Based on the evidence of the first two weeks’ hearings of the Planning Inspector’s Examination of the Horsham District Planning Framework (HDPF) it is disturbing that scant attention seems to have been paid to two crucial issues that are of vital concern to the public relating to the proposed housing allocations under the Plan.
Affordable housing. The PI should have been made aware that, while the HDPF gives a target rate of 35 per cent affordable housing on large sites, this rate is subject to modification on ‘viability’ grounds.
This get-out clause is reflected in the National Planning Policy Framework (NPPF), which states (para. 173) that ‘the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable’.
Experience across the country has shown that in practice this has allowed developers to determine – in effect unilaterally – a proportion of affordable housing acceptable to themselves and their shareholders, typically much lower than the target sought by the LPA.
In the case of the HDPF – and the North Horsham Strategic Development in particular – this is all too likely to result in a watering down of the affordable housing commitment imposed on the developers to well below 35 per cent so as to enable them to meet their other obligations (notably under the Community Infrastructure Levy).
In that event we can expect that the district’s ratio of house prices to average earnings at the bottom end of the market (lower quartile) to remain close to or above the current elevated level of 11.04, compared with averages of 8.88 for West Sussex and 6.45 for England – a gap which has widened significantly since 2009.
Use of brownfield sites. Although the NPPF encourages ‘the effective use of land by reusing land that has been previously developed (brownfield land)’, the HDPF tries to suggest that most suitable brownfield locations have already been developed and that a greater share of future new housing will have to be built on greenfield sites.
However, as was pointed out at the hearings a) there are in fact extensive brownfield sites – particularly in and around Horsham town – as a result of the continuing redundancy of office and other commercial premises – and b) this tendency is certain to continue as a result of long-term economic and technological trends.
Despite this the Inspector has shown little interest thus far in brownfield potential for housing in relation to HDPF, even though it would have the obvious advantage that the sites concerned are close to existing infrastructure and would thus also be appropriate locations for affordable housing.
If, as seems all too likely, the Inspector decides to follow what may well appear the line of least resistance and approve a Plan providing for housing development overwhelmingly on greenfield sites (which are far more profitable for developers) and with minimal provision for affordable housing, he will arguably only be following a government policy – enshrined in the NPPF – that in practice is proving to be well designed to give developers and private landowners all they demand.
Yet if that happens it would clearly be seen as a betrayal by all members of the community who seek to create an economically and socially sustainable future for themselves and their children.
A vision of what such a sustainable future should be – and how the NPPF needs to be adapted to make it possible – can be found in evidence submitted by Future Horsham (a group of local residents) to the inquiry into the operation of the NPPF just completed by the Communities and Local Government Select Committee - http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/communities-and-local-government-committee/operation-of-the-national-planning-policy-framework/written/12952.html
In fact, based on other evidence submitted to the same inquiry, such an outcome would be all too typical of the experience of local communities all over England, who may have been deluded into thinking that the Framework was designed to protect their interests, whereas in reality it leaves them exposed to outside commercial interests who care nothing for local concerns or aspirations.
Allingham Gardens, Horsham