In my own view the cause of the present disaster has to be shared between the present government and the CDC. In May 2010 the present government took over a Strategic Planning shambles from the two previous governments. That had started in 1997 by the countrywide imposition of the unelected and undemocratic Regional Governments. In our region the South East England Assembly (SEERA) did the strategic planning. Instead of bringing planning nearer to local people, as suggested, it also brought a new government office (GOSE) into Guilford alongside SEERA. Then GOSE ensured that government preferences for total housing requirements were promulgated through regional plans and cascaded down to District Councils. Our regional plan was the South East Plan (SE Plan), the last of which was in 2009, just before the present government abolished SEERA and GOSE in 2010/2011. The new government took until November 2011 to publish the Localism Act which was long and complicated. It abolished regional strategies but left the SE Plan operational until the 23 March 2013 when it was revoked. That gave the developers the right to use the old GOSE figures for excess housing. The other government faults were their failure to expressly repeal the previous government’s 2007 Planning Guidance, and the 2009 Strategic Housing Market Assessments (SHMAs see below), which were based on it. This put District Councils in a difficult position to resist undesirable housing developments. All this could be said to be due to government incompetence or to a cynical delaying process to please the Chancellor, who thinks he can build his way out of recession.

As regards faults by the CDC; they knew, after the Localism Act in November 2011, that there would be a delay in revoking the SE Plan, and also that it was bound to happen sometime. With the arrival in March 2012 of the new National Planning Policy Framework, there was a new overall planning guidance, which with a new Local Plan would be all that is needed after the revocation of the SE Plan. Meanwhile the CDC was forced to apply the SE Plan until it was revoked. So “plan A” was already there, it was to apply the SE Plan. But common sense would suggest that a “Plan B” should have been established in the Local Plan for use after the revocation, which initially could happen at any time. That would consist of the much vaunted “bottom–up” locally based plan, instead of an old “top-down” imposition of old regional figures and methodology. If that principle was appreciated, it seems to have been forgotten, for two reasons. Firstly, because the CDC misconstrued para 159 of the NPPF which states:- “Local planning authorities should have a clear understanding of housing needs in their area. They should prepare a SHMA to assess their full housing needs, working with neighbouring authorities where housing market areas cross administrative boundaries”. The words “in their area” mean the area of the CDC. The words “where housing market areas cross administrative boundaries” mean that the CDC must work with Arun and East Hampshire Districts. Not with Adur and Worthing as well, as happened under the SE Plan. As a result the CDC ignored the need of para 159 for a new SHMA based on their own boundaries, and “on the needs of their area”. Instead they “ updated” the old 260 page SHMA document of 2009. So that outdated regional document is now expressed to be the SHMA basis of housing numbers of the draft Local Plan.

Other District Councils in the Coastal West Sussex sub-region appear to have made the same mistakes as the CDC, and along with them the CDC now participates in the recently created Strategic Planning Board. We have no good reason to talk to all of them, as we did in the days of regional government. We now have a similar shambles in strategic planning as existed under regional government. Furthermore there is still a democratic deficit, because neither the public, nor the elected Councillors or the planning officers, can sufficiently comprehend the complicated requirements of the “updated “ NHMA to question the figures and methodology handed down to the Board for approval by GL Hearn, the consultants who have been immersed in the matter since 2008

There is only one way to put this matter in order. The CDC should urgently sack GL Hearn and appoint a different firm to produce, independently, their own SHMA, after consultations with Arun and East Hampshire. They should also cancel the housing requirements made in the draft Local Plan. They should ignore the updated SHMA and the Panning Guidance of 2007 because it is based on Regional Spatial Strategies, which as stated in the amendments to the Planning and Compensation Act 2004, were abolished by Schedule 5 para 13 of the Local Democracy and Economic Development Act of 2009. The CDC should also not be concerned about the Inspectorate refusing to accept the Local Plan even if, on an adequate evidence base, it reduces the housing requirements to even half of the present number. The reasons why all these proposals are lawful under the new planning law are explained in my full report.