LETTER: Due process must be transparent

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Since we are informed that the Planning Inspector’s (PI) final report on the soundness of the revised Horsham Development Planning Framework (HDPF) – following conclusion of his Examination in July – is due to be delivered by the end of August, it is hard to understand why he has now seen fit to inform the council, via a note of 21 July, that he has decided that the housing requirement for the plan period should be raised yet again – from 750 to 800 dwellings per year (as reported in your issue 23July ).

This move seems all the more bizarre as he makes clear that he is not yet able to give the reasoning behind this conclusion, which will only be revealed in his final report – except that ‘it reflects all the evidence produced before the hearing, including... the updated position regarding unmet needs in the Strategic Market Housing area, with particular reference to Crawley’.

This action by the Inspector appears highly anomalous for a number of reasons:

His note seems to suggest that this is a decision of the PI that cannot be overturned by the council – who are only being consulted as to how and where the additional housing is to be provided; this appears to be a clear contravention of the National Planning Policy Framework, which gives the responsibility for plan preparation to the council (as local planning authority) in the first instance.

The PI’s note supports his decision based on his unsubstantiated claim ‘that the District has the capacity to accommodate this level of development without unacceptable environmental effects’ while ignoring the other more important criterion of objectively assessed need.

In fact it emerged during the hearing on 3 July, as is evident from the truncated recording of the proceedings, that the council’s own assessment of housing need in the District – based on market signals and the current excess of supply over demand – is lower than it was in 2014.

Likewise it was made clear that HDC is now taking a much less optimistic view of the prospects for employment growth, one from which the PI did not appear to dissent during the hearing.

How can he therefore reconcile the further increase in the housing need that he has called for with slower projected growth in employment?

The apparent attempt to bridge the gap by reference to overspill from Crawley runs up against the reality that, as pointed out by Roger Arthur during the hearing, the present ratio of house prices to incomes is significantly higher in Horsham than Crawley, so that people whose place of work is in Crawley will not be very keen to move to Horsham.

The call to increase the housing allocation from 750 to 800 dpa is nowhere justified by the Inspector in terms of objectively assessed need or any kind of market signals - just as was the case with his request last December for an increase from 650 to 750 dpa.

In fact the best clue to his decision is his statement during the afternoon session on 3 July (when unfortunately the recording system had failed) in response to the insatiable browbeating of the assembled developers that 800 dpa was the maximum he thought he could get away with without having to reopen the public examination.

From the above we may reasonably infer that the PI’s otherwise unexplained early announcement of his decision on the revised housing target without giving his reasoned justification for it could be an attempt to present the decision as a fait accompli and pre-empt further discussion by the council, which might otherwise expose him and others to serious embarrassment.

Whatever the true explanation it is up to councillors and concerned citizens to ensure that due process is transparently followed.


Allingham Gardens, Horsham


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