The Consultation on HDC’s Planning Framework (HDPF) re-commences on 18th March, but we await guidelines on what can and cannot be raised with the Planning Inspector (PI). For now, it would be useful to review a) the Inspector’s notes and b) what he has missed.
The PI considered the HDPF to be flawed i) in that HDC had failed to justify the housing need and ii) in that a clear link between housing and employment figures needs to be demonstrated. But there were other flaws, which were not mentioned.
1. To recap, the HDPF focus changed in 2013 to include 2,500 houses – extending into North Horsham’s strategic gap. That was linked to 500,000 sq ft of local employment space, from which it was hoped to increase Business Rate income. But we don’t have a full audit trail to justify that option - against the cost and impact of alternatives.
Surely the erosion of the Strategic Gap and the massive development in North Horsham, should have been justified with such an audit trail - before Consultation was initiated?
2. HDC hopes that the employment space will create 4,000 jobs. But no one knows how many existing residents might work there, whether their skills are suitable, how many would commute in daily and how many could afford to live in the District. The assessment of infrastructure demand (including road capacity) would have to be updated, once full data has been collated.
However, the Gatwick Diamond Initiative (GDI) indicated little need for more business space in the area - other than for warehousing/distribution and the Inspector failed to demand evidence that HDC’s Plan was consistent with market demand.
Alternatively HDC would need to show how they would make Horsham attractive enough to buck the market, but they have not done that. The Developer’s contingency plan will no doubt be to build more houses, when business space is not taken up, with much of the profit going offshore.
3. On brown field options, the PI seems to conclude that any significant increase in housing supply from vacant commercial premises is unlikely to be achieved, without the “undesirable” loss of valuable employment sites. But how can they be valuable if the demand is not there?
4. Of course the number of Persons per Household is affected by market factors and cannot be deduced primarily from population demographics. There has been a shift away from constant decreases in household size, because first time buyers are almost 40 years old, while the average house price/salary ratio in HD, is over 10:1.
Moreover the 750 new dwellings pa target is about 65 per cent higher than the 8 year average (453dpa) before the recession, when the economy grew at around 3 per cent pa. So neither a 650pa nor a 750pa average target is attainable over 20 years and short-term peaks are irrelevant.
5. We also need to know how the infrastructure funding gap is to be closed, eg i) by raising S106/CIL contributions, ii) by reducing the % of Affordable Houses (AH) or iii) by building more houses? The answer to that becomes even more important since the smallest developments do not now have to provide AHs and developers can veto developments as “not viable”, if they generate “insufficient profit”. (Yes developers are still in the driving seat!)
It is clearly no good projecting AH as a percentage of a housing target, that is itself flawed.
6. All of these flaws should have been addressed before the start of Consultation and the PI should have insisted on that. However, since his conclusions were “preliminary” we might still expect them to be fully addressed, as “Main Issues”.
Since Taxpayers stump up around £40,000,000 pa for the un-elected Planning Inspectorate, they are unlikely to be happy with an outcome, which has little to do with Localism, which is not based on sound market data, is without a complete audit trail and an options analysis.
As the Plan is fundamentally flawed, it would be totally unacceptable to residents for it to be adopted - unless and until all of the unanswered questions have been properly addressed.
Roger Arthur is UKIP’s Horsham parliamentary candidate and district councillor for Chanctonbury.