It became difficult to object to applications for the usual reasons. We therefore informed relevant Councillors and senior planning officers on the reasons why we consider wrong decisions being made, resulting in too high a 5 year HLS. Firstly the Council considers itself to be bound by the top down 2007 SHMA Guidance issued by the Department for Communities and Local Government (DCLG), and not cancelled despite the abolition of the South East Plan. This is wrong because the Guidance is only valid insofar as it does not conflict with the NPPF. In most applications it conflicts with paras 197, 7 and 8 of the NPPF in respect of the social, and environmental dimensions of sustainability as we state above. Secondly, under para 159 the Council has not itself prepared an Strategic Housing Marketing Assesment (SHMA) for its area as required. Under para 47 this should assess "their full housing needs, working with neighbouring authorities where housing market areas cross administrative boundaries", this means the adjacent lpa's for Arun, East Hampshire, and Horsham. Instead the Council has worked with the lpa's for the Coast" extending to Lewes.

Also, by "updating" in November 2012 the SHMA of 2009, they have perpetuated into 260 pages the top down methodology of the SE Plan after its abolition last March. Furthermore, as we have mentioned, in para 8 of our comments on the draft Local Plan, there is a democratic deficit whereby the 2009 SHMA was updated by the original paid Consultant who continues to provide housing requirement figures to the Strategic Planning Board of the Coastal lpa's which own the document, so that the Chichester District Council has no control over the numbers chosen. Meanwhile the Council has extended the time for approving the draft Local Plan until December, which gives developers another four months to be certain of winning their planning applications. If, and when, the 2007 Guidance is replaced, the draft Local Plan will immediately become out of date, by which time all possible damage to the environment will have occurred. We doubt the sincerity of the DCLG's statements that the new Guidance would be issued in July, then September. The delay is seen to benefit the Treasury's proposals for widespread house-building by allowing developers to win applications of their choice on outdated policies. This matter should be tested by a judicial review.

RICHARD HILL (District convener)

Thursday, September 19, 2013