& DEANE BOROUGH COUNCIL

Town and Country Planning Act 1990 – Section 78

Town and Country Planning Appeals (Determination by Inspectors) (Inquiries Procedure) () Rules 2000

PROOF OF EVIDENCE

Of

Mr Andy Blaxland BA (Hons), Dip TP, Dip Mgt, MRTPI

On behalf of the Local Planning Authority

Outline planning permission for the erection of up to 90 dwellings with public open space, landscaping and sustainable drainage system (SuDS). Demolition of garages to form a vehicular access point from Bow Drive and replacement garaging. All matters reserved except for means of access.

LAND OFF GODDARDS LANE, SHERFIELD ON LODDON, BASINGSTOKE

Appeal by Vivid Homes and Gladman Developments Ltd

Planning Inspectorate Reference: APP/H1705/W/19/3226286

Basingstoke & Deane Borough Council Reference: 18/03486/OUT

FINAL 17th July 2019

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 1

CONTENTS

1 QUALIFICATIONS AND EXPERIENCE ...... 3 2 SCOPE OF MY EVIDENCE ...... 4 3 RELEVANT HOUSING LAND SUPPLY POLICY FRAMEWORK AND GUIDANCE ... 5 4 THE COUNCIL’S CURRENT HOUSING LAND SUPPLY POSITION ...... 9 5 MATTERS OF DIFFERENCE ON HOUSING LAND SUPPLY BETWEEN THE PARTIES (AS IDENTIFIED BY THE APPELLANT), AND EVIDENCE ON THESE MATTERS ...... 13 6 CONCLUSIONS, INCLUDING THE RELEVANCE OF THE HOUSING LAND SUPPLY POSITION TO THE PLANNING BALANCE ...... 33

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 2 1 QUALIFICATIONS AND EXPERIENCE

1.1. My name is Andy Blaxland and I am a Director of Adams Hendry Consulting Ltd. I am a Chartered Town Planner with a BA (Hons) in Economic Development & Planning and a Postgraduate Diploma in Town Planning, both from Coventry University.

1.2. I have 25 years of town planning experience in public and private sector roles, and have been employed as a consultant at Adams Hendry Consulting Ltd since 2004, initially as an Associate and as a Director since 2007. My role includes leading public and private sector projects, including providing support to local authorities’ Local Plan preparation; and supporting their development management functions, including the determination of planning applications and work on planning appeals. I also lead Adams Hendry’s water and wastewater, minerals and waste, and energy infrastructure projects.

1.3. Prior to joining Adams Hendry in July 2004, I was employed as Forward Planning & Transport Manager at Borough Council (BDBC), where I was responsible for Local Plan preparation, housing land supply, major development sites and transport policy. I held a number of planning policy related roles at BDBC between 1994 and 2004.

1.4. I have undertaken a number of residential planning appeals for local planning authorities within , providing evidence on matters relating to housing land supply, application and interpretation of policy and the planning balance.

1.5. I am familiar with the local and national policies and guidance relevant to this Inquiry, and am familiar with the local area.

1.6. I am instructed by BDBC to act on its behalf as the planning expert witness on matters relating to housing land supply for this appeal.

1.7. I can confirm that the evidence which I will give is true, and in accordance with the guidance of my professional institute, the Royal Town Planning Institute. Any opinions expressed are my own true and professional opinions.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 3 2 SCOPE OF MY EVIDENCE

2.1. I will provide evidence on the housing land supply related issues in respect of this appeal. My evidence to the inquiry is structured as follows:

• Section 3 sets out the relevant housing land supply policy framework and guidance.

• Section 4 sets out the Council’s current housing land supply position.

• Section 5 identifies matters of difference on housing land supply between the parties as identified by the Appellant, and provides evidence on these matters.

• Section 6 provides housing land supply conclusions, including the relevance of the housing land supply position to the planning balance.

2.2. The matters in dispute relating to housing land supply remain under discussion at the time of submitting this proof of evidence. The Council intends to continue to seek to reach additional agreement with the Appellant on housing land supply matters prior to the start of the Inquiry.

2.3. Should it be necessary to do so, a supplementary housing land supply proof of evidence or supplementary housing land supply statements of common ground (SoCG) will be prepared and submitted to the Inquiry.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 4 3 RELEVANT HOUSING LAND SUPPLY POLICY FRAMEWORK AND GUIDANCE

3.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires local planning authorities to determine applications for planning permission in accordance with the provisions of the development plan unless material considerations indicate otherwise.

The Development Plan

3.2 The development plan relevant to the consideration of this appeal comprises the following documents:

Basingstoke & Deane Local (2011-2029) – Adopted 26th May 2016 (CD 7.02)

Sherfield on Loddon Neighbourhood Plan – made 22nd March 2018 (CD 7.01)

3.3 The Hampshire Minerals and Waste Local Plan 2013 also forms part of the Development Plan, but is not relevant to the housing land supply aspects of this appeal.

The revised NPPF (2019)

3.4 Relevant Government policy is set out in Section 5 of the NPPF.

3.5 The Government’s objective is “significantly boosting the supply of homes”, as set out in para 59 of the NPPF, noting that “it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.”

3.6 Paragraph 65 of the NPPF identifies the requirement that “Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period”.

3.7 To ensure that sufficient land is identified for residential development, Para 67 of the NPPF states that: “Strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. Planning policies should identify a supply of:

a) specific, deliverable sites for years one to five of the plan period; and

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 5 b) specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan. “

3.8 To maintain supply and delivery, the NPPF (para 73) states:

“… Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement set out in adopted strategic policies, or against their local housing need where the strategic policies are more than five years old. The supply of specific deliverable sites should in addition include a buffer (moved forward from later in the plan period) of:

a) 5% to ensure choice and competition in the market for land; or b) 10% where the local planning authority wishes to demonstrate a five year supply of deliverable sites through an annual position statement or recently adopted plan38, to account for any fluctuations in the market during that year; or c) 20% where there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply

3.9 Para 74 of the NPPF goes on to note that:

“A five year supply of deliverable housing sites, with the appropriate buffer, can be demonstrated where it has been established in a recently adopted plan, or in a subsequent annual position statement which:

a) has been produced through engagement with developers and others who have an impact on delivery, and been considered by the Secretary of State; and

b) incorporates the recommendation of the Secretary of State, where the position on specific sites could not be agreed during the engagement process.”

3.10 Para 75 of the NPPF notes that:

“To maintain the supply of housing, local planning authorities should monitor progress in building out sites which have permission. Where the Housing Delivery Test indicates that delivery has fallen below 95% of the local planning authority’s housing requirement over the previous three years, the authority should prepare an action plan in line with national planning guidance, to assess the causes of under- delivery and identify actions to increase delivery in future years”.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 6 3.11 Finally, the glossary to the NPPF identifies the following definition of a deliverable site for housing:

To be considered deliverable, sites for housing should be available now, offer a

suitable location for development now, and be achievable with a realistic prospect

that housing will be delivered on the site within five years. In particular:

a) sites which do not involve major development and have planning permission,

and all sites with detailed planning permission, should be considered

deliverable until permission expires, unless there is clear evidence that

homes will not be delivered within five years (for example because they are

no longer viable, there is no longer a demand for the type of units or sites

have long term phasing plans).

b) where a site has outline planning permission for major development, has

been allocated in a development plan, has a grant of permission in principle,

or is identified on a brownfield register, it should only be considered

deliverable where there is clear evidence that housing completions will begin

on site within five years.

The Planning Practice Guidance (PPG)

3.12 The policy in the NPPF is supported by more detailed guidance in the PPG, which is available as an online resource. The most relevant parts of the PPG for housing land supply are included in the Housing and Economic Land Availability Assessment Guidance, last updated in September 2018.

3.13 This includes guidance on Housing delivery and 5 year land supply in paragraphs 3-028- 20180913 to 3-054-20180913. Specifically in relation to deliverable sites, para 3-036, notes that “…where clear evidence is required to demonstrate that housing completions will begin on site within 5 years, this evidence may include:

• Any progress being made towards the submission of an application;

• Any progress with site assessment work; and

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 7 • Any relevant information about site viability, ownership constraints or infrastructure provision.”

3.14 The council’s housing land supply position, taking account of the above is set out in Section 4 of this proof of evidence.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 8 4 THE COUNCIL’S CURRENT HOUSING LAND SUPPLY POSITION

Context at the time of the determination of the application

4.1 At the time of the determination of the planning application, as set out in the Officer’s Report (CD 5.01) the council considered that it could demonstrate a five year housing land supply, although this was not a position that was accepted by the Appellant.

Context for the Council’s stated housing land supply for this Inquiry

4.2 The council’s housing land supply position is published annually in December through the Authority Monitoring Report (AMR). The most recently published AMR was in December 2018 for 2017/18 (CD 8.10) which demonstrated a 5.3 years supply based on the position at 1st April 2018.

4.3 At the time of writing this evidence, the 2017/18 AMR still represents the most up to date published annual statement.

4.4 The council is in the process of preparing its next AMR, to be published in December 2019, which will when completed identify the housing land supply position at April 2019.

4.5 As part of its preparation for this Inquiry, the council issued a Housing Land Supply Statement (CD 8.11) dated 18 June 2019, representing the council’s stated housing land supply at that date. This represented a partial update of its annual statement, for the purposes of informing the Inquiry, albeit that the confirmed housing completion data for 2018/19, and the position on individual development sites continued to be updated as new information was secured.

4.6 An Addendum to the land supply statement dated 27 June 2019 (CD 8.12) was issued to update and clarify the position on some of the largest changes to housing land supply since the December 2018 AMR.

4.7 At the request of PINS and the Appellant, further information for the Inquiry on housing land supply was published by the council on 8 July 2019, comprising a detailed schedule of the individual components of the council’s housing land supply (CD 8.13). A detailed schedule of the 2018/19 housing completions information from Hampshire County Council was also issued to the Appellant and Inquiry on 10th July 2019.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 9 4.8 By letter dated 12 July 2019 (CD 8.22), the Appellant’s housing land supply witness identified areas of disagreement between the parties. These are summarised, and my evidence provided in response, in section 5 of this proof of evidence.

Explanation of the Council’s approach to monitoring housing land supply

4.9 A comprehensive updated land supply position covering the 2018/19 monitoring year will be published through the 2019 AMR in December 2019, when all of the relevant information will be available.

4.10 The council’s evidence is gathered on a site by site basis and is informed by consultation with the individual landowners, housebuilders and agents on an at least annual basis. This allows the council to use relevant data for the site in question including sales, marketing and phasing information and to identify any specific considerations applicable to individual sites rather than applying an average taken from a national dataset.

4.11 The information provided through such consultation is critically reviewed by officers to ensure that a robust position is given in the council’s land supply schedules. Lead-in times and build out rates used are also externally validated and agreed with Hampshire County Council (HCC) every year. HCC officers have decades of experience having undertaken housing monitoring jointly with all Hampshire districts through a service level agreement for many years. They are also able to draw upon site specific information relating to lead-in and build out rates of sites of varying sizes across the county supplementing individual site assumptions with sub-regional evidence and trends where relevant.

4.12 The council’s monitoring and updates for the 2019 AMR are continuing, however the council has accelerated the release of information on housing land supply for the purposes of the Inquiry. Further information may come to light as discussions with applicants and developers continue, and the final 2019 AMR position may differ from that set out in evidence for this Inquiry.

4.13 From my own examination of the evidence currently available, I am satisfied that the information currently available is a robust basis for this Inquiry.

The basis for the council’s housing requirement

4.14 The current Local Plan (2011-2029) (CD 7.02) was adopted in May 2016 and sets out a sound housing strategy for meeting the borough’s needs over the plan period. The Local

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 10 Plan Inspector’s report, published in April 2016 (CD 7.03) concluded the following in relation to overall housing supply:

‘81. Based on the above considerations, I am satisfied that the housing provision in the Plan is sufficient to meet the Borough’s requirement within the plan period on an appropriate range of deliverable sites, and that the Plan is therefore both justified and effective in this respect.’

4.15 Paragraph 73 of the NPPF provides that a Local Planning Authorities’ (LPA) housing land supply should be measured against the housing requirement set out in adopted strategic policies unless those policies are more than five years old. As the strategic policies of relevance here were adopted less than five years ago, the housing requirement is that set out in the adopted policy.

The council’s currently stated housing land supply for the Inquiry

4.16 Taking the above documentation together, the council accepts that it cannot currently demonstrate a 5 year housing land supply.

4.17 The council’s stated housing land supply for the purposes of the Inquiry, at the time of writing this proof of evidence, is as set out in the table below.

Total Requirement (2011 to 2029) – (850 dpa x18 15,300 years)

Completions (2011/12 – 2018/19) 5,005

Shortfall (2011/12-2018/19) 1,795 [6800 (850x8) – 5,005]

Requirement (2019/20 – 2023/24) 4,250 [850x5]

Requirement plus proportionate amount of shortfall 5,148 [4,250+898] (1,795/10x5) – Liverpool method

Requirement Plus 20% 6,178 [5,148 + 1030]

Revised Annual Requirement (2019/20 – 2023/24) 1,236 [6,178 ÷ 5]

5 year Supply 5,686 Years Supply 4.6 Years [5,686 ÷ 1,236]

4.18 The sites forming part of the council’s supply are identified in detail in the tables issued for the Inquiry on 8th July 2019, and included as CD 8.13.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 11 Housing Delivery Test Action Plan

4.19 The Housing Delivery Test (HDT) was introduced in 2018 by Government as part of its agenda to deliver a step change in housing delivery across the country. As a result, the first Housing Delivery Test (HDT), published by MHCLG in February 2019, required the council to prepare a Housing Delivery Test Action Plan (HDTAP), the purpose of which is to identify key issues for the borough and outline what actions will be taken to increase and maintain delivery levels.

4.20 The council’s HDTAP was approved by the council’s Cabinet at its meeting on 9th July 2019, for publication. The document identifies the significant steps that the council is taking to promote housing delivery within the Borough. A copy of the document is included as a core document (CD 8.14).

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 12 5 MATTERS OF DIFFERENCE ON HOUSING LAND SUPPLY BETWEEN THE PARTIES (AS IDENTIFIED BY THE APPELLANT), AND EVIDENCE ON THESE MATTERS

5.1. By letter dated 12 July 2019 (CD 8.22), the Appellant’s housing land supply witness identified that is was agreed between the parties that:

• The base date is 31st March 2019 and the relevant five year period is 1st April 2019 to 31st March 2024;

• The local plan was adopted in 2016 and is less than 5 years old. The annual housing requirement is therefore 850 dwellings per annum as set out in Local Plan policy SS1;

• A total of 5,005 dwellings were completed between 1st April 2011 and 31st March 2019, against a total requirement for the period of 6,800 dwellings;

• The shortfall at 31st March 2019 is 1,795 dwellings; and

• Following the 2018 Housing Delivery test results, the 20% buffer should be applied.

5.2. By the same letter, however, the Appellant’s housing land supply witness identified the following areas of disagreement between the parties:

1. The method for addressing the past shortfall

2. The extent of the deliverable supply, with commentary provided as to the degree of difference on 24 individual sites.

3. The inclusion of a small sites windfall allowance of 100 dwellings

5.3. The Appellant’s housing land supply witness summarised the extent of the difference between the parties as follows:

Requirement Council Appellant

A Annual requirement 850 850 B Past shortfall at 1st April 2019 1,795 1,795 C Amount of past shortfall to be addressed in the 898 1,795 five year period D Total five year requirement (A X 5 + C) 5,148 6,045 E Requirement plus 20% buffer (D + 20%) 6,178 7,254 F Annual requirement plus buffer (E / 5 years) 1,236 1,451

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 13 Supply

G Five year supply 1st April 2019 to 31st March 5,686 4,069 2024 H Years supply (G / F) 4.6 2.8

5.4. At the time of submitting this proof of evidence, these issues remain as the areas of disagreement between the parties. Should the situation change prior to the Inquiry then I will update the Inspector accordingly either through a supplementary proof of evidence or through the housing land supply SoCG.

5.5. My evidence on the matters of difference is as set out below.

1. The method for addressing the past shortfall

5.6. The Appellant considers that the past shortfall (of 1,795 dwellings) should be addressed in the five year period (the ‘Sedgefield method’), in accordance with para 3-044 of the PPG (ID 3-044-20180913).

5.7. The Council maintains that its approach, of addressing the shortfall over the plan period to 2029 (the ‘Liverpool method’) is the appropriate approach to take.

5.8. As the Appellant rightly notes, Para 3-044 of the PPG states that “The level of deficit or shortfall will need to be calculated from the base date of the adopted plan and should be added to the plan requirements for the next 5 year period (the Sedgefield approach)”.

5.9. However, the paragraph goes on to note that “If a strategic policy-making authority wishes to deal with past under-delivery over a longer period, then a case may be made as part of the plan-making and examination process rather than on a case by case basis on appeal”.

5.10. This is precisely the case that the council has made, as part of the preparation of its Local Plan. The issues was considered at the Examination and the Inspector conclusively concluded that the council’s approach was sound in his report (CD 7.03). The relevant extracts of his report are set out below:

“(vii) The appropriate period for making up the shortfall

93. The Council’s view is that making up the shortfall should be apportioned to the Council’s total evenly over the plan period (commonly known as the Liverpool approach), whilst several (but not all) of the representations from

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 14 house builders argued for the shortfall to be made up in the first 5 years (commonly known as the Sedgefield approach).

94. The PPG advises that the local planning authorities should aim to deal with any undersupply within the first 5 years of the plan period, although this is qualified by the expression “where possible”. The Council’s reasons for pursuing the Liverpool approach are linked to its partial reliance on several large sites, which require the provision of significant infrastructure prior to the completion of the first dwellings. These major allocations, which I deal with below in more detail, are sustainably located, near to the main urban areas, especially Basingstoke; they can achieve economies of scale and important community and environmental provision. In my view, these benefits outweigh the delay in their implementation. I therefore support the use of the Liverpool approach for Basingstoke and Deane.

95. The housing trajectory shows projected annual completions to exceed 1,000 dpa from 2017/18 through to 2024/25. It also shows that the shortfall would be made up completely over a period of 7 years, i.e. by 2021/22. The trajectory which is included in the Plan, as required by modification [MM86] ensures clarity in the effectiveness of the Plan in scheme delivery.

96. I therefore consider that the spreading of the shortfall over the entire plan period is the most appropriate method for Basingstoke and Deane. There are several recent Local Plan Examinations where the Liverpool method, has been found to be sound, including East Staffordshire (October 2015), Canterbury (August 2015) and Lichfield (January 2015).

97. The thrust of several representations is that there is urgency for the Plan to deliver the housing the Borough needs. The Council is aware of this and I am confident that it will proceed quickly to Plan adoption to enable the Borough to be able to benefit from the plan-led system as soon as possible.“

5.11. There has been no material change in circumstances since matters were assessed by the Local Plan Inspector to suggest that a different approach to land supply should now be taken. The Local Plan Inspector was well placed to consider the suitability of the two different methodologies for calculating land supply in a comprehensive and rigorous manner in light of all relevant factors, and came to a reasoned conclusion having

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 15 weighed up the sustainability credentials of the Local Plan’s housing strategy against delivery timescales. The continued use of this method is therefore considered suitable.

5.12. In line with the Local Plan Inspector’s recommendations, the council has acted quickly to adopt the plan (adopted in May 2016) to enable the borough to benefit from the plan- led system. The council has taken a pro-active approach to planning applications in recent years as reflected in the number of permissions granted which has risen significantly. However, sites take time to deliver dwellings on the ground due to the relevant lead in times and therefore a realistic approach should be taken to housing delivery given the council’s adopted strategy which relies on strategic sites and thus the Liverpool method remains the most appropriate approach.

5.13. This is supported in the Secretary of State's appeal decision at Fisherwick Road, Lichfield, Staffs, (13 February 2017) (APP/K3415/W/15/3024063), which maintained the use of the Liverpool method for calculating land supply where this had been recently endorsed by a Local Plan Inspector (some 2 years prior to the Secretary of State’s decision).

2. The extent of the deliverable supply, with commentary provided as to the degree of difference on individual sites.

5.14. The Appellant’s housing land supply witness’s letter of 12th July included a table of some 21 sites which it considered not to be deliverable, in the absence of evidence from the council as required by para 3-036 of the PPG. In addition, the Appellant’s witness also identified concerns relating to the inclusion of 3 further sites, a site adjoining the White Hart, Reading Road, a site at Copenhagen Court, and a site at Innovation Court.

5.15. My response on each of these sites is as set out below, based on discussions with the Council Officers and informed by their work on the 2019 AMR.

5.16. As noted above, discussions with the Appellant on housing land supply matters are continuing and should further agreement be reached, the Inquiry will be updated accordingly.

Upper Cufaude Farm, Basingstoke

5.17. It is considered that the site meets the deliverability tests as the site is available for housing now, offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 16 site is allocated for approx 390 units in the adopted Local Plan (Policy SS3.8). In line with policy SS3, a development brief SPD was adopted by the council in March 2019.

5.18. The preparation of the SPD has enabled issues associated with the site to be considered upfront by relevant stakeholders. The land is owned by HCC with the majority of the site held under option to Croudace Homes who control access to the site. Croudace are actively taking the majority of the site forward (approx.350 units) and technical studies have been completed to inform the outline application which was submitted in January 2019 (19/00018/OUT). This is due to be determined at Development Control Committee over the summer.

5.19. Through the site monitoring process, Croudace Homes has confirmed that the site is deliverable and will be complete by 2027/28, with 100 dwellings falling within the 5 year period. Predicted completion rates are based on an anticipated planning permission date and their current build programme at the neighbouring Vyne Park site which is due to complete in 2021/22. Croudace do not foresee any constraints likely to impact on future delivery and their presence on the neighbouring site will assist in reducing potential delivery issues eg access points in place etc. A statement of intent is due to be agreed to reflect the above position, in line with the council's adopted Housing Action Plan (CD 8.14).

5.20. HCC has confirmed that the timing of the delivery of the remainder of the site (40 units) is dependent on the Croudace development given that utility provision (water supply and foul) is subject to contractual triggers in the option agreement. However, utility provisions are to be provided within 2 years of commencement and therefore the smaller parcel is likely to be completed around 2026.

5.21. For the purposes of land supply, the 40 units have been placed at the end of the development (2028/29), outside the 5 year period, although this will be monitored.

5.22. There is clear evidence that completions will take place on the site within 5 years and there are no foreseen constraints to delivery.

East of Basingstoke

5.23. The site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site is allocated for approximately 450 units in the adopted Local Plan (Policy

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 17 SS3.9). In line with policy SS3, a development brief SPD for this site and the neighbouring Redlands sites was adopted in July 2017.

5.24. Following meetings to discuss progress with Hampshire County Council owned sites, HCC Officers have confirmed, subject to member approval (which is not considered likely to be withheld), that the site will now be taken forward in 2 phases. The northern part of the site will be taken forward as a first phase for approximately 150 units and is likely to be accessed from the north, with links to the Redland site allocation.

5.25. There are no notable constraints to the delivery of this part of the site and this approach will enable development to progress in the short term. Survey and technical reports are currently being progressed to support a development framework document which will form the basis for marketing this part of the site later this year. Given the potential timescale involved in selling this part of the site and gaining relevant permission, delivery has been pushed back to 2023/24 for land supply purposes although the site could come forward more quickly. Therefore just 50 units are included in the 5 year supply from this allocation.

5.26. The remainder of the allocation (300 units) will be delivered once infrastructure requirements (new access off the A33) are more fully understood and this work is on- going. These dwellings are not included in the 5 year period.

5.27. A statement of intent is due to be agreed with HCC to reflect the above position, in line with the council's adopted Housing Action Plan (CD 8.14).

5.28. There is therefore clear evidence that housing completions will be delivered on part of the site within 5 years and there are no foreseen constraints to delivery.

Basingstoke Golf Course

5.29. The site is allocated for approximately 1,000 units in the adopted Local Plan (Policy SS3.11). Members of the golf club have voted to buy an existing club and relocate following relevant improvement works, making the site available for redevelopment.

5.30. Bloor Homes signed an agreement with the club to develop out the site in late 2018 and it is now required to quickly and actively take the site forward in light of contractual arrangements.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 18 5.31. A Development Brief SPD is being developed for the site by the council and is due to be adopted in October 2019. An outline application for up to 1,100 homes was submitted in April (19/00971/OUT) and is due to be determined in the Autumn.

5.32. Through the site monitoring consultation the agent (Boyer Planning ) has, on behalf of the developer, confirmed that the site is deliverable. It stated that the developer is committed to delivery on the site as soon as possible and hope to be delivering the initial phase in 2020/21.

5.33. Bloor Homes is currently aiming to deliver the site in phases from 2020/21, subject to approval of the outline planning application and subsequent reserved matters. Its predicted completion rates (20 in 2020/21 and 120 units annually thereafter) take into account the fact that an outline planning application has been submitted and is due to be determined in autumn 2019.

5.34. Bloor Homes and its consultant team is currently working on the detailed design matters and therefore reserved matters applications will be submitted as soon as practically possible following the grant of outline planning permission. Boyer do not anticipate any delays to commencement or build out rates subject to planning and infrastructure delivery. A statement of intent is due to be agreed to reflect the above position, in line with the council's adopted Housing Action Plan (CD 8.14).

5.35. The council’s consideration is that the predicted delivery in 2020 is optimistic and therefore in light of relevant lead in times a more conservative rate of development (pushed back 2 years) has been included in the 5 year housing land supply schedule to ensure a robust position in land supply terms. The rate of delivery once the site is up and running reflects the phasing suggested by Bloor Homes. Some 140 dwellings are therefore included in the 5 year supply. Some 260 units now lie outside the Local Plan period but will be delivered post 2029.

5.36. The site meets the deliverability tests and there is clear evidence that the site will start to be delivered in the 5 year period.

Manydown, Basingstoke

5.37. The site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 19 The site is allocated for approx. 3,400 units in the Local Plan (Policy SS3.10) and is primarily in the ownership of the council and HCC (who have a 999 year lease) in addition to two smaller parcels in separate ownerships.

5.38. A Development Brief SPD to guide development across the allocation was adopted in December 2016. A development partner (Urban and Civic) for the BDBC/HCC owned land was selected in February 2018. An outline application (with all matters reserved except access) (17/00818/OUT) is due to be determined in Autumn 2019 following what the council accepts is a lengthy delay resulting primarily from the need to resolve a number of highway issues.

5.39. The outline application seeks consent for residential-led development and the submitted application tests a site capacity of 3,200 dwellings +10% (3,520 dwellings). The phasing used in the housing land supply schedule reflects the information submitted as part of the outline application, plus more recent updates from discussions held with the landowners through the site monitoring consultation, and the landowners' delivery plan. In light of previous delays, the site has been phased back from past predictions, with some 250 dwellings now being included in the 5 year supply.

5.40. In addition to finalising the outline application, design codes/site wide frameworks are currently being worked up. Reserved matters applications for green and grey infrastructure will be developed in tandem with key phase masterplanning and first phase applications are due to follow in 2020/21. Discharge of conditions will be addressed in parallel and on future phases at the appropriate time. It is expected that development will commence by Spring 2021. The approach being taken to the site reflects the recognised need to progress a number of work streams concurrently including the outline application, site wide frameworks and design codes followed by phased reserve matter applications.

5.41. The two landowners are committed to accelerated levels of delivery on the site, which requires government support via additional infrastructure and services investment. Significant Government funding has already been secured and this, in addition to an increased diversity of offer and the ability to draw in greater market demand, given the nature of the development, will lead to high levels of delivery over coming years. However, initial delivery levels are relatively conservative to ensure a robust 5 year land supply position.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 20 Andover Road, Oakley

5.42. The site is allocated for approximately 15 units under Policy 3 of the adopted Oakley and Deane Neighbourhood Plan (2011-2029). An application for up to 16 units was submitted in October 2016 (16/03881/OUT) but subsequently withdrawn in September 2018. A further outline application for demolition of the existing cottage and the erection of up to 15 dwellings, with car parking for the village hall (18/02521/OUT) has a resolution to grant consent subject to completion of a S106 agreement.

5.43. Through the annual monitoring process the agent has stated that it considers the site to remain deliverable, and expecting completions on site to fall within 2022/23 (7 units) and 2023/24 (8 units). The council considers that these predictions are reasonable for land supply purposes and that the site will be delivered within the 5 year period.

Sainfoin Lane, Oakley

5.44. The site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site is allocated for approximately 35 units under Policy 3 of the adopted Oakley and Deane Neighbourhood Plan (2011-2029).

5.45. Through the site monitoring consultation Phillips Planning (the agent) noted that Cooper Estates Strategic Land (CESL) are in the process of purchasing the site and that they would be the sole land owner. This position has since been confirmed and they are preparing a pre-application submission (background studies, ecology, flood risk, highways etc. have been undertaken) with a planning application due to be submitted later this year/ early 2020.

5.46. The agent anticipates 20 completions in 2020/21 and 15 in 2021/22, although this has been pushed back a year by the council in its housing land supply schedule, to ensure a robust land supply position. The council accepts that there is a delay in the delivery of the site compared to predictions in previous AMR land supply schedules, however this is associated with the sale of the land, an issue that has now been resolved. There is clear evidence that housing completions will take place on the site within 5 years and there are no foreseen constraints to delivery.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 21 Oakley Hall, Oakley

5.47. The site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site is allocated for approximately 30 units under Policy 3 of the adopted Oakley and Deane Neighbourhood Plan (2011-2029).

5.48. An outline application for up to 33 units was submitted on behalf of the Fogarty Group Ltd and Cove Construction Limited, in December 2018 (18/03558/OUT) and is due to be determined in Autumn 2019. At the time of writing this proof, no updated response has yet been received in response to the site monitoring consultation, and therefore the council is using the previously submitted information and has made assumptions based on delivery for this small greenfield site. Subject to outline permission being granted in 2019 and reserved matters approved in 2020, this would enable completions in 2022/23 and 2023/24 allowing for some slippage.

5.49. There is clear evidence that housing completions will take place on the site within 5 years.

South of Two Gate Lane, Overton

5.50. The site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The Overton Neighbourhood Plan, adopted in July 2016, allocates this site (Site F) for 70 units.

5.51. Through the site monitoring consultation, Estates (the agent) has confirmed that the site remains deliverable. Bewley Homes are the development partner for the site and a full planning application will be submitted by the end of Summer 2019. They anticipate 11 completions in 2020/21, 38 in 2021/22 and 21 in 2022/23. These predicted completion rates take into account the fact that start on site is expected in summer 2020 (subject to securing detailed consent) and the completion of enabling works required to create and implement the access. The delivery of the site has been pushed back one year and rounded for land supply purposes by the council in its housing land supply schedules, to provide a robust position. There is clear evidence that housing completions will take place on the site within 5 years.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 22 Fawconer Road,

5.52. The site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site is allocated for approximately 12 dwellings in the Kingsclere Neighbourhood Plan (Policy K HA1) which was made in October 2018.

5.53. Through the site monitoring consultation David Wilson Homes (DWH) has confirmed that there is no reason that the site cannot come forward for development and it is considered to be deliverable. It is in the process of preparing an outline planning application for the site and anticipate 12-14 units to be completed in 2020/21. DWH consider that the timeframe allows for the determination of the outline application, site disposal and reserved matters, and they do not foresee any constraints to delivery.

5.54. To ensure a robust land supply position, the site has been phased back slightly by the council in its housing land supply schedules, for 2022/23. Whilst there is no planning permission in place, it is considered that there is evidence that housing completions will be delivered on the site within the 5 year period.

Coppice Road, Kingsclere

5.55. The site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site is allocated for approximately 26 dwellings in the Kingsclere Neighbourhood Plan (Policy K HA2) which was made in October 2018.

5.56. Through the site monitoring consultation the agent (Barton Willmore) has stated that the site is deliverable and will be taken forward within the next couple of years following approval of a planning application. It anticipates all 26 units will be completed on site within the financial year 2020/21 and don't currently foresee any constraints likely to impact on future site delivery.

5.57. The Council has adopted a slightly phased back approach to ensure a robust basis for its housing land supply schedules. Whilst there is no planning permission in place, there is evidence that the site will be delivered in the 5 year period.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 23 Strokins Road, Kingsclere

5.58. The site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site is allocated for approximately 14 dwellings in the Kingsclere Neighbourhood Plan (Policy K HA3) which was made in October 2018.

5.59. Through the site monitoring consultation the agent (Barton Willmore) has stated that the site is deliverable and will be taken forward within the next couple of years following approval of a planning application. They anticipate all 14 units will be completed on site within the financial year 2020/21 and don't currently foresee any constraints likely to impact on future site delivery.

5.60. The council has adopted a slightly phased back approach to ensure a robust basis for its housing land supply schedules. Whilst there is no planning permission in place, there is evidence that the site will be delivered in the 5 year period.

Land between Elmdene and Fairholme Road,

5.61. The site meets the deliverability tests as set out in the NPPF. Outline planning permission was granted for 12 units on the site in May 2016 (15/03029/OUT). A reserved matters application (18/03729/RES) for 11 units is currently being considered by the Council. Amended plans have been submitted and the application is due to be determined at the August 2019 Planning Committee.

5.62. The appellant accepts the delivery of 11 units on this site, in line with the reserved matters application but questions the additional 1 unit. The base date for the current land supply position is 1 April 2019 and therefore the annual position statement reflects the position at that time, namely that the site benefitted from an outline planning permission for 12 units. The difference between the parties is 1 unit.

5.63. There is clear evidence that the site is being actively progressed and that completions will begin on site within 5 years.

Swing Swang Lane, Basingstoke

5.64. This greenfield site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 24 site within 5 years. The site is allocated for approximately 100 units in the adopted Local Plan (Policy SS3.1).

5.65. An outline planning application was approved in June 2018 (17/02846/OUT) with the S106 signed in March 2019. Following meetings to discuss progress with Hampshire County Council owned sites, it has confirmed that marketing of the site is underway with a deadline for bids of September 2019.

5.66. In order to enable time for a reserved matters application by a developer, first completions are projected for 2021/22, with 30 completions forecast. Delivery predictions take into account the fact that there are no known constraints which will affect the delivery of 100 units on the site. There is therefore clear evidence that housing completions will take place on the site within 5 years and there are no foreseen constraints to delivery.

Redlands, Basingstoke

5.67. This greenfield site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site is allocated for approximately 165 units in the adopted Local Plan (Policy SS3.7).

5.68. The council received a request for EIA screening opinion in March 2015 and a development brief SPD for the site was adopted in July 2017. An outline planning application for up to 150 units on the majority of the site (16/02457/OUT) was granted in September 2017.

5.69. The site has now been sold to a developer (Bellway Homes) which is progressing the site. Active progress is being made including the submission of further masterplanning/ design work in advance of a reserved matters planning application, in line with the outline planning conditions.

5.70. The delivery rates reflect feedback from Bellway through the site monitoring process, who have stated, through its agent (Turley) that the site remains deliverable and they anticipate 50 completions per year with the first 50 in 2021/22. Their predicted delivery rates take into account planning approval, S278 approval and commencement of works, labour and material availability, open market sales rate and affordable housing delivery and appear reasonable for land supply purposes. There is clear evidence that the site

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 25 is actively being taken forward and that housing completions will be delivered on the site in line with the timescales outlined.

South of Bloswood Lane, Whitchurch

5.71. The Appellant accepts the Councils stated 90 expected completions within the 5 years. There is no disagreement on this site.

Hounsome Fields, Basingstoke

5.72. This greenfield site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site is allocated for approximately 750 units in the adopted Local Plan (Policy SS3.12).

5.73. An outline planning application for 750 dwellings was granted in September 2017 (15/04503/OUT). A full application for two gypsy and traveller pitches on the site (18/00873/FUL) was submitted in May 2018 with an application for Phase 1- 93 units (18/02513/RES) submitted in August 2018 and amended plans submitted in July 2019.

5.74. There is clear evidence that housing completions will take place on the site within 5 years and there are no foreseen site specific constraints to delivery. Through the site monitoring consultation Linden Homes has stated that the site remains deliverable. It anticipates completions to start in 2020/21 with 70 completions in the first year, followed by 120 completions per year for the following 5 years and 80 in the final year (2026/27). These rates anticipate that two outlets will be delivering on site and are based on their predicted start on site subject to planning and Section 278 site access. A statement of intent is due to be agreed to reflect the above position, in line with the council’s adopted Housing Action Plan (CD 8.14).

5.75. In comparison to the rate proposed by the developer, the predicted rates have been pushed back a year by the council in the housing land supply schedule, and extended over a longer period. This is considered to be a more robust basis for land supply purposes, and reflect general patterns of development and the need to deliver the site access from the A30.

5.76. The appellant accepts the delivery of 93 units on the site within the 5 year period, reflecting the current full application for this number of units. They therefore accept that the site is deliverable. Linden Homes have provided clear evidence that the site will be

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 26 built out in phases and that full applications will be submitted in a phased manner to support their predicted rate of delivery. There is therefore clear evidence to support the delivery of 290 units within the 5 year period and the submission of multiple full applications at this time would not be expected.

Park Farm, Oakley

5.77. The Appellant accepts the councils stated 48 expected completions within the 5 years. There is no disagreement on this site.

Cranes Road,

5.78. This greenfield site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site has been allocated for ‘approximately 12-18 dwellings’ in the Sherborne St John Neighbourhood Plan (adopted May 2017) and is being actively progressed by Rydon Homes.

5.79. The site is being actively progressed by Rydon Homes. An outline application for 18 units (16/04110/OUT) was approved in June 2018 and conditions on the outline are being discharged.

5.80. Although no recent response has yet been received from Rydon Homes through the site monitoring consultation at the time of writing, a reserved matters application for 18 dwellings was received by the council in July 2019 and is in the process of being validated.

5.81. Rydon Homes has previously stated through site monitoring, that the site is deliverable in all respects and that they anticipate 9 completions in 2021/22 and 9 in 2022/23. The relatively small site is therefore being actively progressed by the developer and there is clear evidence that housing completions will be delivered on the site within 5 years. No constraints to delivery have been identified and the developer's previously proposed rates for delivery have been used for land supply purposes.

Land off Evingar Road, Whitchurch

5.82. This site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 27 The site is allocated for approximately 60 dwellings and a business development area in the Whitchurch Neighbourhood Plan (Policy HA2) which was made in July 2017.

5.83. A hybrid application was submitted in September 2016 for a mixed use development with 60 dwelling units on site combined with B1 and B2 use. This was granted in June 2018 (16/03220/OUT). The developer for the site (Foreman Homes) has responded through the site monitoring process, indicating that the site remains deliverable. It anticipates the reserved matters application will be submitted before the end of 2019 and for construction to commence on site in summer 2020 with first completions in 2020/21.

5.84. There is clear evidence that housing completions will take place on the site within 5 years.

North of Popley/Merton Rise, Basingstoke

5.85. This site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site has detailed planning permission and is under construction. The site gained outline permission for 784 units (BDB73174) in 2012 and the landowners, Hampshire County Council (HCC), sold the site in October 2012. All of the site is within the ownership of Persimmon Homes (being built out as Persimmon and Charles Church brands).

5.86. Permission was gained for reserved matters on phases 3 and 5 in June 2013 and these phases are now complete (15 units completed in 2013/14, 118 in 2014/15 and 84 units in 2015/16). A reserved matters application for 122 units on Phase 4 (14/01913/RES) was approved in August 2015 and an application for phase 6 for 147 units (15/02040/RES) was approved in March 2016. Phase 4 is complete and phase 6 is due to be completed at the end of 2019. A reserved matters application for phase 2a (40 units) was approved in January 2017 (15/02040/RES). An application for Phase 2b (98 units) was approved in October 2018 (17/04139/RES) . 60 units were completed in 2016/17, 75 in 2017/18 and 103 in 2018/19 leading to 455 completions overall.

5.87. The predicted completion rates reflect starts on site (61 starts at April 2019) and also the information provided by the developer (building in sales and completion rates) through the site monitoring consultation. Persimmon has confirmed that the site remains deliverable and ground works have commenced for both Phases 2A and 2B. From

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 28 Phase 2A 40 units are expected to complete in 2019/20 with 40 units also anticipated from 2B and a further 58 from 2B in 2020/21.

5.88. The remaining dwellings on Phase 2C (148 dwellings) are yet to be consented, but will be brought forward in line with the phased approach to the site. Persimmon have stated that Phase 2C will deliver 20 units in 2019/20, 50 in 2020/21, 50 in 2021/22 and 28 in 2022/23. The predicted completion rates are based on Persimmon's response, past delivery rates, starts on site etc and are considered reasonable for the purposes of land supply. There are no foreseen site specific constraints to delivery .

Police Station, London Road, Basingstoke

5.89. This site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years. The site is a SHELAA site (ref. BAS012) which lies within the built up area of Basingstoke, within the Settlement Policy Boundary in an area of predominantly residential development in close proximity to the town. The principle of development in this location is established under current planning policies.

5.90. The current use of the site as a police station has ceased and a new police facility has been constructed elsewhere in the town (). This relocation is part of the wider review of sites. The site is therefore now available for redevelopment and has been marketed as such.

5.91. A planning application for 55 retirement apartments (19/00436/FUL) was submitted in February 2019 on behalf of Churchill Retirement Living. The application was refused permission in June 2019 (7 reasons for refusal were given). A revised application for 56 units was submitted on 16th July 2019.

5.92. My review of the previous refusal leads me to conclude that there is good potential for a revised scheme to overcome the reasons for refusal. It is too soon to say if the revised scheme that has been submitted will achieve this. Nevertheless, the site remains available for residential redevelopment and there is clear evidence that the site is being actively taken forward for delivery within the 5 year period. As such, I consider it appropriate that the site has been moved into the 5 year supply by the Council. It is not known whether the yield of the site may increase from the 30 units previously assessed by the Council, however the 30 has been retained in the land supply schedule for robustness. Any increase would be picked up in future monitoring.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 29 Field adjoining the White Hart, Reading Road

5.93. The site meets the deliverability tests as set out in the NPPF in that the site is available for housing now, it offers a suitable location for development now, is achievable and there is a realistic prospect that development will be delivered on the site within 5 years.

5.94. This is a greenfield site on the edge of Sherfield on Loddon village which was considered and promoted by the developer through the Sherfield On Loddon Neighbourhood Plan, made in March 2018. Whilst the site was not allocated within the Plan itself, the neighbourhood planning process led to an application being submitted for the site to meet the requirements of Local Plan Policy SS5. A full application for 15 units (17/03849/FUL) received a resolution to grant consent in June 2018.

5.95. There is a developer associated with the site, Mill Lane Estates. Details associated with the S106 are currently being considered and outstanding issues have been narrowed to the clause relating to affordable housing delivery which is being actively addressed by the council. There is clear evidence that the site is being actively taken forward and that housing completions will be delivered on the site in the suggested timescales.

Copenhagen Court

5.96. The site meets the deliverability tests as set out in the NPPF. The site gained prior approval for 38 units in June 2017 (17/00135/GPDOFF). A further application to extend the building for 20 units (17/02933/FUL) was refused planning permission in December 2017.

5.97. The site was removed from the supply in the 2018 schedule as there was no clear evidence at that time regarding the site’s delivery. However, the site is now under construction and, through the site monitoring consultation, the owners (Equity Real Estate) have confirmed that the site is deliverable and anticipate that all 38 units will be completed in 2019/20. The site has therefore been moved back into the 5 year supply in light of the clear evidence of delivery.

5.98. The Council has adopted a slightly more conservative approach than suggested by the owners for land supply purposes in light of there being a risk of some limited delay as a result of the process of decanting tenants. However, there are no other identified constraints to delivery within a 5 year timescale.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 30 Innovation Court

5.99. The site meets the deliverability tests as set out in the NPPF. A prior notification was approved for the conversion of the building to residential use (16/00031/GPDOFF) in March 2016 for 35 flats. The lease expired in autumn 2016 and the site was sold. In August 2018 an additional Prior Approval for 46 units gained approval (18/01504/GDPOFF).

5.100. The site was removed from the supply in the 2018 schedule as there was no clear evidence at that time regarding the site’s delivery. However, the site is now under construction and the owner, Equity Real Estate Developments, have confirmed that the larger 46 unit scheme is being progressed and that completions are predicted for 2019/20.

5.101. There is clear evidence that progress is being made towards development on the site with permission now in place to deliver homes in line with predicted timescales. There are no viability, ownership or infrastructure constraints to delivery and this scheme is under construction. The site is therefore included for completions by 2020/21.

3. The inclusion of a small sites windfall allowance of 100 dwellings

5.102. The Appellant notes that the Council has included a small-site windfall allowance of 100 dwellings within the 5 years supply. The Appellant argues that the Council has failed to provide compelling evidence for its inclusion, as required by para 70 of the NPPF and para 03-24 of the PPG.

5.103. The Council maintains that its previous and ongoing monitoring demonstrates a continuing supply from small site windfalls, at a significant rate which justifies the inclusion of a windfall allowance within its 5 year land supply. The allowance is set at a relatively conservative 50 dwellings per annum in years 4 and 5, lower than the rate at which such windfall sites have been and are continuing to come through the development management process.

5.104. The Local Plan Inspector tested through the examination the use of a windfall allowance for small sites (net gain of less than 10 units) of 100 units over the five year period. From analysis undertaken on historic rates of delivery to inform the Borough’s Strategic Housing Land Availability Assessment (SHLAA), it was considered that there was clear evidence that small sites consistently become available in the local area, often through redevelopment schemes within the borough’s built up areas or from the reuse of

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 31 buildings in the rural areas. Small windfall sites are an important source of housing supply and the principle of including a small site windfall allowance is justified. This approach was supported by the Local Plan Inspector, noting in para 92 of his Report (CD 7.03) that “This reflects the fact that such sites have consistently become available in the Borough and no evidence was presented to the Examination to shed doubt on this source of housing coming forward over the next 5 years”.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 32 6 CONCLUSIONS, INCLUDING THE RELEVANCE OF THE HOUSING LAND SUPPLY POSITION TO THE PLANNING BALANCE

Conclusion on housing land supply

6.1. I conclude that at the current time the Council can demonstrate a 4.6 year housing land supply, as summarised in the table below.

Total Requirement (2011 to 2029) – (850 dpa x18 15,300 years)

Completions (2011/12 – 2018/19) 5,005

Shortfall (2011/12-2018/19) 1,795 [6800 (850x8) – 5,005]

Requirement (2019/20 – 2023/24) 4,250 [850x5]

Requirement plus proportionate amount of shortfall 5,148 [4,250+898] (1,795/10x5) – Liverpool method

Requirement Plus 20% 6,178 [5,148 + 1,030]

Revised Annual Requirement (2019/20 – 2023/24) 1,236 [6,178 ÷ 5]

5 year Supply 5,686 Years Supply 4.6 Years [5,686 ÷ 1,236]

Relevance of the housing land supply position to the planning balance

6.2. As set out in the evidence of Katherine Fitzherbert-Green it is the council’s case that para. 11(d)(ii) of the NPPF does not apply, and therefore the tilted balance is not engaged.

6.3. However, even if the council’s case is not accepted, and the Inspector considers that the tilted-balance was engaged, that does not mean that determinative weight cannot still be afforded to the development plan policies. The Suffolk Coastal Supreme Court (CD 10.03) judgment confirms that where the tilted-balance is engaged, the weight to be afforded to development plan policies which have a ‘restricting’ impact on the supply of housing is a matter for the decision maker [66] and [83].

6.4. The Supreme Court’s judgment differs from that of the Appeal Court in Suffolk Coastal (CD 10.03). However, nothing in the Supreme Court’s decision questions Lord Justice

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 33 Lindblom’s judgment, at [47] where he identified that the following factors may be highly relevant to the attribution of weight to be afforded to development plan policies in the tilted balance exercise:

• The extent of the shortfall;

• The action being taken to address it (how long any deficit is likely to persist and the prospect of development coming forward to make it up); and

• The particular purpose of the constraint policy (and whether it is consistent with the NPPF – see NPPF Paragraph 213).

6.5. I consider that the extent of the shortfall, on the council’s stated figures, is limited albeit that the fact that the council cannot currently identify a five year housing land supply is a significant factor in the determination of the appeal.

6.6. I consider that the shortfall will be likely to be short-lived, and that as explained in the preceding sections, on the basis of the completion figures for 2018-19, the council is expected to be identified as a “5%” rather than a “20%” authority when the next Housing Delivery Test results are published. This is expected to mean that a 5 year housing land supply will be capable of being demonstrated.

6.7. I consider that the council is taking significant steps to seek to address the shortfall, including the determination of appropriate applications for residential development, which have led to high levels of planning permissions, the active promotion of the proposed Manydown strategic development, and the council’s close working with applicants and developers as a result of its preparation of the Housing Delivery Test Action Plan to identify and tackle potential barriers to the delivery of individual sites, where the council can assist with overcoming these.

Andy Blaxland Proof of Evidence APP/H1705/W/19/3226286 34