To:
Cllr Angela Glass
Portfolio Holder for Regulation & Enforcement
East Hampshire District Council
councillor.aglass@easthants.gov.uk
Cc:
Planning Policy Team – planningpolicy@easthants.gov.uk
Simon Jenkins – Director of Regeneration and Place
Rt Hon Damian Hinds MP – damian.hinds.mp@parliament.uk
From:
[Resident’s name withheld]
[Address redacted]
[Email removed for privacy]
Date: 22/05/2025
Dear Councillor Glass,
I write to you in your capacity as Portfolio Holder for Regulation & Enforcement to formally request that EHDC adopt an immediate Planning Position Statement (PPS) to suspend further approvals of speculative housing developments in Medstead and Four Marks, until a functioning system for:
- Cumulative application tracking, and
- Quantified, consultee-linked infrastructure evaluation
is introduced and made operational.
📌 Context and Planning Harm
Medstead and Four Marks have already absorbed a disproportionate volume of growth relative to infrastructure capacity. However, EHDC continues to:
- Apply the tilted balance without evaluating cumulative harm;
- Consult statutory bodies with no formal data aggregation or numeric context;
- Issue EIA screening opinions without referencing adjacent or phased development; and
- Publish only consultee responses, not the queries or briefing data sent to them.
As a result, consultee responses may be based on incomplete information, and approvals are being made without a lawful or transparent assessment of risk—particularly in areas such as road safety, school access, flood resilience, and GP capacity.
⚖️ Policy and Legal Basis for a PPS
A Planning Position Statement is an appropriate and well-established tool that can be used to:
- Signal a pause while evidence and tracking systems are corrected;
- Provide guidance to applicants;
- Protect EHDC from reputational, legal, and appeal-based risk.
Under NPPF Paragraphs 11(d), 39 and 55, and Regulation 4(2) of the EIA Regulations 2017, EHDC is required to ensure that decisions are:
- Informed by cumulative impacts;
- Based on transparent consultee data;
- And proportionate to local infrastructure reality.
The Supreme Court in Hopkins Homes v Secretary of State for Communities and Local Government [2017] UKSC 37 confirmed that while applying the tilted balance involves planning judgment, that judgment must be rational and based on a proper evidential foundation. Where the Council lacks any system to track cumulative approvals, consultees are not provided with aggregate data, and EIA screening fails to reflect phased or adjacent development, the tilted balance risks being applied in a procedurally flawed and legally vulnerable manner.
✅ Requested Actions
We respectfully request that EHDC:
- Issue a Planning Position Statement stating that:
- New speculative applications in Medstead and Four Marks will be deferred,
- Until EHDC can demonstrate that cumulative impacts have been tracked and evaluated.
- Engage statutory consultees to implement numeric, cumulative-aware response protocols.
- Report publicly what permissions exist, what infrastructure burdens they imply, and what cumulative screening methodology will be used going forward.
This PPS would reinforce public confidence in the planning system and ensure the tilted balance is not misapplied through administrative fragmentation. It would also help shield the Council from legal challenge and future appeals.
I look forward to your response and to EHDC taking urgent steps to address these failures in planning process and governance.
Yours sincerely,
[Name redacted for publication]