A Housing Delivery Action Plan that’s short on actions

This may sound like a dry subject but read on, it’s actually rather important and will drive the way your town and its surrounding area evolves. (As always, click the underlined links to find out more. Internal links and videos will open on this same page, external links and documents will normally open in a separate browser tab.)

New (sustainable?) house construction currently in progress on the former Colt site in Havant

With the same sledgehammer wisdom demonstrated last year by the now infamous ‘mutant algorithm’, central government uses another mechanism called the Housing Delivery Test (HDT) to hold local authorities accountable for the delivery of sufficient quantity of new homes within their area.

The HDT is embedded within planning policy via the National Planning Policy Framework (NPPF). If delivery of completed housing has fallen below 95% of the Local Authority’s housing requirement over the previous three years, the test requires that the authority produces an action plan which assesses the causes of the shortfall and identifies actions to increase delivery in future years. This Housing Delivery Action Plan (HDAP) must then be updated every year until the council achieves the 95 per cent target.

In common with many other local authorities Havant has now fallen into this trap and so on Wednesday 13 January, Cllr. Hughes, Deputy Leader of HBC and Cabinet Lead for Planning, introduced his draft Housing Delivery Action Plan to an Extraordinary Cabinet meeting.

To view the 16 page document in another browser tab, take this link. To listen to Cllr. Hughes introduce the subject at the Cabinet meeting, play the following brief video.

Cllr. Pike had clearly done his homework by reading the draft action plan and had submitted a deputation to the Cabinet in response. In summary, he finds that the actions in the plan need to be clearer and tougher if the Council are to restore their housing delivery completion targets with the minimum of delay.

Listen to Cllr. Pike’s deputation by playing the following clip.

Cllr. Pike’s first point was not lost on us, rounding on the Cabinet for not making the draft plan available for proper scrutiny before presenting it for approval. In other words, another disquieting example of the lack of transparency evidenced elsewhere.

Having made the ‘lack of scrutiny’ point, Cllr. Pike went on to make three useful further points.

  1. The council needs to accelerate the plans for their own sites [at the Civic Plaza] which were identified in the Regeneration Strategy. These sites would contribute significantly to the target and should be clearly identified in the Housing Delivery Action Plan. He points out that the inclusion of these sites is particularly important given that there are other sites included in the five year supply numbers that are unlikely to come to fruition in the forseeable future – for example Long Copse Lane.
  2. The Cabinet needs to ‘beef up’ section 4.8 of the report and work much more closely with developers to clear the log jams in the system. These often involve the ‘statutory consultees’ on topics such as Trees, Infrastructure, Birds, Water and Roads.
  3. Cllr. Pike recommended that ‘heads be knocked together’ to get work started on the major delivery site at Southleigh. This site alone will contribute significantly to the five year housing supply.

(Although it is not an early release site in the Local Plan to 2037, this large green field site to the north of the A27 in Denvilles will eventually include up to 2,100 new homes. Large development sites such as this would generally deliver 50 or 60 homes completions each year.)

In summing up, Cllr. Pike reminded the Cabinet that housing delivery should be the highest priority for both the Borough Council and its residents and the action plan must reflect that with clearly stated actions, target dates and metrics in place to measure achievement.

Following Cllr. Pike’s deputation, Cllr. Wilson’s request for comments from the members was interrupted by Cllr. Hughes’ plea to be allowed to address the point about ‘lack of scrutiny’. Less than two minutes later, it almost seems as if the responsibility for slow housing development has been diverted to the hapless Regeneration Programme (admittedly an easy target).

Cllr. Wilson then opened up the meeting for general questions from the Cabinet members, starting with Cllr. Thain-Smith who surely had her tongue firmly in her cheek for questioning whether ‘we want to be an action led council’?

Listen to it next:

The Cabinet then moved on to debate the action plan and it soon becomes apparent that with the exception of Cllr. Bains, Cllr. Pike’s deputation has fallen on deaf ears.

Cllr. Bains started the debate off with undue modesty and not a hint of sarcasm by observing that the words ‘Housing Delivery Action Plan’ suggested to her that the document should actually include an action plan that needs deliverable outcomes. In doing so, she echoed not just the comments made in Cllr. Pike’s deputation but also the majority view from those of us listening to the meeting. Cllr. Bains went on to reinforce the point that one of the obvious barriers to building is delivery of associated infrastructure change, citing the ‘15 minute neighbourhood‘ concept and highlighting the fact that many of the sites under consideration lack the infrastructure that would make people want to live there.

Cllr. Bains reinforced the point first made by Cllr. Pike that with 1632 families on the housing waiting list, it is imperative that the council take stronger and more effective action by strengthening this document. Putting it bluntly, the Housing Delivery Action Plan doesn’t go far enough, the same message that we heard earlier.

Sadly, at this point the debate fizzles out and first the Deputy Leader and then the Leader of the Council seem to have lost the plot. Cllr. Wilson at one point appears to infer that since the ‘evolving’ plan will run to 2037 by which time everything will have changed, then there’s little point in spending too much time on it until next year. Cllr. Rennie’s contribution to the debate suggested that he’s been listening to far too many Downing Street coronovirus briefings. If only they’d stuck to a constructive and effective criticism of the document before them.

Listen to the debate by playing the next video clip.

With no further contributions and the content of the document unchanged, Cllr. Wilson moved for a vote on the motion proposed by his deputy, ‘Alpha, Bravo’ Charlie. In the absence of any other response to his request for a seconder, he stepped up to the task himself and the vote followed its predictable course. Another wasted opportunity.

So what do we think?

We are disappointed that there was no response whatsoever to the valid questions raised on the overwhelming need for ‘affordable housing’. For the 1,632 families currently on the Havant Borough Council waiting list, this remains a fundamental and serious issue.

We would like to see more officer time allocated to ‘implementation’ once a planning application has been granted, with funding for that role allocated to cover officer time. With more active oversight of approved applications, the issues we’ve seen in the past with lack of delivery on town centre sites such as the Wessex site in New Lane and the various sites in East Street and West Street, might be averted. We are painfully aware of such sites which, despite planning consent, have in the past been left derelict, with buildings part demolished and the sites standing empty for a decade, blighting our town centre.

As far as the numbers go, the target for housing completions has increased considerably over the last few years from 313 in 2011 to 504 for 2020-2021. You may recall from the widespread rebellion against increased targets last year, that the housing demand algorithm would have bumped that figure up to 962 for 2021-2022. In other words, the goalposts are constantly shifting.

While the housing delivery target keeps moving, the external influences on delivery in the past year have simply been impossible to contain. In the first place, the Nitrate Neutrality issue put a significant block on the building out of all but pure greenfield sites. The Warblington Farm nitrate mitigation scheme should now lift some of that block, but the ongoing impact on house building from both Covid-19 and Brexit will remain significant for months if not years.

None of these factors were within the control of the Council, and collectively they provide ample grounds for pushing back on central government dictates. Scanning the internet today for Housing Delivery Action Plans from other local authorities, we see that ‘Lobbying Central Government’ is a common theme among their proposed actions.

You would surely think that a Conservative majority Council in a parliamentary constituency with a safe Conservative seat ought to be able to successfully lobby a Conservative majority government in the face of such overwhelming impacts.


HCS would like to thank members of the Havant Borough Residents Alliance (HBRA) for their contributions to this post.

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