LETTER: Justifying an unjustified plan

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Below is a copy of an email I have just sent to Barbara Childs, Head of Economic Development and Leisure, Horsham District Council.

I believe the points made contradict HDC’s logic and undermine their case for 500,000 sq ft of additional commercial space, let alone north of the A 264 bypass. I hope you may find it worthy and have space to publish in your paper.

Dear Barbara,

I refer to your email dated 25th October, timed at 21:04, in response to my email sent to you on 26th September 2013 which was a simple and straightforward request for:

A breakdown of the commercial spaces available in Horsham town and district.

Details of and information about enquiries HDC had received for commercial space.

As you will have gathered from our prior meeting (in your office on 23rd September 2013) my request was made in order to understand HDC’s justification for proposing, in its Draft Preferred Strategy, the building of 500,000 sq ft of commercial premises / business park; and in order that I may more knowledgably respond to HDC’s consultation, before it closed on 11th October.

For the record, on 30th September I sent an email asking about progress with my request. On 3rd October you telephoned to say you would respond the following day. On 13th and 23rd October I emailed to remind you I had still not received a response. Your response was eventually sent a month later and two weeks after the closing date for the consultation.

In your response (which Cllr Vicker’s described as “really good’’) you confirm that HDC did and still does ‘not have data in the format requested… that office stock in the town is around 1m sq ft, current vacancy is circa 250,000 sq ft, of which an estimated 100,000 sq ft may be viable for conversion to residential use’.

You state, without substantiation or quantification “Whilst there appears to be an abundance of discussed [sic] commercial floorspace within the district, the majority of it is dated stock, unsuitable to meet modern business needs… we are now left with a considerable oversupply of older, poorer quality units which present a significant barrier to viability as they are often very costly to refurbish and upgrade. Businesses are seeking Grade A stock with raised floors for computer cabling, air conditioning, double glazing and DDA compatibility (lifts, ramps etc). Much of our existing stock is unable to meet these needs which is why it currently remains under utilised.” However, this ignores an HDC sponsored consultants’ report that “even where stock has been refurbished it is proving difficult to let…The condition or type of stock in itself does not appear to suggest that it is unsuitable for continued use as office provision…The survey work undertaken by both Horsham District Council and GVA Grimley identify few premises where the condition of the building, or the context within which it sits, alone make it unsuitable for continued use as an office. Beyond these specific premises the general condition of office stock within Horsham is deemed to be good and, notwithstanding the current economic and market conditions, would provide suitable accommodation for businesses in the future.”

Accepting that some (not all) businesses seek “Grade A” accommodation; there are premises in Horsham which are “Grade A” which have remained empty for years. I note, amongst other omissions, you have not provided any data as to the amount of Grade A and non-Grade A space available nor information as to the cost of upgrading non-Grade A premises; or the relative cost of leaving premises empty, demolishing or converting them to alternative uses; or mentioned the certainty that the recent economic downturn is a factor in the under utilization; or that some businesses may not require and may choose to occupy premises which are less costly than Grade A stock.

To obtain a breakdown of the commercial spaces available in Horsham town and district, in order to understand whether there is any justification in HDC’s proposal, you defer “if you wish to do further research details on existing vacant premises I suggest that you contact local commercial agents”.

The same HDC consultants’ report referred to above concludes “The oversupply of large stock [in Horsham] is also likely to be exacerbated by the commercial attractiveness of relatively nearby centres of Crawley and Croydon. Crawley especially has a critical mass of large scale office provision and, with faster rail links to London, has established itself as the prominent office location within the sub-region.” Despite that, HDC proposes another 500,000 sq ft of commercial building - more than twice as much as all the space R&SA occupied at peak.

You state that “a number of the District’s business parks started out as a small collection of units which have expanded over time, because of this, the access route into these sites is often [not always] via narrow country lanes which are not suitable to accommodate the expanding flow of traffic”. You omit to quantify the accessible premises available in Horsham town (which if occupied would bring much needed trade and would help revitalize the town-centre) and instead of considering the option of upgrading the few restricted access routes, HDC is proposing building new offices beyond easy reach of the town centre and where there are currently no access routes at all across the green fields!

You refer to the 2006 Employment Land Review while ignoring the more recent consultants’ report which concluded Horsham’s limited potential for attracting demand for office space. You have provided only two examples of businesses which have considered but did not choose to come to Horsham and you have not explained their reasons. The fact is that whatever and to what extent premises are available they will not necessarily suit every enquirer. The balance in making provision is where the raison d’être of our town and district are maintained without either detrimental loss or detrimental gain.

Despite your findings that “there is a shortage of available industrial space across the District… Only three per cent of Industrial stock is vacant ... The vacancy rate for office space is around eight per cent”, HDC is proposing yet more office space and no more industrial space. I wonder if that contradiction is because HDC recognises that planning permission for a commercial building could relatively easily be varied to permission for industrial use!

The “estimate [that] around 100,000 sq ft may be viable for conversion to residential use” is conspicuous by its absence from HDC’s assessment as to how Horsham’s future housing needs (and, in particular, affordable housing) may be met without destroying yet more of our precious and irreplaceable green fields. At current averages, 100,000 sq ft is equivalent to more than 100 houses, and would accommodate many more, much needed, 1 and 2 bedroom homes. You have not said what consideration HDC has given to the remaining around 150,000 sq ft of vacant commercial premises which, contrary to HDC’s consultants’ report, you conjecture “present a significant barrier to viability”.

It is evident that when proposing the North of Horsham development HDC did not and still does not know the breakdown of commercial premises in its region (nor, presumably, in adjacent regions) and no regard has been made for the immanent availability of substantial space, such as in Hurst Road and at the Novartis site, nor to premises you regard as no longer viable.

Perhaps worse than all this, even though HDC’s North of Horsham development proposal should have been based on a sound economic growth assessment you state “I am unable to send you a copy of [an Economic Growth Assessment] because it has yet to be finalized.” Evidently HDC is working on an economic assessment after deciding its conclusion – searching for reasons to justify its unjustified plan.

Please let me know if and where my understanding is incorrect.

CHRIS MORRIS

Tennyson Close, Horsham