The Editor
West Sussex County Times

Dear Sir,

Understandably there is considerable public anger at Horsham District Council’s allocation for development in the HDPF of huge tracts of countryside North of Horsham, west of Southwater and at Billingshurst.

However, those who value the countryside and the natural environment should also be very concerned that the HDPF’s policies for the natural environment and biodiversity will, because of their wording, carry less weight than national policies for same. This will have consequences for countryside and communities across Horsham District.

A planning consultancy provided an independent and objective appraisal for CPRE Sussex and proposed amendments to align the policies with the NPPF, which we submitted to the Planning Inspector, Mr ‘Geoff’ Salter, at the public examination of the HDPF last November. All but one was rejected by the Council’s officers on the grounds that to incorporate them would be ‘overly protective’, ‘too restrictive’ and ‘could conflict with the provision of necessary housing and employment growth’. Mr Salter did not disagree with the officers.

My understanding of Mr Salter’s position and that of the Council is that in their view the environmental dimension of sustainable development carries less weight than the economic dimension, including housing and employment growth, and that it is their belief that Councils can decide for themselves the extent to which their policies for the natural environment conform to NPPF policies.

It is CPRE Sussex’s view that Mr Salter and the Council are mistaken and that conformity with NPPF policies would not prevent development, but it would require proper due diligence by decision-takers when considering applications and determining appropriate mitigation measures and conditions. It is also our understanding that local plans and plan policies, including those for the natural environment, must be in conformity with national policies - that conformity is not discretionary.

Meanwhile, the Chief Executive of the Planning Inspectorate (CEPI) will neither confirm nor deny whether it is the Planning Inspectorate’s position that the environmental dimension of sustainable development, as expressed in the NPPF, carries less weight than the economic dimension, and whether it is permissible for councils to adopt local-plan policies for the natural environment that are not in conformity with the wording of the NPPF.

However, responding to a question, asked under the Freedom of Information Act, the Department of Communities and Local Government has confirmed that to be sound a local plan “must conform with national policy”.

Accordingly, it would appear that unless a High Court Judge has ruled to the contrary, and notwithstanding CEPI’s reluctance to clarify the Inspectorate’s position, any local plan with policies, including those for the natural environment, that are not in conformity with national policies would be unsound – including Horsham District Council’s HDPF.

Yours faithfully,

Dr Roger F Smith
Trustee CPRE Sussex