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Horsham & Crawley District Update February 2019

4th February 2019

Update: Parishes with “in progress” plans targeted by developers; Horsham District Council’s review of the Horsham District Planning Framework up to 2036 in progress; questions over viability of house building targets and more.

Parishes without ‘Made’ Neighbourhood Plans targeted by developers

Developers are continuing to submit applications to build houses on green fields that have not been allocated for development in the Horsham District Planning Framework (HDPF).

Parishes where Neighbourhood Plans are in progress, but not yet ‘Made’, for example Kingsfold (Warnham) and Rudgwick (applications refused) and Cowfold, Henfield and Upper Beeding (decisions pending) seemed to be developer’s preferred targets.

Fortunately, Horsham District Council’s Authority Monitoring Report (AMR), published January 2019, which covers the period from 1 April 2017 to 31 March 2018, but also includes house-building forward-projections, shows that the council can demonstrate a 109% Five Year Housing Land Supply against its local-plan requirement of 800 dwellings per year.

Details are given in Chapter 3 of HDC’s AMR: Chapter 3: Housing and also in Chapter 6: Policy Indicators:

Fortunately, too, it is apparent from the AMR that the house-building criteria, which have to be met in order to pass the Government’s newly introduced Housing Delivery Test (HDT) have been met in Horsham District.

Should HDC be unable either to demonstrate a five-year housing-land supply or pass the Housing Delivery Test, communities and countryside across the District would be vulnerable to developer-imposed house-building. Parishes with ‘Made’ Neighbourhood Plans that are more than two years old, as well those without ‘Made’ Neighbourhood Plans, would be particularly at risk.

Horsham District Council’s review of the HDPF and the preparation of the new Local Plan, for the period 2021 to 2036, is in progress.

To calculate what the new house-building target should be the Council must use the Government’s new formula-based method, which by means of hocus pocus with numbers has been rigged to achieve an-over England target of at least 300,000 new homes per year.

This means that Horsham’s current target of 800 houses per year will be increased to a minimum base-line number of around 910 houses per year, which developers will seek to increase; plus, because of the ‘Duty to Co-operate’ with other Councils, a proportion of Crawley Borough’s unmet need (currently 150 per year) and perhaps, too, the unmet needs of other Councils; therefore an imposed annual target in excess of 1,100 houses per year is a possibility.

HDC’s AMR Chapter 2: Duty to Co-operate reveals that the Council is engaged in “further evidence-based work with neighbouring authorities as part of progressing the Horsham Local Plan Review” (paragraph 2.4).

An annual target of, say, 1,150 per year would amount to 17,250 in-total over the 15-year period to 2036; 1,250 per year would amount to 18,750 in total. Note that the target, what ever it might be, will be subject to periodic reviews – and increases.

A crucial matter for HDC and communities and countryside across the District is whether the present house-building target of 800 houses per year will stand until the new HDPF is adopted, subject to approval by the Planning Inspectorate, in 2021.

I anticipate that developers will argue at Appeal that the present target is no longer valid and should be updated by applying the Government’s formula-based method – and the five year land supply requirement increased in line with the new and increased target. In which event the consequences for the District would be catastrophic.

Strategic sites to accommodate yet to be announced house-building target

In the meantime, as part of the plan-review process, HDC has to identify strategic sites with the capacity to accommodate the yet to be announced house-building target, for inclusion in the new plan.

Hence “a number of developers seeking to carry out large-scale developments had sought detailed discussion with the planning department.” Of these only Market Mayfield Town and their proposed site has been identified to date (West Sussex County Times 15/01/19).

Details of their proposal, for a development of up to 6.120 dwellings on countryside in the parishes of Henfield, Shermanbury and Woodmancote, are given in HDC’s Strategic Housing & Economic Land Availability Assessment (SHELAA) Housing Report 2018, released January 2019 (page 52:SA414).

The SHELAA advises, with caveats, that the proposed development-site is “not currently developable”, “unless allocated for development through the review of the Horsham District Plan”.

Other strategic-scale sites identified in the SHELAA include Adversane/North Heath (SA597), Billingshurst (SA118, SA642), Itchingfied (SA130), Kingsfold (SA459),,Kilnwood Vale (SA341) and Southwater (SA119). They, too, are classified as being “not currently developable”, “unless allocated for development through the review of the Horsham District Plan”.

Doubtless some, if not all of the developers and landowners who put there sites forward for inclusion in the SHELAA are, like Market Mayfield Town, seeking to have them allocated in the new Local Plan.

Communities need to be alert as to what might be coming to their green fields. HDC’s SHELAA Housing Land Reports by Parish are essential reading.

Dr Roger F Smith
CPRE Sussex  Horsham District leader
and Chair Protect Sussex Group

29 January 2019