In her letter ‘Huge risk if we have no plan’ Cllr Vickers warns that ‘until we have our Plan fully agreed by him (the Planning Inspector) we do not have the ability to prevent even more housing’ (WSCT 12Mar15.
Unfortunately, having a plan fully agreed by the Inspector will not provide assured protection against opportunist developers.
Developers are able to gain approval at appeal to build on unallocated sites in Horsham District because the council (HDC) is unable to demonstrate a five-year housing land supply.
This is in large part because, as is acknowledged by the Planning Inspector in his ‘Initial Findings’, the ‘financial crisis and economic downturn’ had ‘an unprecedented influence on house building in the local area’ causing house sales to fall and developers to reduce build rates in response.
A significant contributory factor, too, is the use by HDC since 2012 of the ‘Sedgefield’ method of calculation to determine the five-year requirement for new houses, whereby the accumulated shortfall in the number of houses built is included in the five-year requirement going forward.
This has substantially inflated the District’s five-year housing land requirement, (against the target imposed by the South East Plan), thereby putting the council in a much more vulnerable position when fighting appeals, as the council acknowledges in its Authority Monitoring Report 2012/13.
Previously, HDC had used the ‘Liverpool’ method whereby the shortfall was spread over the remaining plan period resulting in a much lower five-year requirement.
When the Horsham District Planning Framework is adopted, use of the Sedgefield method will require HDC to include in the five-year requirement from when the Framework is adopted the substantial shortfall that has accrued since 2011 (the start of the new plan-period) against the new and increased target of at least 750 houses per year, imposed by the Planning Inspector Mr G. Salter.
This will result in yet another inflated requirement. Developers might then question whether the council can demonstrate an achievable five-year requirement and invoke NPPF paragraph 49 to submit applications to build on unallocated sites and go to appeal should HDC refuse them.
Moreover, as is recognised by the Office for Budget Responsibility in its ‘Economic and Fiscal Outlook’ (December 2014) there is considerable uncertainty around any economic forecast.
Mr Salter, however, has taken a contrary view. In deciding his arbitrary target for the District he has assumed unabated economic growth and no fall below his target in house sales and build rates in all years to 2031; a most unlikely eventuality.
To reduce the District’s vulnerability to opportunist developers and for the sake of communities across Horsham District, the council should return to using the Liverpool method.
Dr R.F. SMITH
For Campaign to Protect Rural England (CPRE) Sussex (Horsham District), Bashurst Copse, Itchingfield