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Housing Delivery Test Action Plan 2020-2021 July 2020 CONTENTS

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Housing Delivery Test Action Plan 2020-2021 July 2020 CONTENTS ANNEX 1 Gosport Borough Council Housing Delivery Test Action Plan 2020-2021 July 2020 CONTENTS 1.0 INTRODUCTION 3 - Context - Housing Delivery Test - Housing Delivery Test Results February 2020 - National Planning Practice Guidance 2.0 BARRIERS TO HOUSING DELIVERY 8 - Gosport Housing Land Supply - Infrastructure - Housing Market - Environmental Issues - Development Viability - Competing Land Uses 3.0 KEY ACTIONS 16 - Local Plan Review - Working with Others - Development Management Processes - Heritage Action Zone - Gosport Taskforce - One Public Estate - Social and Affordable Housing Development Strategy - Other GBC Sites - Brownfield Register - Improving Infrastructure 4.0 CONCLUSIONS 26 APPENDIX ONE: GOSPORT HOUSING DELIVERY TEST ACTION PLAN 2 1.0 INTRODUCTION Please note: The Action Plan does not set out any possible impacts of the ongoing Covid 19 pandemic as the three year period which informed the Housing Delivery Test result ended in March 2019. It is currently anticipated that future iterations of the Action Plan will set out any implications for housing delivery arising from the pandemic although the extent of this is as yet unknown 1.1 Context 1.1.1 Gosport Borough Council (GBC) recognises the Government’s commitment to boost the delivery of new homes and has responded to this challenge by taking a proactive approach to working with developers and landowners to facilitate delivery on a number of very complex brownfield sites. The current Gosport Borough Local Plan 2011-2029 (GBLP’) was adopted in October 2015 following an Examination in Public (EiP). The Local Plan sets out that during the plan period 2011 to 2029 the housing target is 3,060 net new dwellings with an average delivery of 170 per annum. 1.1.2 GBC has long-recognised constraints on the availability of sites and limitations of highway infrastructure associated with its peninsula location. These constraints have been recognised at both sub-regional and regional level and have informed previous higher-level development plans and the current South Hampshire Strategy1. Nonetheless, GBC will continue to contribute towards the overall sub-regional requirements by taking a positive approach towards new residential development. 1.2 Housing Delivery Test 1.2.1 The Housing Delivery Test (HDT) was introduced by the Government as a monitoring tool in order to speed up the delivery of housing2. The HDT is an annual measurement of housing delivery in terms of the total number of new houses and flats completed in a local authority area annually. The first set of HDT results were published in February 2019. The second set of HDT results were published in February 2020 (see Section 1.3). 1.2.2 The HDT will be used to determine the level of consequences applied to the local authority where the delivery of the housing requirement has not been met. The national Planning Practice Guidance (PPG)3 provides further details on Government planning policies set out in the National Planning Policy Framework (NPPF), including the Housing Delivery Test measurement. This states where delivery of housing has fallen below the housing requirement, 1 https://www.PfSH.gov.uk/work/planning-and-infrastructure/PfSH-position-statement/ 2 https://www.gov.uk/government/collections/housing-delivery-test 3 https://www.gov.uk/guidance/housing-supply-and-delivery 3 certain policies set out in the NPPF will apply. Depending on the level of delivery these are:- The authority should publish an action plan if housing delivery falls below 95%; A 20% buffer on the local planning authority’s 5 year land supply if housing delivery falls below 85%; and Application of the presumption in favour of sustainable development if housing delivery falls below 75% subject to the transitional arrangements (NPPF Paragraph 215). 1.2.3 These consequences apply concurrently. For example, those who fall below 85% should produce an action plan as well as the 20% buffer. The consequences will continue to apply until the subsequent HDT measurement is published. The relevant consequences for any under-delivery will then be applied. Should delivery meet or exceed 95% no consequences will apply. 1.2.4 The NPPF Paragraph 215 sets out that the ‘presumption in favour of sustainable development’ applies on a sliding scale under transitional arrangements. For this year it will apply where the HDT falls below 45% and for November 2020 if this falls below 75%. 1.2.5 In line with NPPF Paragraph 11, the primary implication of the presumption in favour of sustainable development for decision takers is that policies which are most important for determining applications are out of date and hence planning permission should be granted unless (emphasis added): The application of policies in the NPPF that protect areas or assets of particular importance provides a clear reason for refusing the development proposed; or Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits when assessed against the policies in the NPPF as a whole. 1.2.6 However, Gosport Borough is surrounded by international habitat designations (Special Protection Areas and Special Areas of Conservation, amongst others) and therefore the entire Borough is subject to Habitats Regulations. This results in the Borough falling within the zone of influence where housing development is likely to have a significant effect on the integrity of the designations. As such, it is not possible to automatically apply the presumption in favour of sustainable development as a likely significant effect cannot be ruled out without the completion of an Appropriate Assessment (AA). This is in line with the NPPF (2019) Paragraph 177: The presumption in favour of sustainable development does not apply where the plan or project is likely to have a significant effect on a habitats site (either alone or in combination with other plans or projects), unless an appropriate assessment has concluded that the plan or project will not adversely affect the integrity of the habitats site. 4 1.3 Housing Delivery Test Results (February 2020) 1.3.1 The HDT Measurement Rule Book (February 2019)4 sets out the method for calculating the HDT result. The HDT compares the net homes delivered over the previous three financial years to the homes that should have been built over the same period as identified by the housing requirement for each authority. The housing requirement is either that identified in a recently adopted Local Plan i.e. where the plan is less than 5 years old, or a standard methodology is applied, as set out in the HDT Technical Note (February 2019), namely the annual average household growth plus any unmet need. 1.3.2 The outcomes of the second HDT were published for the second time by the Ministry of Housing, Communities and Local Government (MHCLG) on 24 February 2020. The HDT assesses the number of homes built in local authority areas over the previous three years and compares these against local housing requirements. The February 2020 HDT results set out that the Borough scored 87% with an under-delivery of 64 dwellings over the last three years against the Local Plan target of 170 dwellings per annum5. The results as published are set out in Figure One below. Figure 1: Gosport Housing Delivery Test Result, February 2020 YEAR Total 2016/17 2017/18 2018/19 Number of Homes Required 170 170 170 510 Number of Homes Delivered 166 221 58 445 Number of Homes -4 51 -112 -65 Delivered less Required Housing Delivery Test Result 87% Housing Delivery Test Consequence ACTION PLAN 1.3.3 Therefore, as a consequence of the HDT, there is a requirement for GBC to prepare an Action Plan. The Action Plan should cover the period 1 April 2020 to 31 March 2021. The third HDT results are currently proposed to be published in February 2021. The need for an updated Action Plan in 2021 will be considered in light of these results. 4 https://www.gov.uk/government/publications/housing-delivery-test-measurement-rule-book 5 The results of the first HDT for 2018/19 as reported in the Council Annual Monitoring Report was 111% 5 1.3.4 The GBC HDT Action Plan summarised in Section 4 of this report has been produced by the LPA in line with requirements set out in national planning guidance which states that such plans should: outline the local challenges; identify actions to address under delivery; and set out measures to maintain or improve levels of delivery 1.3.5 The Action Plan has involved the consideration of reasons for the under delivery of new housing in the Borough and aims to put in place suitable actions to speed up future delivery and ensure that this is maintained. 1.4 National Planning Practice Guidance 1.4.1 The national PPG sets out6 that the Local Planning Authority (LPA) may wish to include in their Action Plans an analysis of under delivery considering: Barriers to early commencement after planning permission is granted and whether such sites are delivered within permitted timescales; Barriers to delivery on sites identified as part of the 5 year land supply; Whether sufficient planning permissions are being granted and whether they are determined within statutory time limits; Whether the mix of sites identified is proving effective in delivering at the anticipated rate; Whether proactive pre-planning application discussions are taking place to speed up determination periods; The level of ongoing engagement with key stakeholders to identify more land and encourage an increased pace of delivery; Whether particular issues such as infrastructure or transport could be addressed at a strategic level. 1.4.2 In light of the PPG, Section 2.0 of this report sets out an initial analysis of potential barriers to housing delivery in Gosport. Section 5.0 sets out any conclusions drawn.
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