The Government is creating ‘totally unrealistic’ housing targets that are impossible to meet - according to the leader of Horsham District Council.
Writing to planning minister Nick Boles last week Ray Dawe (Con, Chantry) argued that the Government’s planning inspectors were approving applications regardless of any assessment of local conditions.
He called on Mr Boles to implement interim measures to stop developers being allowed to build wherever they wanted, and told him that the slump in housebuilding was due to tough economic conditions out of the council’s control.
HDC was therefore in an ‘invidious position’ of being punished for a dip in housebuilding prevalent across the South East, while developers sat on around 8,000 approved housing applications in the Horsham district.
“This is contrary to any conception of Localism and creates a housing target which by any measure is totally unrealistic and simply impossible to meet,” he explained.
“None of this collapse in new house building can be attributed to local authorities and, under the circumstances, it is difficult to see what else they could have done to alleviate the situation.”
HDC published its new draft housing plan for consultation earlier this month, which lays out where and how many houses will be built in the district over the next 20 years.
Proposals would see a new business park and 2,500 homes in North Horsham, and 500 in both Billingshurst and Southwater.
He said that more weight needed to be given to emerging housing strategies when deciding appeals.
This was evident last week as the council approved 475 homes for Billingshurst, with most members admitting they could not reject the application because it would be overturned by the inspector, and they would lose control of community benefits.
In his letter to Mr Boles, Mr Dawe wrote:
You will recall our meeting with Francis Maude on 24th June. I argued then that Government housing policy has put Horsham District Council in the invidious position of having housing applications approved by Inspectors regardless of what it has locally assessed. You suggested that we should have a further meeting once you had been able to look at all the information and I hope that this can now be arranged.
I repeat the primary suggestion that Francis Maude and I made when we met you that Inspectors give much greater weight to emerging housing strategies. To this, I now add three further suggestions to ease the difficulties that central Government is causing to residents in the South East of England.
Since the Government came to power in May 2010, it has abolished the South East Plan (SEP) and introduced the National Policy Planning Framework (NPPF). Paragraph 14 of the NPPF states in essence that where a Local Authority’s development plan is considered to be out of date, planning permission must be granted.
The SEP housing target was developed in the period 2006 to 2008 when the number of new dwellings created annually was at a peak (in 2008 224,000 new dwellings were created in England). Following the Lehman collapse in 2008 and the onset of the recession, the number of new dwellings created has fallen to - in 2012 135,000 (DCLG Housing Statistics Release 25/04/13). Indeed in Horsham District, the predicted build out rates of two major developments declined from 610 dwellings per annum in 2007/08 to 268 in 2011/12. None of this collapse in new house building can be attributed to Local Authorities and, under the circumstances, it is difficult to see what else they could have done to alleviate the situation.
It has also become apparent that Local Authorities without a perceived five year housing land supply cannot win appeals against developers. Horsham District has approaching 8000 approved housing applications, yet is considered by Inspectors at appeals not to have a five year housing supply based on the premise that any houses not built in previous years must now be added to the next five years’ housing target rather than being phased over the 20 years of a local authority housing plan. This is contrary to any conception of Localism and creates a housing target which by any measure is totally unrealistic and simply impossible to meet.
The overall effect of the foregoing is that in districts which do not get special protection (eg they are not in an AONB) developers can build houses where they choose and not in the most sustainable areas where the local communities would like the houses to be built. Five years is far too short a period to be able to make a sensible and considered adjustment to the huge economic downturn we have experienced.
Effectively, Horsham District is being held to a housing target set in a plan developed during the loose money era which created a boom in UK house building and eventually a banking crisis. The panel report on Regional Spacial Strategy (RSS) for the SE of England contained on page 87 the extraordinary statement that, “it sees (housing) demand as almost limitless”. Despite the SEP saying that the assumptions underpinning the RSS would be monitored and lead to a review of the plan, this did not occur despite the onset of the most serious recession since the 1930s. Instead, although the SEP has supposedly been abolished, we have a situation where its central thrust of highly optimistic housing targets still remains and is being used by central Government appointed Inspectors to overrule decisions made by elected Local Authorities.
The argument from Government to all this simply appears to be that a Local Authority should publish its 20 year plan and get it adopted regardless of what happens through appeals that could strongly undermine the basis of that plan in the interim period. This comes at a time when there has been a constant stream of new legislation emanating from Whitehall making it even more difficult to follow the lengthy and bureaucratic plan making processes laid down by central Government.
In addition to the earlier suggestion of advising Planning Inspectors to give much greater weight to emerging plans in planning appeals, we ask for your consideration of the following additional actions:
1. Instruct Inspectors to place significantly less weight on five year housing land supply performance against targets set in the South East Plan and give more weight to other planning considerations e.g. sustainability of the location, effect on sensitive local landscape, etc;
Following a seismic change such as that which followed the Lehman collapse, allow Local Authorities to allocate their housing backlog over all the remaining plan period, not just a five year timescale;
Allow Local Authorities to develop housing needs targets and agree these with Planning Inspectors separately from the production of the overall District Plan. This would enable Local Authorities to set sensible housing targets related to present day conditions in a shorter timespan than that required to develop and get adoption of the full District Plan. It could also save Local Authorities time and effort in the event that the Planning Inspector disagreed with the housing target and rejected their plan.
I look forward to hearing from you.
Mr Dawe’s letter, dated August 23, was copied to Horsham MP Francis Maude, South Downs MP Nick Herbert, and Cabinet Members with responsibility for Planning in West Sussex.