📉 4. No national investment strategy to match housing delivery
Even though local councils are told to deliver more homes, there’s no automatic funding for schools, GPs, roads, or public transport.
So you get:
Homes approved without sufficient infrastructure
Communities growing faster than services
Backlash and resistance
📍 Summary Table
National Control
Exists?
Notes
National Spatial Strategy
❌ No
England is the only UK nation without one
Housing Need Formula
✅ Yes
Standard Method sets minimums per district
Binding Housing Targets
❌ No
Targets aren’t enforced unless in Local Plan
Infrastructure Funding
❌ No
No automatic match to population growth
Land Use Redistribution
❌ No
No plan to rebalance growth across the country
🧠 Final Thought
There is national control over the numbers, but not over the consequences or coordination. That’s why districts like EHDC are under pressure from targets they didn’t shape — without the tools or funding to deliver them properly.
The Annual Monitoring Report (AMR) is a document that each local planning authority — including East Hampshire District Council (EHDC) — must publish at least once per year. Its purpose is to track the council’s performance in delivering planning objectives and housing targets.
Think of it as EHDC’s “planning report card”, offering transparency about whether it is meeting the commitments set out in its Local Plan.
The Annual Monitoring Report (AMR) is a yearly publication required by all local councils. It tracks housing delivery, Local Plan progress, and whether the council is meeting national planning targets. One of its most influential roles is confirming whether the council has a five-year housing land supply — a key measure used to determine how much control it retains over planning decisions.
In this article, we explain how the AMR works — and how windfall housing approvals (homes approved outside planned allocations) are sometimes used to improve headline figures. While this can help councils meet short-term targets, it can also mask deeper planning problems, such as overdevelopment in rural communities, underinvestment in infrastructure, or failure to deliver allocated sites.
🧾 What Does the AMR Include?
The AMR typically reports on:
📦 Progress on the Local Plan: Has the council delivered what it promised?
🏡 Housing completions: How many homes have been built each year?
📉 5-Year Housing Land Supply (5YHLS): Does the council have enough land to meet demand over the next five years?
🧮 Housing Delivery Test (HDT) performance
The Housing Delivery Test (HDT) is a national measure of how many homes a council has actually delivered, compared to how many it was expected to deliver over the past three years. If delivery falls below key thresholds (e.g. 85%, 75%), it can trigger penalties such as action plans or tilted balance.
🏘️ Affordable housing delivery
🧭 Windfall trends and development outside planned allocations
🌿 Environmental and infrastructure indicators
📆 Whether the Local Plan still meets national policy requirements or needs updating
🗓️ When Does EHDC Publish the AMR?
EHDC typically publishes its AMR between May and July each year, covering the previous financial year (e.g. 1 April 2023 to 31 March 2024).
The most recent version as of early 2025 is the 2022/23 AMR, released in summer 2023.
📌 What Is the Legal Duty?
Under Regulation 34 of the Town and Country Planning (Local Planning) (England) Regulations 2012, councils must:
Publish a monitoring report at least annually,
Make it publicly available, and
Keep it relevant to Local Plan performance.
⚠️ Why It Matters
The AMR helps determine whether EHDC has maintained a 5YHLS and met its housing targets.
If shortfalls are revealed, the tilted balance is triggered, weakening local control over speculative development.
The Housing Delivery Test (HDT) uses AMR figures to assess whether local planning authorities are delivering enough homes. Failing the HDT can:
Trigger an action plan,
Require an early Local Plan review, or
Engage the presumption in favour of development (tilted balance).
🚨 Pressure to “Patch the Numbers” Before the AMR Cut-off
Because AMRs rely on data captured as of 31 March each year, there is a risk that councils under pressure to meet housing targets might approve borderline or windfall applications in Q1 (Jan–Mar) to artificially boost completions before publication.
This creates a risk that:
Windfall approvals are rushed or strategic rather than properly assessed.
Councils may cut corners on cumulative impact, environmental risk, or consultation.
Settlements like Medstead — which already absorbed disproportionate growth — may be further burdened to “make up the numbers.”
🧾 Windfall allowances hide structural failure
NPPF Paragraph 71 allows councils to count windfall sites in their housing supply — but without any spatial limit.
👉 Result:
Councils can use windfalls to fill the numbers,
Even if growth is unplanned, disconnected from infrastructure, and overloads specific settlements (like Medstead).
This makes it look like delivery is working, while masking the failure to deliver plan-led, equitable growth
🚨 When the AMR Becomes a Trigger to Cut Corners
Although the AMR is designed to promote transparency, it can also create perverse incentives when councils are under pressure to meet housing delivery targets. Because each AMR captures housing data up to 31 March, local authorities may feel compelled to approve marginal or windfall developments in the final months of the year — even in unsustainable locations — simply to boost their numbers before publication.
In reality, this pressure can begin well before the AMR deadline. If internal tracking or draft housing completions reports indicate that delivery may fall short, councils like EHDC may accelerate approvals in Q3 or earlier, particularly for windfall or tilted balance schemes that can be counted toward annual totals.
This is especially risky when:
The council anticipates failing the Housing Delivery Test (HDT),
The Five-Year Housing Land Supply (5YHLS) position is already weak,
Or the tilted balance has been triggered and used to justify approvals.
🎙️ In the LPC meeting on 20 March 2025, EHDC’s Development Manager confirmed that the 2016 Ashwoods (Medstead) development was approved during a period when the council lacked a five-year housing land supply and was relying on an Interim Housing Position Statement. It was a windfall development, not part of a planned allocation.
📉 Every year, EHDC must report on housing delivery. When it appears that targets may fall short, windfall approvals can play a role in closing the gap. While this helps meet district-wide numbers, it also risks obscuring underlying planning weaknesses — with communities like Medstead absorbing the real-world impacts of unplanned growth.
In such moments, settlements like Medstead — which have already absorbed high levels of growth — may be exposed to rushed or speculative approvals without cumulative safeguards, long-term infrastructure planning, or meaningful local scrutiny. The AMR, intended as a tool for accountability, can unintentionally incentivise short-termism and overdevelopment, particularly in rural communities that lack formal delivery caps.
The Council’s Leadership Cabinet, which is responsible for setting and resourcing strategic priorities.
The Planning Policy Team, for managing the process (though often under resourcing constraints).
Full Council, if they failed to adopt or fund a timely review when warned.
⚖️ Why Accountability Matters?
Loss of Local Control
Increased Risk to Infrastructure and Communities Without an up-to-date plan, housing growth may happen in places without the necessary roads, schools, or GP capacity — and the council cannot effectively coordinate delivery.
Legal and Financial Exposure
An outdated plan may increase the risk of:
Planning decisions being overturned at appeal.
Costly Judicial Reviews.
Loss of control over CIL/S106 infrastructure negotiation.
Impact on Public Trust
Residents may lose confidence in the council’s ability to manage development fairly and transparently — especially when speculative schemes are approved without strong local backing.
Use the latest household growth projections for your area (East Hampshire). These projections come from the Office for National Statistics (ONS), which estimates how many new households will form in each local authority area over time.
Look at the average annual household growth over a 10-year period.
🧾 Example (as of April 2025): ONS projects East Hampshire will grow by 3,678 households over 10 years → that’s 368 new households per year (baseline).
✅ Step 2: Apply the Affordability Uplift
If housing in the district is expensive compared to local earnings, the required housing number is increased.
🔍 What is the Affordability Benchmark?
The government uses a benchmark affordability ratio of 4.0, which assumes that housing is reasonably affordable if the median house price is no more than four times the median annual earnings in the area.
If the local affordability ratio is above 4.0, an uplift must be applied to the housing need to reflect increased demand caused by unaffordable housing.
💡 How the Uplift Works
For every 1.0 point above the benchmark of 4.0, the baseline housing need is increased by 0.25 (25%). This formula is set by the government in its Planning Practice Guidance (PPG).
🔎 What’s the Logic Behind the Benchmark of 4.0?
The 4.0 affordability ratio is a policy judgment: it reflects the idea that housing becomes unaffordable when it costs more than four times the average local salary.
Historically, house prices around 3–4× income were considered manageable by mortgage lenders.
The government uses 4.0 as a threshold where no uplift is applied — it’s the point where housing is just about affordable without overstretching buyers.
⚖️ If house prices are below 4× average income, housing is considered affordable enough, and no additional housing pressure needs to be factored into the council’s housing target.
📈 Why Apply a 25% Uplift per Point Above 4.0?
The uplift rate of 0.25 (25%) per point over 4.0 is meant to scale proportionally with housing stress.
For every 1.0 increase in the affordability ratio, the assumption is:
Demand exceeds supply
Additional homes are needed to cool price pressure
✅ Example: If the ratio is 5.0 (just one point over), the government assumes a 25% uplift is enough to help restore balance between supply and demand over time.
If it’s 13.0 (as in East Hampshire), the uplift becomes over 225% — because prices are so far detached from wages, the area needs a lot more housing just to stabilize affordability.
This method is intentionally simple and scalable. It avoids overcomplicated modelling and gives each council a clear formula based on just two data points.
✅ Example A: Affordable Area
If the affordability ratio is 4.0 or below, no uplift is applied.
✅ Example B: Unaffordable Area
If the affordability ratio is 13.03, as in East Hampshire:
Affordability ratio
13.03
Affordability benchmark
4
Above the benchmark of 4
(13.03-4) = 9.03
Adjustment Factor = 25 % of the excess over the benchmark
(0.25 * 9.03) = 2.2575
Baseline – Total projected new households (2024–2034)
3,678
Baseline – Annual average growth
3,678 ÷ 10 = 368 households/year
Affordability Adjustment (uplift)
+83 households per year
Total Annual Housing Need
368 + 83 = 451 households/year
✅ Step 3: Cap It (In Some Cases)
If the Local Plan is up-to-date (reviewed within 5 years and aligned with national policy), the number can be capped to avoid sharp increases.
⚠️ As of 2024, EHDC’s Local Plan is out of date, so no cap applies.
✅ Step 4: Use It for the 5-Year Supply
The final number becomes EHDC’s annual housing requirement.
To remain compliant, EHDC must show enough land for 5 years of housing need.
💡 If need = 560 homes/year → EHDC must show land for 2,800 homes over 5 years.
📌 Where This Is Written
National Planning Policy Framework (NPPF) – Paragraphs 61–62
Planning Practice Guidance (PPG): Housing and Economic Needs Assessment
Annual housing need for East Hampshire District Council (EHDC) using the Standard Method as of April 2025
📍 Data Sources:
Data Source: ONS 2018-based household projections.
Affordability Data: Latest median house price to income ratio.
🧾 Key Definitions (Glossary)
ONS (Office for National Statistics) – UK government agency responsible for population and economic data.
Affordability Ratio – Ratio of median house price to median local earnings; used to assess how affordable housing is.
Standard Method – The formula councils must use to calculate annual housing need.
Local Plan – The council’s official planning document setting out what can be built and where.
5-Year Housing Land Supply – A requirement for councils to show they have enough land available to meet 5 years of housing need.
Council publishes the plan it wants to adopt. You can now object on legal and soundness grounds (e.g. not justified, not effective, not compliant with NPPF).
🔹 Critical stage: your last chance to influence what gets adopted.
An independent Planning Inspector holds a public examination to test if the plan is “sound” and “legally compliant”. You may be invited to a hearing if you objected at Reg 19.
🔹 Required by law. Inspector checks legality and compliance with national policy.
📝 2. Regulation 18 – Draft Plan & Early Consultation
What’s happening? This is the first formal public consultation. The council publishes a draft version of the plan or “issues and options” — they might offer different scenarios or layouts and ask the public what they think.
📜 What does “Regulation 18” mean? It’s the legal requirement that the council must consult “any person or organisation it thinks will be affected.” This gives the public a first formal voice in the process.
🟢 You can:
Respond with general views on where homes, roads, and green spaces should go.
Highlight local evidence: flooding, schools, transport, nature, etc.
📣 3. Regulation 19 – Final Plan & Legal Objections
What’s happening? The council publishes the plan it wants to adopt — the Pre-Submission Plan. This is not a “what do you think” stage — this is a “tell us what’s wrong” stage.
📜 What does “Regulation 19” mean? The council must publish the final version for a minimum of 6 weeks and allow the public to raise formal legal or policy-based objections. These go straight to the Planning Inspector.
🔴 You must:
Say if you believe the plan is unsound (not justified, not effective, or conflicts with national policy),
Or not legally compliant (e.g. flawed consultation, missing evidence, or no proper Sustainability Appraisal).
🛠️ This is the last chance to get changes made before it becomes law.
What’s happening? The Planning Inspector tests the plan’s legality and “soundness”. There are public hearings — but they are technical, not like public debates.
🎯 They check:
Is the plan positively prepared?
Is it based on evidence?
Can it actually be delivered?
Does it comply with national policy (like the NPPF)?
📚 The Inspector may also suggest “main modifications” — required changes before it can be approved.
What’s happening? The council votes to formally adopt the plan. Once adopted, the plan becomes the law — developers must follow it, and so must the council (unless national policy overrides it).
After adoption, anyone can launch a Judicial Review if they believe the plan is legally flawed (e.g. flawed process, failed consultation, unlawful policies).
🧑⚖️ Challenges go to the High Court, and only succeed if a clear legal error is proven.
There are no legal, financial, or procedural barriers preventing East Hampshire District Council (EHDC) from implementing a stronger Environmental Impact Assessment (EIA) screening policy — none. The full cost of EIA preparation falls entirely on developers, not the council. National policy (NPPF) not only allows but encourages local authorities to tailor EIA thresholds and requirements to reflect their area’s specific environmental and infrastructure pressures. EHDC holds full legal discretion to do so. The only missing ingredient is political will: a genuine, resident-focused leadership that chooses to act. Strengthening EIA screening is a no-brainer — it costs EHDC nothing and delivers enormous public benefit. Any refusal to pursue this reform cannot be justified on planning grounds; it can only be seen as an abdication of responsibility.
Environmental Impact Assessment (EIA) isn’t just a bureaucratic box-ticking exercise — it’s a critical safeguard, designed to protect local communities, public services, and the environment from developments that might cause serious harm. And like any serious risk management process, it unfolds in structured steps.
To make it easy to understand, imagine the planning system as a healthcare system. Just as doctors don’t rush into surgery without checking a patient’s history, local councils shouldn’t approve large-scale developments without understanding their real-world impact — especially when multiple schemes may combine to produce cumulative harm.
🏥 The EIA Process – Explained Through a Health Analogy
Stage
Planning Term / Actor
What It Does
Medical Analogy
Who Pays / Decides?
0
National Planning Policy Framework (NPPF)
Sets the national rules for how and when EIA should be applied. Councils are encouraged to interpret and strengthen this based on local needs.
Like NHS clinical guidelines — national standards, but applied by local doctors.
National policy – EHDC decides how it’s implemented locally
1
EHDC (Local Planning Authority)
Determines if EIA is needed, what it must include, and whether cumulative risks should be examined. Has full legal discretion to require stronger screening.
Like your GP and local hospital board — deciding how best to apply the rules to protect patients.
EHDC decides — developer pays for all assessment, not the council
2
EIA Screening
Decides whether a full EIA is required. Must include a check for cumulative impact with other approved or planned developments.
Like triage — do current symptoms or known risk factors (including past conditions) justify tests?
Developer (small admin fee)
3
EIA Scoping
If an EIA is needed, scoping defines what topics must be studied and how deeply — including any combined/cumulative risks.
Like a doctor deciding whether to test the heart, lungs, liver — and whether existing health problems must be factored in.
Developer
4
EIA (Full Environmental Impact Assessment)
The developer commissions expert reports, surveys, and models on traffic, flooding, biodiversity, health services, etc. Findings go into an Environmental Statement.
Like a full medical workup before major surgery — detailed and evidence-based.
Developer
5
EIA Findings & Mitigation
The results shape planning conditions, developer contributions (e.g. roads, GPs, biodiversity offsetting), or project redesign. May include long-term monitoring.
Like a treatment plan — surgery allowed, but with follow-up, rehab, or medication.
Developer (via conditions, Section 106, etc.)
🧱 Why Cumulative Impact Is So Critical — and So Often Ignored
Here’s where many councils, including EHDC, fall short: they treat each development in isolation, ignoring the fact that multiple smaller schemes can combine to cause major damage. That’s the essence of cumulative impact — and it’s already a required part of both the Screening and Scoping stages under national planning guidance.
It’s like assuming a single prescription is harmless — without checking whether the patient is already taking five others. One scheme might not overload a road or surgery, but five new estates across a village cluster absolutely can.
EHDC has both the legal right and the moral duty to insist on proper cumulative impact assessment — especially in overdeveloped areas like Four Marks, Medstead, Alton, and Whitehill. Yet time and again, it fails to use its powers.
🧾 Final Word
EIA, when done properly, is a vital planning tool. It’s not about blocking development — it’s about making sure growth happens responsibly, with the real-world effects understood, mitigated, and monitored.
Developers pay for the entire process
The NPPF allows and expects councils to strengthen safeguards locally
EHDC has complete discretion to apply these checks based on local needs
The only thing missing is the will to use the powers already available
The standard method is a government-set formula used to estimate how many new homes a local authority needs to plan for each year.
It was introduced to provide consistency and transparency in how housing need is calculated across England, and is the default approach unless a council can justify using an alternative (e.g. through an up-to-date Local Plan that’s been examined and accepted).
⚙️ How does it work?
The standard method is a two-step calculation based on:
Household growth projections – These are official statistics (from ONS) that estimate how many new households are expected to form in each area over time.
Affordability adjustment – This increases the housing need figure in areas where house prices are high compared to incomes (i.e. less affordable areas must plan for more housing). – The formula uses the median house price-to-earnings ratio to adjust the total.
📌 For example: If a council area has a high affordability ratio — say, homes cost 12 times the average income — the housing need figure will be increased significantly to reflect that more homes are needed to address the imbalance.
🧮 Formula (simplified):
Minimum Annual Housing Need = ➡️ Baseline household growth + ➡️ Uplift based on local affordability
🛑 Can a council use a different method?
Only in specific cases — such as during a Local Plan review that’s:
Fully updated and subject to public consultation and examination
Using locally-specific evidence (e.g. infrastructure capacity, environmental constraints)
Approved by a Planning Inspector
But in the absence of a recent, examined Local Plan, the standard method applies automatically — and forms the basis of the 5-Year Housing Land Supply test.
On 24 March 2025, a formal request was submitted to Medstead Parish Council asking it to act as the Claimant in a Judicial Review (JR) of the recent planning permission granted for the Beechlands Road development.
Importantly, Medstead Parish Council formally objected to this application, and two of its councillors spoke against it at the East Hampshire District Council (EHDC) planning meeting. As many residents who were present in person — or who later watched the proceedings via EHDC’s video link — will confirm, the decision to approve the application was met with shock and disbelief. The recording of the meeting remains available to view on EHDC’s website for six months following the meeting.
The request identifies multiple serious concerns that may render the decision legally challengeable. These include:
Failure to consult the public on the true scope of development in South Medstead
Improper reliance on outdated precedent
Procedural and legal errors
Lack of environmental oversight
The Parish Council has confirmed that the matter will be discussed at its next full council meeting on 9 April 2025.
📣 If wish to share relevant information or concerns, please contact Mrs Julie Russell, Clerk to Medstead Parish Council, at clerk@medsteadpc.org.
💬 You are also warmly invited to join the discussion on our community platform: 👉 https://www.beechlands-rd-community.online/forum/forum/52/ Simply start a new topic or comment under the threads already there. Regardless of how obvious something might seem, please don’t hesitate to share it — important points are often overlooked. We’re aiming for an open and practical exchange of information
Why This Is, in Our Opinion, the Right Course of Action
The following are substantiated and evidenced grounds that collectively justify a Judicial Review of the Beechlands Road approval. Each point highlights a potential breach of planning law, policy, or due process:
⚖️1. Illegality – Failure to Apply EIA Law to Cumulative Development
⚖️ 2. Procedural Impropriety – Failure to Disclose Strategic Intent and Monitor Impact
⚖️ 3. Procedural Impropriety – Fragmentation of Impact Assessment
⚖️ 4. Illegality and Irrationality – Tilted Balance Applied Without Baseline Evidence
⚖️ 5. Failure to Give Lawful and Adequate Reasons
⚖️ Was the EIA screening decision in 2013 (60 dwellings) lawful?
✅ Legally it was a Schedule 2 development (Category 10(b))
The site was:
3.3 ha, with a 2 ha developable area
Not in a sensitive area (as per 2011 Regs at the time)
Exceeded the 0.5 ha threshold → Screening was mandatory
👉 EHDC did carry out a screening opinion — ✅ this part is procedurally lawful
🔎 Did EHDC properly consider environmental effects?
They did consult statutory bodies:
Environment Agency
HCC Highways
Natural England
Thames Water
Environmental Health
📌 Several consultees noted risks:
Flooding potential and drainage (EA + EHDC drainage)
Noise, air quality (Environmental Health)
Highways concern about cumulative impact (HCC Highways)
Medstead PC specifically objected due to cumulative development pressure and loss of open space/woodland
But…
⚠️ Critical Weakness in the Screening Decision: Cumulative Impact Was Dismissed
EHDC acknowledges that:
“The village has experienced rapid development pressures in the preceding short-term of 5–10 years but not on a scale likely to cause significant social issues…”
And:
“A full TA will be required… but crucially for the purposes of the 2011 Regulations only committed developments can be considered in screening.”
👉 This is the legal weak point:
❌ EHDC’s interpretation of “committed development” was narrow and conservative
They dismissed wider growth because the other SHLAA sites weren’t yet consented
They ignored local-scale saturation, even though HCC Highways and the Parish Council both warned about cumulative pressure
💣 Conclusion: Was the 2013 screening opinion lawful?
Procedurally: Yes — screening was carried out, consultees were asked.
Substantively: ⚠️ Weak, potentially vulnerable to challenge today:
Because EHDC relied too heavily on the absence of “committed” status for nearby schemes, rather than assessing the real risk of cumulative impact
They did not apply Schedule 3 criteria dynamically, as later clarified in case law like Loader v Rother DC [2015]
Presumption in Favour of Sustainable Development: According to the National Planning Policy Framework (NPPF), there is a presumption in favour of sustainable development. This means that planning permission should be granted unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits when assessed against the policies in the NPPF as a whole.
Lack of Five-Year Housing Land Supply: If a local authority cannot demonstrate a five-year supply of deliverable housing sites, the policies in the Local Development Plan that are most relevant to housing supply are considered out-of-date. In such cases, the presumption in favour of sustainable development is particularly relevant.
