Doubtless at its Extraordinary Meeting on 19 November, Horsham District Council (HDC) will present Planning Inspector ‘Geoff’ Salter’s conditional endorsement of the HDPF as set out in his report to the Council, as a triumph. Regrettably, however, there is a substantial mismatch between the Council’s emerging narrative and the reality and the resulting consequences for the District of the Inspector’s report and his instructions to the Council therein.

Contrary to the understanding of some commentators and Councillors, the arbitrary and excessive target of 800 houses pa imposed on our District by Mr Salter is intended as an interim measure only.

As far as Mr Salter is concerned the only way is up for housing numbers and he has instructed HDC to review the District’s ‘objectively assessed need’ for housing within three years of the HDPF’s adoption, in order to play “its part in addressing the needs of the wider area”, including “those of the coastal area authorities and possibly London”. A substantial addition to Mr Salter’s arbitrary 800pa in all years to 2031 is therefore highly likely, and developers will certainly seize the opportunity to press for a substantial increase and the allocation of their greenfield sites to accommodate them.

Note, too, that although the Inspector concedes in his report that his interim target will cause “some environmental impact” he studiously avoids acknowledging that the offloading of more houses to our District from other Districts will add significantly to that impact and that the resulting accumulated impact will cause environmental harm.

Another important issue is that whilst the Inspector says that HDC has a demonstrable 5year supply, including the ‘historic undersupply’ accrued against his target since 2011 (the start of the new plan-period), he also says that more sites will have to be allocated in order to accommodate additional houses and to maintain the 5year supply throughout the plan period.

Notwithstanding, Mr Salter’s report, the ability of HDC to demonstrate that developers are able and willing to build the requisite number of houses on allocated sites over the next five years has already been challenged by a developer at Appeal (held 26 and 27 Oct), the outcome of which is awaited.

Tellingly, only four of the 102 paragraphs in Mr Salter’s report are devoted specifically to infrastructure and its provision. This is because, as Mr Salter explained at his examination of the HDPF in November last year, his primary role was to ensure a ‘step change’ in the delivery of housing in Horsham District. Ensuring that the infrastructure needed in consequence of his imposed target and conditions could and would be delivered was not part of his brief from Government.

Acceptance and implementation of the Inspector’s conditions will result in substantial harm to our District and its environment and to residents’ quality of life. Horsham District Council should reject them.

Yours faithfully,

Dr Roger F Smith
For CPRE Sussex (Horsham District)