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CPRE Sussex response to the Horsham District Local Plan

2nd June 2020

CPRE SUSSEX RESPONSE TO THE HORSHAM DISTRICT LOCAL PLAN 2019 – 2036 PUBLIC CONSULTATION (REGULATION 18) 17 FEBRUARY TO 30 MARCH 2020

CPRE Sussex’s responses submitted on-line (x21 plus 4 supplementary submissions) to the Consultation Plan, including Horsham District Council’s ‘Housing Number Options’, ‘Potential Housing Allocations’ (strategic sites), and various policies are accessible via this page.

The three ‘Housing Number Options’ presented by Horsham District Council (HDC) in its draft plan are flawed:

We disagree with HDC’s understanding that it must add a 5% buffer to the 965 homes per year Standard-Method-calculated ‘minimum annual local housing need’, for each year of the 18 years of the plan-period, 2019 to 2036 (Consultation District Local Plan, paragraph 6.14).

NPPF para. 67 requires a buffer to be added to the first five years of the plan, not for the entire plan-period, to ensure that there are sufficient sites available to deliver the first five years of housing need. It should not be confused with the buffer required for five year housing land supply.

Note that a 5% buffer would increase the ‘district’s minimum annual local housing need’ of 965 houses per year to 1,013.25 houses per year (5% of 965 = 48.25. 965 + 48.25 = 1,013.25 per year). Over the 18 years of the plan-period this would increase the District’s total minimum local housing need from 17,370 (18 x 965) to 18,238 (5% of 17,370 = 868. 17,370 + 868 = 18,238).

In addition to the 5% buffer, the third ‘option’ presumes an unmet housing need of ‘around 400 house per year and a resultant huge and unprecedented housing target of 1400 houses per year over the 18 years of the plan-period, therefore 25,200 in total (1400 x 18).

However, it is stated in the Consultation Local Plan (paragraphs 6.8 and 6.9) that under the Duty to Cooperate, the ‘unmet housing need’ of other local planning authorities, allocated to/accepted by HDC, might well be considerably more than “around 400 homes each year” – therefore an overall housing target in excess of the 25,200,is indicated.

Since this has huge ramifications for Horsham District, clarification is needed and until this is provided the district’s overall housing target will continue to be open-ended and uncertain.

The advent of the Covid-19 pandemic, and the deepening recession that it has caused, warrants an ‘alternative approach’ to establishing the District’s housing need.

How councils are to determine their ‘minimum annual housing need’ is set-out in the ‘Guidance: Housing and Economic Needs Assessment, guides councils in how to assess their housing needs’, issued by the Ministry of Housing, Communities and Local Government.

The Guidance informs councils that although “there is an expectation that the standard method will be used” for strategic policy making, it is “not mandatory”, “if it is felt that circumstances warrant an alternative approach,” with the caveat “that any other method will be used only in exceptional circumstances” (Paragraph 003 Reference ID: 2a-003-20190220).
https://www.gov.uk/guidance/housing-and-economic-development-needs-assessments

The advent of the Covid-19 pandemic, and the deepening recession, “the likes of which we have not seen” (Chancellor Rishi Sunak, 19 May 2020), is an Exceptional Circumstance in consequence of which house sales and build rates will be much reduced and the huge, unprecedented, unsustainable and open-ended housing target now in prospect, because of the Standard Method and ‘unmet needs’ of other councils, will be rendered unattainable.

The resultant failure to meet housing targets on allocated sites with permissions will be the norm and the council’s ability to control development will be lost.

An ‘alternative approach’ to establishing the District’s housing need is therefore warranted and needed, and the open-ended off-loading to Horsham District of other authorities unmet need should be resisted.

After all, as is acknowledged by HDC (Consultation District Local Plan, paragraphs 6.8 and 6.9) the council “does not have any direct control over housing delivery rates”, and there is “no guarantee that there will not be issues outside our control (such as a national economic downturn) which would limit the delivery of homes”.

Covid-19 and its devastating impact on the economy and the housing market is outside of HDC’s control – and the house-building target now in prospect is unsustainable.

See:
https://www.planningresource.co.uk/article/1681454/covid-19-crisis-cause-housing-delivery-plunge-one-third-planning-consultancy-predicts

https://www.civilserviceworld.com/articles/news/sunak-warns-uk-faces-%E2%80%98severe-recession-likes-which-we-haven%E2%80%99t-seen%E2%80%99

https://www.bloomberg.com/news/articles/2020-05-19/sunak-predicts-u-k-recession-on-scale-we-have-not-yet-seen

Potential Housing Allocations

‘Potential Housing Allocations’ (strategic sites) presented in the consultation draft are:
‘Land at Adversane’, Land east of Billingshurst, Land West of Billingshurst, Land East of Billingshurst’, ‘Land at Buck Barn’, ‘Land West of Crawley’, ‘Land North East of Henfield, Land at Kingsfold, ‘Land at Rookwood’

It was apparent from the site appraisals, given in the consultation draft plan, that none of these ‘Potential Housing Allocations’ can be depended upon to bring forward development that accords with wider sustainable development that balances the need for economic growth with social and requirements as identified in the NPPF – and also with the policies proposed in the draft for-consultation plan, notably in regard to climate change, affordable housing, impacts on the vitality and viability of existing communities, and on the natural environment

Smaller Site Options: Summary

With a severe recession now in prospect, in consequence of Covid-19, the allocation of Smaller Sites should be phased over the local-plan period, by means of Neighbourhood Plans and the neighbourhood planning process.

Dr R F Smith
Trustee CPRE Sussex