This annual target needs to be understood in context: firstly, in the context of the escalation of MSDC’s own view of the District’s needs over the decade during which it has been working up this new strategic plan. As recently as 2013 it calculated its housing target at 530 dwellings a year (dpa). By June 2015 the target had jumped to 650 dpa and ended up in the version submitted this summer to the PI at 800 dpa.
Secondly in the context of the number of new homes (houses and flats) that actually get built within the District. Until a spurt in the last 18 months this has been running at an annual average of about 476 dpa. This level of building has itself involved considerable controversial green field development, but it has been well below the 855 dpa target imposed on MSDC under the old South East Plan. So, since 2012, the building shortfall has occurred despite MSDC being under the cosh of the National Planning Policy Framework which made it far harder for MSDC to refuse permission.
CPRE’s take on all this has been to argue at the examination hearings that, whatever the District’s housing needs, it lacks the environmental capacity to absorb the level of housing proposed in MSDC’s new Plan; and that this was demonstrated by the problems that MSDC has had to date in delivering new housing in sustainable locations. What is it about the new Plan, we have asked, that will so dramatically change things that it will enable the consistent delivery, year on year, of 800 new homes on sustainable sites in a District in which the long term average delivery has been under 500? How much rape and pillage to our special countryside would that involve?
The worst thing that can happen would be for the new Plan to set a housing target that MSDC finds itself unable to meet, dragging it back into the current default situation where it again loses control over strategic planning within the District and has to release yet more green field sites to developers. We have urged the Planning Inspector not to allow that to happen. We will have to wait and see.
But the omens are not good. The Inspector plainly does not accept MSDC’s evidence as to what the District’s housing need is, and has indicated that he would expect MSDC to do more to help its neighbouring authorities. We expect him to require MSDC to dredge harder around the district to find more sites that could be developed. Nor has he followed the lead of the Horsham Inspector who offered no encouragement to the promoters of a new 10,000 home so called Mayfields Market Town. This proposed new town would be built somewhere in the middle of the empty Low Weald and could one day see Sayers Common, Twineham, Wineham and Albourne, all of them off-the-beaten-tracks villages within Mid Sussex, disappearing as separate rural communities. The MSDC Inspector seems to want this explored as one option as an overspill location for Brighton and Hove.
There is the very real danger that the level of new housebuilding within Mid Sussex in the years to come will to have to nearly double (yes double) compared to the level that we have experienced in recent years, even without taking the Mayfields scheme into account. Most of it on green fields outside current community boundaries. CPRE Sussex knows from its own experience and from what our members tell us that the level of building occurring within what is a rural District, over half of it comprising the specially protected High Weald Area of Outstanding Beauty, is causing widespread concern for its long term sustainability; and that the balance is wrong between the undoubted need for new homes and the conservation of our countryside and biodiversity.
The public examination of the draft Plan and the consideration of whatever recommendations the Planning Inspector makes in respect of the Plan’s soundness will drag on into the first quarter of 2017, and possibly beyond. MSDC’s has been desperate in recent weeks to demonstrate to the PI that it is doing all it can to increase the level of its approvals of new homes. It has allowed a scheme to proceed on a site in Hassocks that the local community was trying to get protected via their neighbourhood plan as a local green space; it has given up justifying at appeal its perfectly valid reasons for refusing planning permission. It has even taken the position that the housing and site allocation policies in all the adopted neighbourhood plans around the district – ones that it encouraged and vetted - are out of date and carry limited planning weight because of the District level housing shortfall. And, worst of all, MSDC has pre-empted its own proposed policy to allocate via its new District Plan a 110 acre site within the High Weald AONB at Hardriding Farm, Pease Pottage – a policy whose soundness was due to be independently tested as part of the new Plan examination - by granting permission for 600 new homes and a 48 bed hospice there a week before the start of the Plan examination hearings. MSDC has thereby avoided PI scrutiny of this scheme on a site that MSDC itself had described in May 2016 as “very unsuitable” for development. The planning application was opposed not only by CPRE but also by Natural England, the High Weald AONB Unit and by neighbouring Crawley Borough Council. CPRE, a long standing critic of the proposal, did apply to the Government to use its powers to call in the decision when our plea to the Council to defer their decision was ignored; but this application was sadly turned down, and the housing is now, we fear, a fait accompli.
What makes MSDC’s decision particularly worrying is the precedent that it sets. Planning authorities have a statutory duty to conserve and enhance the natural beauty of national parks and AONBs. Major development within them is only permissible where there are “exceptional circumstances” and where it is in the public interest. The only justification suggested by MSDC for this development was the fact that the district has a housing shortfall and that there was a developer ready to build there. If a housing shortfall were, by itself, a sufficiently exceptional circumstance then no national park or AONB would be safe from the bulldozers given how many planning authorities struggle to meet their targets and how high the risk that MSDC will fall back into default under its new Plan.
What makes it all the more galling is that the Hardriding Farm development is intended by MSDC primarily to demonstrate that it is commitment to help out Crawley’s housing shortage, but Crawley BC actually opposed the development. You have to pinch yourself to believe it all!
Meanwhile our regular CPRE Sussex grind of reviewing the larger planning applications for their suitability and sustainability continues. We encourage the Council to refuse permission only where we consider that the harm to our countryside outweighs the benefits and where the would-be developers’ case fails to address properly the environmental challenges that their scheme would involve. We have supported a local resident in East Grinstead who has been effectively been left by the Council to justify for them at appeal their own decision to refuse permission for 200 houses on an exposed site of considerable landscape value alongside the Grade II listed Bluebell Railway viaduct outside East Grinstead. The outcome of that appeal heard in October, which has been called in by the Secretary of State, won’t be known until the new year.
We have started a dialogue with residents of Horsted Keynes as they evaluate a number of options and developer schemes that would see their village boundary expand well into the High Weald. This will be a real test of how to find a sustainable balance between village level needs, District-wide imperatives and AONB conservation.
We have also been working with local residents seeking to prevent a 3 ha site, also within the High Weald AONB, from being converted into a car park for a private business.
All in all, 2016 has been a very challenging year for Mid Sussex and for those of us at CPRE Sussex committed to its future as a very special place to live and work.
Michael A. Brown