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Letter: Covid-19 and its catastrophic consequences is an ‘Exceptional Circumstance’

16th July 2020

Letter published in the West Sussex County Times, 9 July 2020


‘Exceptional Circumstance’

Cllr Vickers, in her letter ‘Must continue making a plan’ (WSCT 2July), advises that Horsham District Council (HDC) “will continue to challenge the basis of the standard methodology, but it is too simplistic to assume that we can ignore it and arbitrarily set a lower housing target”.

For the sake of our district, Cllr Vickers, and those who advise her, really should read and comprehend 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.

As explained previously through the pages of WSCT (11 and 25 June), the Guidance states that usage of the formula-based Standard Method 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).

After all, the Covid-19 pandemic and resultant recession, which Chancellor Rishi Sunak has advised is “a recession the likes of which we have not seen”, is an ‘Exceptional Circumstance’ that most certainly warrants an alternative approach and method to determine the district’s “genuine housing need”.

Moreover, HDC acknowledges in its Draft District Local Plan (paragraph 6.16) that it “does not have any direct control over housing delivery rates”, and that 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 catastrophic consequences is an ‘Exceptional Circumstance’ that is beyond the council’s control.

Accordingly, as is permitted by the ‘Guidance’, the council should itself determine what the district’s housing need is (e.g. not decide arbitrarily), and submit it to the Planning Inspectorate with a detailed explanation as a part of the proposed local plan, for scrutiny at the Examination-in-Public.

Yours faithfully,

Dr R F Smith
Trustee CPRE Sussex