EASTLEIGH BOROUGH LOCAL PLAN EXAMINATION
Ref ID/6: INSPECTOR’S POST HEARING NOTE 4 – RESPONSE TO COUNCIL’S
REQUEST FOR CLARIFICATION
Introduction
1.
This note responds to various questions of clarification sought by the Council in its note of 8 December. It is reasonable for the Council to seek clarification of any matters which are unclear in my Preliminary Conclusions and my response below seeks to address those points. However, there is a danger that such a detailed request for clarification reopens discussion of points on which I have already come to a conclusion. To do so would be inappropriate and unfair to other parties. Accordingly, my responses here are brief. It was not necessary for me to respond to every point made at the hearing or in written representations, whether by the Council or other parties and my Preliminary Conclusions did not seek to do so. Those conclusions are sufficiently detailed and comprehensive and accordingly, where I am satisfied that my conclusions are clear, I see no need to address further the points previously made by the Council which I found unpersuasive. The points below should not be interpreted or applied in isolation.
The points do not change my overall conclusions and those overall conclusions still need to be read and applied as a whole.
Housing Market Area
2.
The PUSH SHMA’s identification of 615 dpa is a reasonable demographic starting point because that is what it identifies as applicable to Eastleigh Borough. In order to progress this Plan there needs to be some assumption as to what is a reasonable starting point at Borough level. Other than the JGC Study (which my
Preliminary Conclusions also take into account), no other up to date basis for identifying a starting point for the Borough is included in the Council’s evidence base. As I note in my Preliminary Conclusions (paragraph 8): If the Council consider that the Borough-based assessments are fundamentally inadequate then it would have to withdraw this Plan and undertake what further work it considered
necessary.
3.
I am content to accept a range of 2,019-2,045 dpa as an appropriate demographic starting point for the Southampton HMA (with an emphasis on a figure toward the upper range) in the context of my Examination of the Eastleigh
Borough Local Plan. Clearly, evidence in Examinations of other Plans may challenge the SHMA on this matter.
Affordable housing needs
4.
The PUSH SHMA’s figures of 615 dpa overall and 509 dpa for affordable housing are seeking to highlight different matters, which need to be considered separately. However, part of the affordable housing need is the need arising from newly forming households and that is derived, in part, through an element of demographic modelling (see PUSH SHMA 8.37). Thus I would not want say that the numerical agreement or otherwise is largely coincidental as put in the
Council’s question; simply that they are different matters.

Private rented sector
5.
The Council asks whether people currently occupying privately rented properties, but supported by local housing allowances are “inappropriately housed” and need to be rehoused. That was not directly addressed in the hearings. I have concluded on the role of the private rented sector (PRS) and affordable housing needs in the light primarily of the discussion at the hearing which was framed by the exploration of the matter in the PUSHM SHMA. Households in receipt of local housing allowances are clearly households whose needs are not met by the
market and thus would qualify for affordable housing in accordance with the definition used in the Framework in housing needs. This is also the approach taken in the PUSH SHMA in assessing needs. I see no need to elaborate further.
6.
My conclusion that the PRS with local housing allowances should not be regarded as the provision of affordable housing complaint with the Framework very much flows from the thorough discussion we had of the matter at the hearing and my conclusions are as stated. Whilst based on the evidence (particularly in the PUSH
SHMA) and argument at the hearing, it is not primarily based on factors which are necessarily unique to Eastleigh. But it is not for me to speculate on whether my conclusions might have more general applicability. I do not know whether a similar conclusion has been made in other Examinations, but I am satisfied that my conclusion is clear and robust, based on the evidence and arguments put to me.
7.
Notwithstanding the above, the Council should also not loose sight of the fact that the projected provision of affordable housing in Eastleigh Borough falls well short of the PUSH SHMA’s figure of 310 affordable dwellings per annum identified in that study for Eastleigh, where the role of the PRS with local housing allowance was assumed to be meeting part of the need (Preliminary Conclusions paragraph
32).
Market Signals
8.
The uplift required by market signals is over and above (or rather distinct from) the adjustment made in the SHMA to account for the past suppression of household formation. Although one of my pre-hearing questions explored whether they should be treated as the same, I am persuaded that they are distinct, separate adjustments to consider.
9.
I was not persuaded by the Council’s arguments that the attractive qualities and character of Eastleigh explain market signals such that no uplift is required. My reasons for the uplift are as stated in my Preliminary Conclusions.
Housing Land Supply - Garden Land
10.
I believe that the Council accepted that garden land should not come within the definition of windfalls because it would involve a different definition to that used in national policy (Framework, paragraph 48), which would simply be too confusing. I did not mean to imply at the hearing that it would be acceptable (ie justified) for the Council to include in its housing supply a new category for
unidentified small sites on garden land, simply that it would have to invent such a category if the Council wanted to try and include it. It had not done so.

However, the justification would not just be in terms of numbers of dwellings that might come forward, but whether any such category should exist at all. It would be for the Council to argue the matter (in due course) if it wished to pursue it, but given that the Framework so specifically excludes garden land from windfalls it seems a difficult point to justify.
Simon Emerson
Inspector
9 December 2014