On 20 July, Havant Borough Council opened what is likely to be the last real opportunity for residents to influence the Building a Better Future Plan before it is handed to a Government-appointed Planning Inspector for independent examination. Given how much rests on this plan – it will shape housing, employment and green space across the borough through to 2043 – it’s worth taking stock of how we got here, what’s genuinely at stake in the next six week consultation period, and what residents can and can’t usefully say at this particular stage.

A plan with a previous life

This is not the borough’s first attempt at a new Local Plan this decade. An earlier version went to independent examination in 2021. Following the first round of hearings, the Planning Inspectors wrote to the Council setting out serious concerns. Most decisively, they found that the Council’s public consultation had not followed the methods its own adopted rules for community engagement had promised – for example, leaflets and exhibitions in libraries that had been committed to but not delivered. The Inspectors judged this created a real risk that some residents, particularly those without easy internet access, had been shut out of the process, and their strong advice was that the Council withdraw the plan, consult properly, and start again. Separately, and worth remembering given what follows, the same Inspectors also had serious doubts about two of that plan’s largest housing sites – Southleigh and Campdown – finding that neither could be shown, on the evidence at the time, to be reliably deliverable. The Council withdrew the plan.

The current process, branded Building a Better Future, began soon afterwards, in March 2022. That July, Council planning officers met representatives of twelve resident and civic groups, Havant Civic Society among them, to discuss the new plan and answer questions submitted in advance. The answers given at that meeting were, at the Council’s informal request, not published at the time. Four years on, with the plan now reaching its final public stage, we think it’s in the public interest to publish that record in full, and we are doing so alongside this post. It makes interesting reading: Council officers acknowledged in writing, a year after the 2021 Inspectors’ findings, that the Southleigh housing figures had simply been carried over from the withdrawn plan “for consistency” and would “need to be put back” to address the Inspectors’ concerns, and confirmed that Campdown had already failed the Government’s test for a deliverable site. Both sites are back in this plan, at very similar housing numbers, four years later.

Where things stand today

Since that 2022 meeting, the plan has been through further rounds of consultation – on options in 2022, and on a full draft in 2025 – before arriving at the version now going forward for what’s called a “Regulation 19” consultation: the publication stage, where the Council presents the version it believes is ready for examination.

Running alongside it, two of that plan’s largest individual housing sites are themselves live planning applications, working through their own separate public consultation and decision process: Southleigh, a proposed community of up to around 1,800 homes between Havant and Emsworth, and Campdown, a 590-home development on Portsdown Hill. Between them, these two sites are expected to supply close to a third of the entire Local Plan’s housing total for the next two decades. The Southleigh application alone has, in the first three weeks since it was published, attracted 763 recorded objections from the public – an exceptional number for a single planning application, and a clear sign of the depth of local concern. Southleigh and Campdown – 1,800 and 590 homes respectively – risk being determined on a planning record that the council itself cannot confirm is complete, accurate, or safe from legal challenge.

This overlap matters for more than just scheduling reasons. If either site turns out not to be deliverable in the way the plan assumes – because the road network genuinely cannot absorb the traffic, or because infrastructure the plan itself requires isn’t actually going to be funded – that is not a small technical footnote. It goes to whether the plan can honestly be called deliverable at all, given it is already relying on these two sites for such a large share of its total housing numbers. Pushing the plan towards examination while that exact question remains unresolved, on two sites an Inspector already found undeliverable once before, is a real risk the Council is choosing to run, and residents are entitled to say so.

What residents can actually say right now

This is the point in the process where it’s easy to get the wrong idea about what kind of comment is useful. Earlier rounds of consultation, in 2022 and 2025, were genuinely open to residents saying “I don’t want this development here” or “I’d prefer a different approach.” This Regulation 19 stage is different, and it catches a lot of people out. At this stage, the Council has already decided this is the version it believes is ready, and the rules only allow comments on two narrow questions: is the plan legally compliant, and is it sound. General objections to a policy you simply disagree with, however strongly felt, carry little weight here – they needed to be raised earlier. What the Inspector wants to hear now is whether the plan has followed the correct legal process, and whether it stands up to scrutiny on its own terms.

An example of a soundness point: one of the four legal tests for soundness is whether a plan is “effective,” meaning genuinely deliverable over its lifetime, not just on paper. If a plan leans on two sites for roughly a third of its total housing supply, and the developers’ own submitted evidence for one of those sites shows local road junctions failing and a piece of infrastructure the plan itself requires – a walking and cycling bridge over the railway – has reportedly been dropped for lack of funding, that is a legitimate, evidenced soundness argument: the plan cannot currently be shown to be effective as written.

An example of a legal compliance point: the Council’s adopted rules for how it will consult the public (its Statement of Community Involvement) set out the specific methods it commits to using. Given that the Council’s previous plan was withdrawn specifically because it failed to deliver the consultation methods it had promised, it is entirely fair for residents to check whether the current consultation – which appears to rely heavily on a website, an online form and an email mailing list – actually matches what the Council’s current rules commit to, and whether residents without easy internet access are genuinely able to take part on equal terms.

What we’d encourage residents to do
Read the plan, and if you have concerns, use the official Regulation 19 representation form to raise them, framed around whether the plan is legally compliant and sound – that is what will actually be read and weighed at examination. We’ll be publishing more detailed guidance and our own submissions on both the Local Plan and the Southleigh and Campdown applications in the coming weeks, but we didn’t want residents to wait for that before understanding the history behind this plan, or what kind of comment will actually count in the next six weeks. The full record of the Council’s 2022 answers to residents’ groups, published alongside this post, is there for anyone who wants to see the fuller picture for themselves.

Havant Civic Society 24th July