Horsham District Update, December 2020

11th December 2020

“Thank you to all who responded to the consultations and/or wrote to their MPs to make known their concerns”.

The previous ‘update’ (September 2020) considered how the radical changes to planning rules and the planning system, presented in two separate but related documents released by the Government for consultation on 6 August, could or would impact on Horsham District.

https://www.cpresussex.org.uk/news/horsham-district-update-september-2020/

The consultations were:

‘Changes to the current planning system consultation on changes to planning policy and regulations’ closed 1 October. https://www.gov.uk/government/consultations/changes-to-the-current-planning-system

‘Planning for the Future, White Paper’ closed 29 October. https://www.gov.uk/government/publications/planning-for-the-future

‘Changes to the current planning system’ includes a proposal to replace the ‘Standard Method’ (imposed in 2018), with which councils are currently required to assess their ‘minimum annual local housing need’ with a new method, details of which were given in the consultation document.

Usage of this new method would result in an enormously inflated target for Horsham District of 1,715 new houses per year: https://lichfields.uk/grow-renew-protect-planning-for-the-future/how- many-homes-the-newstandard-method/#section16

Cllr Claire Vickers, Horsham District Council’s Cabinet Member for Planning and Development, has advised that to accommodate this enormous over-inflated target “we would need to build on every major housing site included in our recent Local Plan Regulation 18 consultation” (West Sussex County Times, Aug 20). These ‘major housing sites’, all of which are greenfield, are:

Land at Adversane, West Chiltington Parish (Kingswood); Land East of Billingshurst (Little Daux); Land West of Billingshurst (Newbridge Park); Land at Buck Barn, West Grinstead (Weald Cross); Land West of Crawley; Rusper Land at Kingsfold, Warnham (North West Horsham); Land North East of Henfield (Mayfield); Land at Rookwood, Horsham; Land West of Southwater, Southwater.

(Horsham District Local Plan 2019-36 Public Consultation (Regulation 18), February 2020, pages 52-101).

The Government, however, has recently indicated that the proposed changes would be altered, “reportedly to allocate more housing development to urban areas in the Midlands and the North.” And that “there is likely to be a further consultation on the Government’s separate proposals to further adjust the method, so it sets ‘binding’ local plan housing requirement figures” (PlanningResource.co.uk: ‘Planning’ issue 2111, Winter 2020, page 5).

Meanwhile, councils are required to determine their ‘minimum annual local housing need’, which has superseded ‘Objectively Assessed Need’, using the ‘Standard Method’.

The ‘Planning for the future, White Paper’ stated that “Local Plans should identify three types of land – Growth areas suitable for substantial development, Renewal areas suitable for development, and areas that are Protected”.

However, according to PlanningResource.co.uk: ‘Planning’ (issue 2111, Winter 2020, page 6), “The Government is now saying that the necessary legislation could take two years to complete”. In which case, a temporary reprieve for councils – and Horsham District’s in- preparation new plan.

The target of 800 houses per year, set by the Planning Inspector who examined the Horsham District Planning Framework (HDPF) during 2014/15, life-expired in November, five years after the HDPF’s adoption, November 2015.

This now redundant target comprised 650 houses allocated to meet the District’s need for housing, plus an allocation of 150 houses to meet a proportion of Crawley Borough’s ‘unmet need’ – the houses needed by Crawley, which because of a lack of sites within its boundaries must be built outside of the borough, in compliance with the ‘Duty to Cooperate’.

As required by the Government, HDC has had to use the method Standard Method to calculate the District’s ‘minimum annual local housing need’. The resultant minimum target is 920 houses per year, an increase of 270 houses (41.54%) per year on the 650 per year allocated to meet the district’s housing need in 2015.

Whether HDC has or will have a 5year housing land supply against the new target should be made apparent by the soon to be published Authority Monitoring Report (AMR) for the District.

Not having a 5year supply would render communities across the District vulnerable to applications to build on unallocated sites, with decision making at Appeal should HDC refuse such applications.

Regarding the Government’s Housing Delivery Test, a review by Savills of completions across England in the three years to March 2020, indicates that HDC should pass the test, the results of which have yet to be published by the Government (Savills Blog: Net Additional Dwellings 2020).

Meanwhile, a developer has lodged an Appeal against a refusal by HDC, in which the developer argues that the council does not have a demonstrable 5year supply (APP/Z3825/W/20/3261401 Land North of Sandy Lane, Henfield). Doubtless others will do likewise.

Horsham District Council’s in-progress new local plan

The public consultation on Horsham District Council’s (HDC) draft replacement, the HORSHAM DISTRICT LOCAL PLAN 2019 – 2036 PUBLIC CONSULTATION (REGULATION 18) was held earlier this year, 17 February to 28 March.

CPRE Sussex’s submission responding to the consultation can be viewed at

https://www.cpresussex.org.uk/news/cpre-sussex-response-to-the-horsham-district-local-plan/

The previous ‘update’ (September 2020) considered how the radical changes to planning rules and the planning system, presented in two separate but related documents released by the Government for consultation on 6 August, could or would impact on Horsham District. https://www.cpresussex.org.uk/news/horsham-district-update-september-2020/

Key stages and dates in the making of HDC’s new plan, the ‘Local Plan Review’, are as follows:

Note that that the Standard-Method-calculated minimum annual local housing need figure of 920 house per year for the District should also be set for the new plan, except that some of Crawley’s unmet need, and probably of other councils too, will be added to the 920.

What the unmet need figure will be, if known by HDC, has yet to be made public.

The Wilder Horsham District Initiative

‘Wilder Horsham District’ is a joint Horsham District Council/Sussex Wildlife Trust initiative which aims in summary to: help wildlife thrive across Horsham District, create networks of land that is protected and enhanced for nature, to allow habitats to expand and for species protection to increase, to ensure species are resilient to change, increase awareness of actions that communities can take to improve their local environment and the benefits that nature provides, and maximise the opportunities for protecting and enhancing the natural environment to reduce the impacts of a changing climate.

Additional information can be viewed and downloaded at:

https://www.cpresussex.org.uk/news/wilder-horsham-district/

With best wishes for Christmas and the New Year.

Dr Roger F Smith
10 December 2020