Plan making - facts, fiction and frequently asked questions

There are many challenges to preparing a new Local Plan. The Government has made many policy changes along the way that have presented difficulties – particularly the significant increase in the housing number. In addition, on 25 March 2026, the Government announced its decision for the future of Local Government in Hampshire and the Solent. That decision splits East Hampshire into two separate unitary authorities; Mid Hampshire and South East Hampshire.  

That itself presents significant risks and challenges to the Local Plan process. There are also other significant challenges, such as proposed changes to national policy (December 2025) that could undermine efforts to tackle the climate emergency and potential restrictions on water supply for new housing in northern parts of East Hampshire, which could undermine efforts to provide a five-year supply of housing land.  

The council wanted to carry on with preparing the East Hampshire Local Plan. A lot of time and resource has been devoted to it – not just by the council, but by the residents who have responded to consultations, developers who have promoted sites, and Neighbourhood Plan groups who have worked alongside this process. Even with Local Government Re-organisation on the horizon, the council tried to remain committed to this process.  

The council did not support the breaking up of authorities to create the new unitary authorities, nor was it expected. With all the other factors to consider following the roll out of a new plan-making system by the Government, this significantly increases the overall risk and challenges for adoption of a Local Plan using the existing or ‘legacy’ planning system.  

The main risk is that we spend lots more money on an East Hampshire Local Plan, and it may not get adopted, or even if it does, part of it is ineffective as a lot of the content may be undermined by the Government’s new planning policy (expected this summer). 

We are facing significant challenges on many fronts, including constraints to development that are complex, such as infrastructure pressures including water supply and transport. We have fed back to Government that our unique position regarding transport modelling places East Hampshire at a huge disadvantage on timescales, cost and complexity. Equally, there is potentially an emerging water constraint that requires assessment at a strategic level, with no immediate resolution. This issue could make it extremely difficult for the Local Plan to demonstrate five years housing land supply, or require such a stepped trajectory that is impossible to deliver.  

The draft National Planning Policy Framework says, “Development plan policies which are in any way inconsistent with the national decision‑making policies in this Framework should be given very limited weight, except where they have been examined and adopted against this Framework”. A local plan for East Hampshire that is adopted under the ‘legacy’ planning system would not have been examined and adopted against the new Framework. This introduces a clear risk, if the draft NPPF is adopted in this form, that policies prepared for the emerging Local Plan, including positively framed local policies, could attract limited weight prior to, or even following, submission. 

The combination of factors heightens the risk of not being able to adopt the plan before vesting day for the new unitary authorities, and even if it were, the benefits of the plan could be immediately undermined on adoption.  

This means planning officers are no longer working on preparing a new Local Plan for East Hampshire under the ‘legacy’ planning system, but instead will be engaging with the new planning system and at the same time preparing for the future wider geography of unitary authorities.  

The legacy system covers plans to be adopted under the Planning and Compulsory Purchase Act 2004 (excluding the amendments made by the Levelling-up and Regeneration Act 2023), and The Town and Country Planning (Local Planning) (England) Regulations 2012. Local Plans being examined under the legacy system will be examined against the 2024 National Planning Policy Framework.  

To benefit from the transitional arrangements that allow plans to be adopted under the legacy system, Local Plans must be submitted by the end of December 2026. After this time, plans would need to be prepared under the new planning system.  

On 27 November 2025 a written ministerial statement was made about reforming local plan making. On 4 March 2026, a package of regulations to implement the new system was published and are now in force from 25 March 2026.  The new systems is a streamlined, map-based and rules-led system, designed to produce simpler, more accessible Local Plans more quickly, with clearer development rules and greater use of standardised data and digital tools. 

We have always said East Hampshire is unique in the challenges it faces – primarily around the presence of the South Downs National Park and the way that splits our district into three separate areas that we plan for

• Our planning areas (jpg 3.3 mb)

It is also unique in the specific technical challenges it faces with regards to preparing the transport evidence to support the Local Plan. Planning authorities generally rely on one model, for East Hampshire – it is two models (doubling the cost and complexity), and one of those models doesn’t fully cover our area.  As such, we cannot be easily compared to other areas. However, it is quite possible that authorities will do similar before the end of the year.  

The SDNPA is a separate planning authority and makes its own decisions.  Development proposals in the SDNP are at a much smaller scale, due to the national park status and its constraint to development. As such, the increase in housing number has not had the same direct impact on the plan making process and evidence needed as it has for East Hampshire outside of the SDNP.  The SDNPA intends to submit its Local Plan for examination before the end of the year under the legacy planning system and adopt it in 2027.  

No. Four formal consultations were carried out, with preparation of a draft Local Plan in 2024 that tried to balance the protection of the environment with the need for development. There is also a considerable evidence base supporting the Local Plan, and extensive information known about sites. We will now use this information to make sure that key information about East Hampshire is recognised, shared and built on during this transition period. We will also make sure that the evidence collated to date informs decision making on planning applications where appropriate. For example, up to date information about infrastructure such as open space, sports facilities and community facilities can be used in relation to new planning applications.

The council recognises that there remains a possibility of speculative development continuing, particularly while planning policy is in transition. Whilst an up-to-date Local Plan is always beneficial in terms of discouraging speculative development, it is not an absolute defence.   

The Government made a manifesto commitment to delivering 1.5million new homes over this parliament, and despite saying it is committed to plan making, very large increases to the ‘top-down’ estimates of local housing needs have meant that it is increasingly difficult for the council to achieve a five-year supply of housing land even with an up-to-date local plan .   

The council will fully utilise evidence and resources to seek the best possible outcomes, within the remit of national planning policy set by Government.  

The change to producing a local plan in accordance with the new plan-making system does not have any immediate impacts on the housing land supply situation in the planning area. 

The council will update the Five Year Housing Land Supply later in the year, using the latest monitoring data from Hampshire County Council (2025-2026). The council does not know at this time whether it will or will not be able to demonstrate a five-year housing land supply when the position statement is updated, however, the high housing number makes this challenging.  

Paragraph 78 of the NPPF requires local authorities to “identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing.” The Planning Practice Guidance states that the five-year supply is measured “against a housing requirement set out in adopted strategic policies, or against a local housing need figure, using the standard method, as appropriate”. When the plan is more than five years old, the strategic policies, including housing requirement become out of date and the adopted requirement can no longer be relied on; the Standard Method then becomes the basis for calculating the five-year supply. The Standard Method outcomes for East Hampshire will therefore continue to be used when assessing housing land supply in the planning area 

This change in direction for plan making does not directly impact on decision making, which continues. Decisions on planning applications are made on a case-by-case basis, taking account of all relevant material considerations including the planning policies of the adopted development plan. With regard to an emerging local plan, the stage of plan making has always been a material consideration, and will continue to be so. 

The policies of emerging local plans are typically of limited weight until any outstanding objections have been resolved through the latter stages of a plan-making process, at an examination in public. 

As such, it is a consideration that the emerging East Hampshire local plan is not progressing on the timescales envisaged, but as it had not reached the stage of an examination in public and (in relation to housing applications) with the absence of a five year housing land supply, this is not expected to materially change outcomes in the short to medium term.  

Unmet housing needs must be considered when plan making. As plan making continues for individual authorities, unmet needs remain and will continue to be considered when preparing new-style local plans. However, unmet needs from outside of East Hampshire do not affect housing land supply calculations in our planning area and do not affect the presumption in favour of sustainable development for decision-taking on planning applications.   

The same concerns remain – the impact of speculative development, the pressures on infrastructure and the environment, and the need for affordable homes.  A lot of the work done to date will now be used to inform planning decisions and the new plan making process.  

The council is also looking carefully at future work (such as Supplementary Plans and guidance notes) that may assist with managing development before a full, new-style local plan has been prepared.  

The Government has intervened in the Local Plan process in other areas. The risk of intervention remains, but the Government would have to deal with the same challenges the council is facing. The council retains its continued commitment to plan making by engaging with the new planning system. Whilst the council cannot demonstrate a five year supply of housing, it has approved housing applications where appropriate taking account of the tilted balance. As such, the council is not an authority persistently refusing applications for new homes and would strongly make this case if intervention were threatened. 

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Neighbourhood Plans are part of the Development Plan, and will continue to be so.  

Neighbourhood Plans currently in the process of being drafted or reviewed can continue as normal. Neighbourhood Plans would need to be in general conformity with the Joint Core Strategy.  

Neighbourhood Plans that wish to allocate housing sites can do so. For those seeking to allocate sites for housing to meet an identified local housing need—particularly where this is necessary to satisfy paragraph 14 of the NPPF—reference should be made to the council’s Indicative Housing Numbers for Parishes document. This document provides indicative housing figures for each parish, based on existing housing stock and using the standard method. It represents the most up‑to‑date information available and should be used as the starting point for any Neighbourhood Plan group intending to allocate housing. 

Any Neighbourhood Plan group wishing to discuss this further is invited to contact localplan@easthants.gov.uk  

Delivery of infrastructure to support new development remains a priority. One of the main purposes of progressing a Local Plan under the legacy system was to ensure there was an Infrastructure Plan to identify the infrastructure needed to support the planned development. As we engage with the new planning system and look to prepare for plan making across wider geographical areas, continued work on infrastructure will be important, particularly in relation to water supply.  

The council still has a considerable infrastructure evidence base to inform planning decision making, such as the Community Buildings Assessment (2026) and forthcoming Open Space Strategy. A full list of evidence base is available.  

In addition, there are many key infrastructure projects identified, with many already receiving funding from development (CIL, S106), such as extensions to health facilities, dentists and community facilities.  

There is potentially an emerging water supply constraint which requires further strategic assessment and does not currently have a confirmed solution. 

Discussions with Natural England, the Environment Agency and neighbouring local planning authorities highlight ongoing uncertainty about the availability of water resources, particularly within the South East Water WRZ4–W supply area. Until further clarity is provided, a precautionary approach is required. 

This means that applicants will need to demonstrate that proposed development can be supported by a sufficient and reliable water supply, without causing harm to the integrity of designated sites such as Special Protection Areas (SPAs) and Special Areas of Conservation (SACs). Where this cannot be clearly demonstrated, further information may be needed before a decision can be made. 

At present, there is no confirmed strategic solution to resolve the identified supply issues, and the infrastructure needed to address this is not expected to be delivered in the short term.  

Tackling the climate emergency remains a core priority for the council. The council’s Climate Change and Sustainable Construction Supplementary Planning Document will remain in force until a new-style local plan is adopted for the planning area. This Supplementary Planning Document provides detailed guidance in relation to adopted local plan policies and additional ‘best practice’ considerations that help new developments become more climate resilient.  

The council will seek to work with partners for the future unitary authorities and across Hampshire to understand how future planning policies can be aligned to best tackle the climate emergency across local authority boundaries. Unfortunately, the extent to which local planning policies can help to mitigate carbon emissions could be reduced by the Government’s proposals to amend national planning policies in ways that limit our ability to set strict limits on emissions from new development. 

Protecting East Hampshire’s environment remains a core priority for the council. A significant amount of environmental evidence has already been prepared through the Local Plan process, including assessments of biodiversity, protected habitats, flood risk, landscape, heritage assets, green infrastructure and climate impacts. This evidence has not been lost and will continue to inform planning decisions and future plan‑making across the new unitary geographies. 

The council still has a legal duty to protect designated and valued sites, including European protected habitats, nationally important landscapes, heritage assets and local green spaces. Requirements such as Habitats Regulations Assessment, nutrient neutrality, biodiversity net gain and flood risk management continue to apply to planning applications, regardless of changes to the Local Plan timetable. 

In particular, established mitigation and enhancement mechanisms will continue to operate, including: 

• Nutrient Neutrality, ensuring that development does not add to existing nutrient pollution in sensitive catchments. EHDC applies Natural England’s current methodology and has published local guidance for applicants, setting out when a nutrient budget is and what information must be submitted.  EHDC continues to work closely with the Solent Mitigation Partnership and neighbouring authorities to help establish and support suitable long-term mitigation schemes.   

   

• Biodiversity Net Gain (BNG), requiring development to deliver measurable improvements to biodiversity.  EHDC has set out its local approach in a BNG position statement. 

• Strategic Access Management and Monitoring (SAMM), which mitigates the recreational impacts of new development on protected heathland habitats such as the Wealden Heaths Phase I and II SPAs.  EHDC are working on a strategic package of access, management, monitoring and engagement measures, typically funded through developer contributions, that will help manage visitor pressure arising from new housing and once established will be adopted. 

Work undertaken to date will be used to: 

• inform decisions on planning applications where relevant and up to date; 
• support the protection of sensitive environments, including internationally protected habitats and local wildlife sites; and 
• shape the future planning framework for the new authorities, ensuring local environmental constraints and opportunities are understood from the outset. 

While the absence of an adopted new Local Plan creates challenges, national planning policy still provides important safeguards for the environment. The council will continue to resist inappropriate development, work with statutory bodies such as Natural England and the Environment Agency, and use the existing evidence base, including mechanisms such as BNG, nutrient neutrality and SAMM, to balance the need for development with protecting what makes East Hampshire special. 

An updated Housing and Economic Development Needs Assessment (HEDNA) 2026 has been published – which is key evidence that identifies the type of housing needed. It informs planning decisions about housing mix and size of housing.   

The Affordable Housing SPD is also an important planning document, which carries material weight in the decision-making process, and aims to guide developers when proposals include the requirement for affordable housing.  

Using these important tools when assessing development proposals will help with continuing to ensure the type of housing needed is proposed.  

The updated Housing and Economic Development Needs Assessment (HEDNA) 2026 has been published.  The HEDNA details the amount and type of employment development that will be needed within the district.  An updated Employment Land Review (ELR) is also soon to be published which will assess the district’s existing portfolio of employment sites, providing a summary of the current supply of business premises.  Both the HEDNA and ELR will inform decision making surrounding future employment-related planning applications, as well as aiding the work of the council’s Economic Development team  

Achieving economic growth and prosperity remains a central component to the vision of the Council’s Strategy 2024-28. The council will therefore continue to prioritise growth of the local economy and monitor the scope for intensification and expansion of existing businesses through its decision making, in accordance with NPPF. 

Supporting existing businesses, enabling sustainable growth across employment sectors, and increasing job density will remain key areas of focus. 

Achieving good standards of design in new development is an important requirement of both national and local planning policies. Existing local policies and guidance will remain in force until a new-style local plan is adopted for the planning area.  

There is potential to specify additional design requirements or advice through a Supplementary Plan or guidance note, if this would assist with managing development. Emerging neighbourhood plans could also bring forward suitable policies and guidance. 

The council will continue to carefully assess the proposed design and layout of new development through the planning application process, to better ensure that the characteristics of well-designed places are achieved, and that new buildings and open spaces respond to the local contexts of East Hampshire.