Horsham District Council (HDC) is producing a new local plan for the period to 2031 – the Horsham District Local Planning Framework, which is due to be adopted in 2014.

HDC has first to decide how many houses should be built. As part of this process a public consultation – ‘How much housing does Horsham District need?’ – in which four options for future housing numbers were presented, has been undertaken. The four options were:- Option A: 11,800 (590 pa); Option B: 12,700 (635 pa; Option C: 13,400 (670 pa) and Option D: 14, 600 ‘plus’: (730 ‘plus’ pa).

Local CPRE Sussex group Horsham and Crawley has commissioned planning consultants Hives Planning Ltd to critically examine the basis of the council's proposals. Our conclusion is that a future target of 9,600 homes is more appropriate.

Dr Roger Smith, Vice Chairman, West Sussex, discusses the issues surrounding this campaign in depth:

Horsham District Council (HDC) is producing a new local plan for the period to 2031 – the Horsham District Local Planning Framework, which is due to be adopted in 2014.

HDC has first to decide how many houses should be built. As part of this process a public consultation – ‘How much housing does Horsham District need?’ – in which four options for future housing numbers were presented, has been undertaken. The four options were:- Option A: 11,800 (590 pa); Option B: 12,700 (635 pa; Option C: 13,400 (670 pa) and Option D: 14, 600 ‘plus’: (730 ‘plus’ pa). These figures include permissions not yet built and allocated sites. According to HDC these commitments amount to 6,300 houses in total.

HDC’s options for future housing development draw upon the misnamed ‘Locally Generated Housing Needs Study’ (LGNS) produced for HDC by a firm of property consultants, which now ‘informs’ HDC’s decision makers in place of the South East Plan.

Readers will have noticed that at least two of the house-building options, C (13,400) and D (14,600 ‘plus’), are higher than the 13,000 new houses allocated to the District by the South East Plan. Moreover, when one takes into account the 395 new houses built in the District since 2009 when the Plan was adopted,HDC’s Option B (12,700 + 395) also exceeds the Plan’s allocation.

These high-number options are particularly surprising when one considers that in 2009, HDC was concerned that the Plan’s allocation of 13,000 new houses to the District was at ‘the upper limit’ of what could ‘be sustained’ and was “very demanding for environmental and infrastructure reasons and that any higher level would likely to have unacceptable impacts”.

For those very cogent reasons HDC wanted a lower number of houses – 12,400, not 13,000. That HDC should now present ‘options’ higher than the 13,000 houses required by theSouth East Plan, which was prepared before the recession, is questionable - especially when neighbouring Mid Sussex District Council has set a significantly lower housing target of 10,600 houses compared to 17,100 in the Plan; a huge 37.4% reduction.

In his introduction to HDC’s Consultation document, Councillor Ian Howard, Cabinet Member for Living and Working Communities, specifically invited ‘interested parties with their own suggestions of numbers to put these forward, be they more or less than those in options A-D. The only requirement is that any figure must be backed up by data, evidence and reasoned argument so that it can be considered for inclusion in the Council’s agreed strategy, which will be examined by an independent inspector’.

CPRE Sussex – Horsham and Crawley therefore commissioned planning consultants Hives Planning Ltd to critically examine the LGNS and the Consultation document and to assess whether there are other options for levels of housing in Horsham District.

The resulting report concluded that HDC’s ‘options’ for future housing are excessive and advocates instead a target of 480 dwellings per annum - 9,600 in total, including 6.600 commitments. This is based on past completions over the last 11 years, which have averaged some 400 houses pa; adding a 20% housing supply buffer to accord with the National Planning Policy Framework results in a future target of 9,600 new houses to 2031.

In coming to this conclusion the Hives’ Planning Report demonstrates that the level of population and employment growth and household formation and inward migration in Horsham District to 2031 is either overstated or unsupported by the LGNS and the consultation document, or is likely to require far fewer houses than HDC’s four options. Significantly, HDC’s proposed options are all much higher than past completions and those projected in the District’s Annual Monitoring Report. Even the lowest option - Option A at 590 pa - is almost 50% higher than actual past completions. Apparently, HDC does not understand that the current economic situation is particularly severe and there is no certainty as to when and to what extent the economy will recover.

Significantly, no evidence is offered by HDC to substantiate its explicit and questionable presumption that building a given number of houses will create a specific number of jobs.

Moreover, HDC’s equally contentious claim that ‘affordable homes could make up 40% of all homes built’ is belied by its current failure to achieve more than 30% for large new developments.

Our response to the Consultation, in which we recommend a target of 9,600 houses, is informed and underpinned by the authoritative Hives Planning Report [see attachments], which meets fully Councillor Howard’s requirement that any proposal that differs from the ‘options’ presented by HDC ‘must be backed up by data, evidence and reasoned argument so that it can be considered for inclusion in the Council’s agreed strategy’.

By Dr Roger Smith, Vice Chairman, West Sussex

Photographs of felled oaks and a tree being prepared for felling in countryside south of Broadbridge Heath, where around 1,000 houses are to be built, courtesy of Roger Finch.

Main image courtesy of psd