Why EHDC’s Housing Target Must Be Capped at 500 per Year

PHAEDRA PONTSIVO

East Hampshire District Council (EHDC) is expected to deliver 1,147 dwellings per annum (dpa)1 under the Standard Method.

Based on the Government’s national housing ambition of 370,000 homes per year, the national per capita delivery rate is approximately 6.55 homes per 1,000 people. EHDC, by contrast, is being asked to deliver 9.12 homes per 1,000 people—a 39% higher burden than the national average.

This outcome contradicts the Government’s stated policy objective that housing targets should reflect a fair share of national growth2.

A revised target of no more than 500 dwellings per year would restore EHDC’s contribution to a fair, proportionate, and policy-aligned level, consistent with its historic overdelivery (8.7% population growth vs. 6.6% nationally between 2011 and 2021), its limited infrastructure capacity, and its small population share (<0.23% of England’s total).

Applying the Standard Method mechanically in EHDC produces a demographically and spatially disproportionate outcome that fails to meet the tests of:

  • Justification and proportionality,
  • Environmental realism and legal alternatives testing, and
  • Sustainable development.

While the Standard Method uses housing stock as its initial baseline, the underlying principle is distributional fairness. In areas like EHDC—where historic population growth has already exceeded national averages, and where environmental and infrastructure constraints are significant—even the national per capita average of 823 dwellings/year represents an upper limit, not a minimum. A cap of 500 dwellings/year, grounded in actual local demand, historic absorption, and delivery capacity, offers a more sustainable and legally justified outcome.

1. EHDC Has Already Grown Faster Than Most of England

Population Growth Outpaced National Average

Between 2011 and 2021, East Hampshire District Council (EHDC) experienced a population increase of +8.7%, growing from approximately 115,600 to 125,700 residents3. This rate exceeded the national growth rate for England, which was only +6.6% over the same period (from 53,012,456 to 56,489,800 people4).

If EHDC’s population had followed the national trend (6.6%), the 2021 population would have been just 123,230. Instead, the actual population exceeded this by 2,470 residents, indicating that EHDC absorbed significantly more growth than would have been proportionate.

Housing Provision Has Kept Pace – Even Outpaced Demand

In 2011, EHDC had roughly 49,000 dwellings. Assuming:

  • A 3% vacancy rate, and
  • An average occupancy multiplier of 2.35 persons per dwelling (commonly used in NHS service planning),

…the existing stock housed approximately:

|(49,000 × 0.975) × 2.35 = 111,696 people

This suggests that, at the 2011 baseline, EHDC was already close to housing its population, with a shortfall of around 3,905 people — equivalent to 166 dwellings per annum (dpa) over 10 years [(111,696 – 115,600) ÷ 2.35 ÷ 10].

By 2021, the housing stock had increased to about 55,000 dwellings, providing capacity for:

|(55,000 × 0.976) × 2.35 = 125,373 people

This comfortably exceeds the population level that would have occurred with national-level growth (123,230 people), providing surplus housing for an additional 2,143 people — equal to 91 excess dwellings per year beyond what was needed locally.

The Wrong Narrative: From Overdelivery to Penalisation

This data makes one thing clear: EHDC did not underdeliver on housing. It delivered more than was locally required, absorbing external displacement from high-pressure areas like London. This migration-driven growth was not a reflection of unmet local need, but of systemic imbalances in national housing pressures and speculative development approvals in areas lacking adequate infrastructure.

Despite this, EHDC is now being penalised with continued high housing targets, justified using population figures that reflect external demand, not local necessity. This is a distortion of policy intent.

A Direct Contradiction of the NPPF

The National Planning Policy Framework (NPPF) promotes sustainable development, defined as development that is:

  • Plan-led
  • Infrastructure-aligned, and
  • Responsive to local needs and circumstances

Using EHDC’s inflated growth — the product of systemic failure and market displacement — to justify even higher targets directly contradicts this principle. It creates a feedback loop where overdelivery leads not to relief, but to further expectations, punishing responsible delivery and undermining local planning autonomy.

Conclusion: EHDC Is Overburdened, Not Underperforming

EHDC’s housing record reflects overperformance in the face of national housing pressure, not local underprovision. The district should not be used as a buffer for failures elsewhere. Instead of shifting the burden onto places like EHDC, national policy should:

  • Identify and address underperforming areas, and
  • Reinforce planning equity by ensuring growth is spatially balanced and locally justified.

2. Even Assuming Continued Growth, the Current Target is Disproportionate

  • If EHDC’s population were to grow by a further 8.7% between 2021 and 2031, its population would reach approximately 136,636—an increase of 10,936 people.
  • Assuming an average household size of 2.35 persons7 per dwelling, this implies demand for around 4,654 dwellings over 10 years, or just 466 homes per annum, 480 if we would like to allocate 3% for vacant dwellings.
  • This is less than 42% of the current Standard Method target of 1,147 dpa.

This illustrates that even under a repeat of high historic growth, the level of housing required on demographic grounds would remain far below the current target. The Standard Method housing figure cannot be justified on the basis of population growth trends alone.

The Standard Method appears disconnected from both historic and projected demand.

3. Official Projections for Context

According to the ONS 2021-based subnational population projections (published January 2024), East Hampshire’s population is projected to grow by just 4.2% between 2021 and 2031, reaching approximately 131,900 by 2031. This is significantly lower than the assumed 8.7% repeat-growth scenario used above for illustration, and would suggest a much lower housing need in line with demographic realism.

4. Infrastructure Cannot Absorb This Level of Growth

  • Local GPs, schools, roads, and sewage systems are already stretched.
  • EHDC includes areas within or near the South Downs National Park, where development is severely restricted.

The district is being used to absorb regional overspill from urban areas and constrained neighbours, without matched investment.

Summary8

While the 1,147 figure originates from the Standard Method prescribed by national guidance, the final housing requirement in the Local Plan is set locally — and must be tested against local environmental constraints, demographic evidence, infrastructure capacity, and the real-world operation of the housing market.

ScenarioAnnual Housing Figure (dpa)BasisComment
Standard Method (Current Target)1,147Prescribed national formula, with affordability upliftIgnores local delivery capacity, demographics, and infrastructure; proven ineffective locally
Population-Based Need (Historic)466–480Based on +8.7% growth from 2011–2021, using 2.35 persons per dwelling + 3% vacancyReflects actual local demographic trend
National Share-Based Cap823Based on EHDC’s population share (125,700) and national target of 370,000 homes/yearEnsures fair per capita contribution aligned with national goals
Proposed Cap (Recommended Target)500Rounded figure balancing demographic need, infrastructure limits, and legal sustainabilityLegally supportable, environmentally responsible, and proportionate

Crucially, East Hampshire District Council has no legal or regulatory control over who occupies new housing, how it is priced, or whether it serves local need. There are no mechanisms — such as those in financial markets — to prevent land banking, speculative build-out manipulation, or investment-driven housing acquisition.

In this context, applying the Standard Method’s affordability uplift — which assumes increased delivery will improve local affordability — is both unfounded and counterproductive. EHDC has already delivered significant levels of new housing over the past decade, yet affordability has worsened. This demonstrates that the uplifted figure is not functioning as intended in rural areas where demand is shaped by external displacement and market speculation, not unmet local need. Since affordability has worsened despite high delivery, raising targets further without price control mechanisms or local occupancy rules cannot be justified under the premise of improving affordability.

ONS data shows that East Hampshire’s median house price-to-earnings ratio increased from 10.27 in 2011 to 13.03 in 20239. This 27% rise in unaffordability occurred despite consistent housing delivery. It provides clear evidence that the Standard Method’s affordability uplift does not function as intended in rural, high-demand areas shaped by speculative and external forces. Using this uplift to inflate targets in EHDC — without corresponding policy tools to manage affordability — is therefore unjustified, and counterproductive.

Continuing to inflate housing targets based on this formula risks further displacement, overdevelopment of sensitive rural areas, and unsustainable pressure on already-stretched public infrastructure.

The proposed cap of 500 dwellings per annum (dpa) is not an arbitrary or invented figure. It is supported by three converging lines of objective evidence:

1. Demographic Demand

Based on EHDC’s own historic growth rate (+8.7% over the 2011–2021 decade), and assuming average household size (2.35 persons) with 3% vacancy, the resulting housing need equates to approximately 466–480 dwellings per year. This is a direct population-based calculation.

2. Fair National Share

Using the Government’s national housing ambition of 370,000 homes/year, and applying the national delivery rate of 6.55 homes per 1,000 people, East Hampshire’s population (125,700) implies a fair share of 823 dwellings per year. This illustrates that even under national expectations, the current target of 1,147 dpa is significantly inflated.

3. Infrastructure and Capacity Constraints

EHDC has no matched investment pipeline to scale GP services, road capacity, school places, or wastewater infrastructure to absorb 1,147 additional homes per year. Statutory consultees have highlighted these constraints repeatedly. Without

This is not about avoiding future growth — it is about recognising that EHDC’s past delivery has already absorbed external displacement, not unmet local need. Planning for further expansion without demographic justification risks deepening that imbalance.

A revised target of no more than 500 dwellings per year — grounded in historic delivery rates, demographic share, and infrastructure realism — represents a proportionate, sustainable, and legally supportable alternative. It must be formally tested under Regulation 12(2) of the SEA Regulations 2004 as a reasonable option during plan preparation and public examination.

Failing to do so would not only risk non-compliance with environmental law, but also perpetuate a national pattern of misallocated growth that penalises areas like East Hampshire for market failures beyond their control.

EHDC is not resisting growth — it is resisting disproportionality. A housing target of 500 dpa aligns with national legal principles, environmental limits, and the council’s responsibility to plan sustainably and locally.

Supplement 1:  If Growth Is Uncapped, So Must Be Our Spatial Responsibility

Population growth in the UK—and particularly in England—appears politically and structurally uncapped. In the absence of any deliberate ceiling, this demographic pressure is absorbed into the planning system by default. Yet that absorption is neither coordinated nor spatially just. It occurs unevenly, often falling hardest on the most fragile or overstretched localities. Without a national framework that ties population growth to sustainable, spatially intelligent development, we are locking in a model of urban failure.

The False Economy of Local Overload

The current model treats towns and villages as pressure valves rather than system components. Under this logic, growth lands wherever resistance is lowest: politically weak areas, undersupplied regions, or landscapes with ambiguous protections. This results in short-term delivery without long-term vision. Public services erode. Social fabric tears. Local identity vanishes under the weight of ad hoc densification. What appears as “housing need” is, in practice, a crisis of unmanaged pressure.

When Developers Extract Without Control

In high-demand regions, particularly in southern England, developers operate without meaningful checks on profit, quality, or legacy. This invites a parasitic form of urbanism:

  • Maximum unit yield, minimum design ambition.
  • Zero spatial resilience: no room for green corridors, public amenities, or public transport integration.
  • High profit extraction, low reinvestment.

Communities are treated as mines, not partners. Value is extracted, degraded, and then abandoned. Planning policy becomes a tool for private extraction, not public design.

Lost Generational Opportunities

Every poorly planned site represents a lost generation of opportunity. Once land is developed, it is rarely reclaimed. Poorly aligned road networks, undersized schools, and architecturally incoherent streetscapes become permanent scars. We lose the ability to create walkable neighbourhoods, coherent transit-oriented communities, and climate-adaptive housing zones.

A Missed Moment: From Pandemic to Parasitism

The COVID-19 pandemic disrupted conventional patterns of work and mobility. Remote work emerged as a powerful decentralising force—offering the potential to reshape national development around flexibility, regional equity, and renewed local economies. Yet this opportunity was entirely missed. Instead, the pandemic aftermath accelerated urban sprawl, with a wave of Londoners relocating to the South—still within commuting range—driven by the perception that one or two days in the office per week was manageable. This shift intensified pressure on the Southeast while undermining the potential to distribute housing, infrastructure investment, and economic growth more evenly across the UK.

Instead of incentivising remote-friendly infrastructure, rebalancing housing targets across the UK, or investing in digital connectivity and localised service resilience, the government reverted to business-as-usual. England, and particularly the southeast, continues to absorb the bulk of population pressure. Development is still dictated by land values, not spatial strategy.

There has been:

  • A key technical flaw in how affordability pressure is calculated. – Compounding this, the Standard Method relies on workplace-based earnings—capturing only what people earn within the district, not the higher incomes of those who live in East Hampshire but commute elsewhere. This depresses the earnings denominator and artificially inflates the affordability ratio. Crucially, it does so without accounting for the earnings of recent in-migrants—many of whom have relocated from higher-income areas and maintain well-paid, often remote or hybrid jobs. These newcomers increase demand and price pressure but are not captured in the earnings data used to determine affordability. As a result, the formula penalises the district as if its residents are poorer than they actually are, inflating housing targets on a false economic reading. Additionally, some companies—responding to pandemic conditions—relocated their headquarters to northern regions while allowing their staff to work remotely from places like East Hampshire. In these cases, high-income earners are living in the district but their earnings are counted as workplace income in another region. This misallocation not only fails to capture their economic impact locally, but may also artificially reduce the affordability ratio in the northern host region while further inflating it in East Hampshire—widening regional distortions in planning calculations.
  • Moreover, the population growth experienced in East Hampshire has consistently exceeded the national average—not because of natural demographic pressure, but because of inward migration from more expensive regions. The very people who can afford to live in East Hampshire are driving up prices and demand. Yet this selective influx is then used to justify further housing targets, as if it reflects an unmet local need rather than a speculative market dynamic. This circular logic embeds external demand as internal obligation, distorting the rationale for growth. – The actual affordability ratio used (13.21) is a median of several high values that include the COVID-era inflation. Because the Standard Method in its revised 2024 form no longer uses ONS-based demographic projections, but instead calculates need from a fixed baseline tied to existing housing stock, even modest spikes inflate the housing target significantly. The higher the affordability ratio, the more the formula adjusts the baseline upward—turning a temporary price surge into a permanent housing delivery obligation.
  • A public narrative that claims targets are now flexible and locally determined, yet in practice some authorities like East Hampshire have seen their housing targets more than double.

  • Recent reforms have allowed some central London boroughs to reduce their housing delivery expectations, citing density, infrastructure, or conservation constraints. Yet rather than confronting this shortfall with strategic design, the unmet need is simply exported outward — to districts like East Hampshire. In the absence of a national coordination mechanism, deregulation in the capital accelerates pressure on surrounding regions. This is not policy reform — it is demographic offloading, concealed in the language of local discretion.
  • No explanation for why a district with known infrastructure limits and landscape constraints is being asked to absorb exponential growth while other regions remain underdeveloped.
  • No attempt to create a national framework for spatial equity.
  • No incentive to distribute growth through post-industrial renewal or digital mobility.
  • No strategy to make the most of the UK’s full geographic footprint.

England, already under disproportionate stress, is treated as a demographic sponge. The system operates not by planning for health, but by managing symptoms — reacting to pressure rather than designing for well-being. It is almost as if overpopulation is allowed to spread like a disease, with the cure being containment rather than prevention. This approach treats demographic intensity as an inevitable burden to be absorbed, rather than a dynamic to be directed intelligently and equitably. But the failure is broader: planning discussions and reform debates rarely acknowledge Scotland, Wales, or Northern Ireland. The assumption that England is the sole container of growth reflects a profound lack of national vision.

Principles for Responsible, Resilient Growth

If population growth is to continue uncapped, then national and local governments must match that reality with structural reforms:

  1. Proactive Spatial Design
    Identify and prepare growth zones ahead of demand, with masterplans, democratic consent, and infrastructure funding in place.
  2. Developer Profit Constraints
    Introduce profit caps or public-gain ratios, tying developer returns to the delivery of green space, social housing, schools, and connectivity.
  3. Ecological and Infrastructure Thresholds
    Enforce hard limits based on local water capacity, biodiversity resilience, and service load-bearing.
  4. Public Land Strategy
    Expand public or community-led land ownership to direct growth toward civic benefit, not speculative turnover.
  5. National Population Absorption Strategy
    Distribute growth equitably across the country, based on spatial capacity, economic renewal needs, and infrastructure readiness.

Conclusion

Growth, unmanaged, is not prosperity. It is erosion. If we continue to permit developers to act without moral or regulatory guardrails, we will sacrifice the future of England’s built environment for short-term profit. We will lose not just green fields, but the very possibility of designing better communities. If growth is to remain uncapped, then so must be our ambition, our foresight, and our responsibility to design for permanence, dignity, and sustainability.

“Without design, growth becomes decay.”

  1. Disclaimer Regarding MHCLG Housing Target Methodology: For the purpose of this argument, the reduction in housing target from 1147 dwellings per annum (dpa) to 1119 dpa for East Hampshire District Council is deliberately set aside, as the difference is considered relatively negligible in the context of the broader policy concern. The response received from the Ministry of Housing, Communities & Local Government (MHCLG) refers exclusively to the methodology underpinning the 1147 dpa figure, without providing further clarification or justification for the uplift imposed on EHDC. At the time of writing, a follow-up response is anticipated, as a review of the MHCLG’s position remains ongoing. ↩︎
  2. Why is housing stock used as the baseline? “…share of the national total that is proportionate to the size of their current housing market.” ↩︎
  3. ONS | EHDC ↩︎
  4. ONS ↩︎
  5. To estimate actual housing capacity, we apply an adjustment for vacancy. The average national vacancy rate in England was 2.7% in 2021. This means only 97.3% of dwellings were occupied, so we use a 0.97 multiplier for accuracy. ↩︎
  6. To estimate actual housing capacity, we apply an adjustment for vacancy. The average national vacancy rate in England was 2.7% in 2021. This means only 97.3% of dwellings were occupied, so we use a 0.97 multiplier for accuracy. ↩︎
  7. NHS – persons per dwelling use to determine capacity in EHDC ↩︎
  8. SEA Reg. 12(2) – EHDC must assess ~500 dpa as a realistic alternative | PCPA s.19(1B) – 1,147 dpa likely exceeds sustainable delivery limits | NPPF para 35 – 500 dpa better meets “proportionate, justified” test | PCPA s.33A – Cap reflects failure of fair distribution regionally ↩︎
  9.  ONS: Ratio of house price to workplace-based earnings ↩︎