Assessment of Impact on Local Infrastructure:


The objection emphasizes the need for detailed assessments of how the development will affect local infrastructure, including roads, healthcare services, and schools, which are crucial for evaluating the economic impacts and benefits of the development.

Local Infrastructure and Community Services:


The objection points out the lack of detailed information in the outline application to assess the full impact on local infrastructure and community services. Comprehensive assessments are necessary to understand how the proposed development will integrate with existing infrastructure and services.

Sustainable Development Requirements:


Paragraph 11 of the NPPF emphasizes the importance of sustainable development. The objection argues that the outline application does not provide sufficient detail to comply with these sustainability requirements, necessitating a full planning application to ensure all aspects are thoroughly evaluated.

Cumulative Impact of Piecemeal Developments:


The objection highlights the cumulative impact of multiple piecemeal developments on local infrastructure, traffic, environmental sustainability, and community well-being. These cumulative effects need to be thoroughly evaluated to protect residential amenity.

Conclusion


The objection to Planning Application 55318/001 is grounded in multiple material planning considerations, including Local and National Planning Policies, Land Use, Economic Benefits, Infrastructure and Services, Sustainability, and Residential Amenity.

Each of these considerations underscores the necessity for a full planning application to ensure comprehensive assessments and compliance with planning policies.

The objection argues that the current outline application lacks the detail required to evaluate the development’s impacts adequately and calls for a more detailed and thorough planning process.


Disclaimer


HOUSING_LAND_SUPPLY_ASSESSMENT-1335961.pdf

Bargate Homes – Housing Land Supply Assessment


Our Analysis of the Housing Land Supply Assessment Document – Key Points


  • The document was prepared on May 1, 2024.
  • The assessment was conducted by Pegasus Group on behalf of Bargate Homes to review the current five-year housing land supply (5YHLS) position in East Hampshire.

  • The review follows the publication of the revised National Planning Policy Framework (NPPF) in December 2023.
  • It references a recent appeal decision for land at Mount Royal, 46 Lymington Bottom, Four Marks, Alton (Appeal Ref: APP/M1710/W/23/3329928).

  • According to the Council’s statement in October 2023, there is a supply of 2,198 homes, equating to a 4.74-year supply.
  • The appellant (developer) and the Inspector found the supply to be only 3.59 years based on their assessment, with 1,664 homes deemed deliverable.
  • Pegasus Group suggests a further reduced supply of 3.47 years.

  • The Council’s initial figure of 2,198 homes was corrected to 1,994 homes.
  • The Inspector agreed with the appellant’s assessment, discounting homes due to various issues like undetermined planning permissions and overestimated delivery rates.
  • Pegasus Group concurred with the Inspector’s assessment but made further adjustments, including correcting the supply arising from C2 uses and questioning the assumed lapse rate for small sites.

  • The housing land supply should be assessed against the minimum local housing need of 464 homes per annum (hpa), as calculated using the Standard Method.
  • The current five-year requirement is 2,320 dwellings (464 hpa x 5).

  • East Hampshire does not need to apply a 20% buffer as the latest Housing Delivery Test result was 112%, indicating no significant under-delivery.

  • The Council is unable to demonstrate a four-year housing supply, falling short at only 3.59 years.
    Pegasus Group further adjusts this figure to 3.47 years.
  • As a result, the most important policies for determining residential planning applications are out-of-date.
  • Planning permission should be granted unless adverse impacts significantly and demonstrably outweigh the benefits.
  • There is an increased need for additional housing to restore a four-year housing land supply.

The analysis of the Housing Land Supply Assessment Document primarily relates to the following Material Planning Consideration categories


  • Revised NPPF (National Planning Policy Framework): The assessment follows the publication of the revised NPPF, highlighting how national planning policies impact local decisions.

The document references the revised NPPF published in December 2023, indicating the national policy context in which local planning decisions are made. This framework sets out the government’s planning policies for England and how these should be applied, emphasising sustainable development.


  • Paragraph 11 of the NPPF: Paragraph 11 sets out the presumption in favour of sustainable development. This is a key consideration in planning decisions, particularly when local plans are outdated or when housing supply targets are not met. The document uses Paragraph 11 to argue for the approval of new housing developments unless adverse impacts significantly outweigh the benefits.

  • Housing Land Supply Requirement: The document’s focus on the five-year housing land supply (5YHLS) directly relates to local planning policies and their compliance with national standards.

The requirement to maintain a five-year housing land supply is a fundamental aspect of local planning policies. The document’s analysis highlights the current shortfall in East Hampshire, showing the council’s difficulty in meeting this national policy requirement.


  • Accuracy of Housing Supply Figures: Ensures that the planning authority bases its decisions on reliable and accurate data.

The appeal decision and Pegasus Group’s assessment highlight discrepancies in the council’s housing supply calculations. Ensuring accurate and reliable data is crucial for transparent and accountable planning decisions. The document calls for thorough verification of housing supply figures, reflecting the planning authority’s responsibility to base decisions on robust evidence.

  • Current Five-Year Housing Land Supply: The figures on the availability and deliverability of housing land supply pertain to land use considerations within the planning area.

The assessment’s findings regarding the supply of deliverable homes directly impact land use planning. The need to allocate sufficient land for housing development is essential to address housing shortages and manage land resources effectively.


  • Housing Need and Requirements: The assessment of housing needs against local housing requirements reflects land use planning strategies.

The calculated need for 464 homes per annum, based on the Standard Method, informs local land use decisions. Meeting these needs requires identifying suitable land for development, balancing this with other land use priorities, and ensuring appropriate infrastructure.

  • Need for Additional Housing: Emphasising the need for additional housing to restore the four-year housing land supply aligns with economic benefits by addressing housing shortages and supporting local economic growth.

Addressing the housing supply shortfall has significant economic benefits. Increasing the housing stock can stimulate local economies by attracting new residents, supporting construction jobs, and enhancing local services and amenities. The document underscores the economic necessity of approving additional housing developments to meet demand.

  • Impact on Local Infrastructure: Although not explicitly detailed in the summary, the broader implications of housing development on local infrastructure and services are a material consideration. Increased housing supply requires supporting infrastructure, which is implicitly linked to this assessment.

Although the document primarily focuses on housing supply, the implications for local infrastructure and services are implicit. Increased housing will necessitate investments in roads, schools, healthcare, and utilities to support the growing population. This consideration is crucial for sustainable development and ensuring that infrastructure keeps pace with housing growth.

  • Sustainable Development: The principle of sustainable development is central to the NPPF and the discussion of planning permissions under Paragraph 11, which emphasises sustainable growth.

The NPPF’s emphasis on sustainable development is central to the assessment. Paragraph 11 of the NPPF, which sets the presumption in favour of sustainable development, is particularly relevant. Ensuring that new housing developments are sustainable in terms of environmental impact, resource use, and community integration is a key planning consideration.

  • Impact on Local Community: Indirectly, the document touches on residential amenity by considering the cumulative effects of housing developments on the local community.

The cumulative impact of housing developments on the local community is an important aspect of residential amenity. The document suggests that piecemeal development can lead to significant adverse impacts if not properly managed and assessed collectively. Ensuring that new developments enhance rather than detract from the quality of life for existing and future residents is a critical consideration.

  • Accuracy of Housing Supply Figures: The accuracy and reliability of the Council’s housing supply figures, as challenged by the appeal decision and Pegasus Group’s assessment, reflect the local planning authority’s responsibilities and accountability in planning matters.

The appeal decision and Pegasus Group’s assessment highlight discrepancies in the council’s housing supply calculations. Ensuring accurate and reliable data is crucial for transparent and accountable planning decisions. The document calls for thorough verification of housing supply figures, reflecting the planning authority’s responsibility to base decisions on robust evidence.

Material Consideration


  • Local and National Planning Policies: The assessment influences compliance with planning policies and frameworks at both local and national levels.
  • Infrastructure and Services: Evaluates the availability and capacity of infrastructure and services to support new housing developments.
  • Residential Amenity: Considers the impact of housing supply on the living conditions and quality of life for existing and future residents.
  • Sustainability: Addresses the long-term sustainability of housing developments in relation to environmental, economic, and social factors.
  • Land Use: Directly affects decisions on the allocation and use of land for housing developments.

Conclusion


The primary categories are Local and National Planning Policies, Land Use, and Economic Benefits, as these directly relate to the planning framework, housing needs, and implications of the housing land supply assessment.

Infrastructure and Services, Sustainability, and Residential Amenity are also relevant as they reflect the broader impacts and considerations of the proposed housing developments.


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