Simon Marsh, Head of Nature Protection explains the options available to solving Portsmouth City Council’s housing situation which don’t involve concreting over its natural assets.

A recent proposal to build 3,500 homes and a marine hub in Portsmouth Harbour dramatically brings to life an age-old question: how to plan for people’s housing needs and protect the natural environment at the same time. In this particular case, the draft Portsmouth Local Plan allocates a strategic housing and employment site at Tipner West, a peninsula jutting out into Portsmouth Harbour. The proposal involves land reclamation and would lead to the direct loss of over 35 hectares of protected inter-tidal and other coastal habitats, as well as the loss of locally-designated feeding areas for brent geese.

 In recent years most housing proposals the RSPB has been involved in have been because of concern about the indirect impacts on protected sites, usually from recreational disturbance. It’s rare that we see such an egregious case of proposed loss of internationally protected habitat. I’m glad to say that after a campaign by the RSPB and the Hampshire and Isle of Wight Wildlife Trust, Portsmouth councillors have voted to ‘pause and rethink’ Tipner West. You can read about this on HIWWT’s blog.

The decision to allocate the site has seemingly been driven by Portsmouth’s need to deliver a certain number of homes under the Government’s standard methodology for calculating local housing need, which provoked an exchange of letters between the leader of the council and former Secretary of State Robert Jenrick.

Portsmouth City is densely populated, and mostly on an island surrounded by protected wetland habitat. Green spaces within the city perform a vital role in giving people access to nature and open space. Options for development are limited. In an earlier part of my career, I worked as a planner for a local authority which was similarly surrounded by protected land where options for development were limited. It wasn’t such an extreme case as Portsmouth, but I’ve long had an interest in this area of planning.

Gone astray

It seems to me that Portsmouth has gone astray in at least two area. Firstly, by confusing local housing need with the local plan housing target.

Understanding the scale of local housing need is a crucial part of any local planning process. Many factors influence it such as projections of household growth and affordability, to name only two. The Government’s standard methodology is an attempt to do two things: to provide an officially-recognised way of calculating housing need that avoids costly arguments when local plans are examined, but also (here’s the controversial bit) to encourage ambitious housing provision that when added up across the country will meet national needs.  The Government got into hot water recently with its own backbenchers by changing its methodology, but that doesn’t affect Portsmouth.

However, national policy makes clear that ‘exceptional circumstances’ might ‘justify an alternative approach which also reflects current and future demographic trends and market signals’ (NPPF para 61). It doesn’t say what exceptional circumstances might be, but this is one option that Portsmouth could follow and justify at the local plan examination.

 Let’s assume, though, that Portsmouth has done that and still finds itself with a housing need that can’t easily be accommodated. Jenrick’s letter is worth quoting here:

“I would emphasise that the standard method is only the starting point for local authorities in identifying the housing need in an area. Local housing need does not set a target for the number of homes to be built. Local planning authorities take into account land supply considerations and environmental constraints before determining the number of homes likely to be delivered in the area. This recognises that not everywhere will be able to meet their housing need in full.”

This brings me to the second area where Portsmouth has gone astray, in not fully recognising environmental constraints when designating Tipner West as a strategic housing site. I might add that it is a risky strategy to rely so heavily on a single site to deliver housing needs (24% of total housing delivery), especially when there is uncertainty that it can even be legally delivered. I say this because the intertidal habitats are rightly protected under the Habitats Regulations and the local planning authority would have to demonstrate that there is ultimately no alternative to building houses there – and since it is not absolutely necessary for housing to be next to the harbour, that would be very difficult if not impossible.

So, if the standard method (or any other method) is only the starting point, what can Portsmouth do?

Three options

 Assuming Portsmouth has already done everything it can to identify housing sites elsewhere, I suggest it has three options. They are not mutually exclusive and the solution is probably a combination of all of them.

  1. Under the exceptional circumstance policy, justify a lower housing need and likewise a lower housing target through the local plan.
  2. Consider increasing housing densities within the existing built-up area. This is a more controversial move and I am not advocating tower blocks, nor do I want to see urban greenspaces built over. However, it is possible to adopt ‘gentle densification’ (for example, by building flats above shops) and still build to a high standard of design. There are already policies in the draft local plan which encourage this, but it is worth considering whether more could be done.
  3. Neighbouring local authorities have a legal duty to cooperate with each other and some of Portsmouth’s housing need should be ‘exported’ by agreement. There is an established Partnership for South Hampshire local authorities which is well-placed to do this, but the failure to agree this so far (the local plan only includes a potential contribution of 1,000 homes) threatens to undermine the soundness of the local plan.

Fundamentally, though, the local planning authority needs to start by putting the environment first and working out how many new homes can be delivered within ecological limits. Portsmouth Harbour and the adjacent waters should be celebrated as environmental assets which the City is proud to protect, not concreted over.
Keep updated on the joint RSPB and Hampshire & Isle of Wight Wildlife Trust Tipner West #DontGoThere campaign:


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