In his report to Horsham District Council, Planning Inspector Geoff Salter concludes that the HDPF ‘provides an appropriate basis for the planning of the District’ subject to ‘a number of modifications’.
He also confirms his previous ‘recommendation’ that Horsham District’s ‘Objectively Assessed Housing Need’(OAN) is at least 800 houses per year, back-dated to 2011, and subject to review and further increase.
However, as is made clear by the report, the Inspector’s use of the descriptor ‘Objectively Assessed Need’ is a misnomer, because the 800 new houses per year target is not the product of a truly ‘objective’ process or methodology.
Moreover, Mr Salter’s explanation of how he arrived at the target build-rate seems to indicate that a smaller target, in the region of 700 houses per year would be nearer the mark.
Consequently, his 800 houses per year, which he concedes will cause ‘some environmental impact’, is seemingly an arbitrary and excessive imposition.
Significant, too, is Mr Salter’s unstated but implicit presumption that developers will be able to build and sell at least 800 houses per year in Horsham District in all years to 2031.
That is a hugely questionable presumption on his part, given uncertainty about future economic growth and therefore job growth, and concerns over the building industry’s capacity to meet the Government’s requirement for a substantial increase in houses built.
Doubtless developers will continue to declare that the District does not have a demonstrable five-year housing supply, which will be grossly inflated by the substantial shortfall against his excessive target, accumulated since 2011 – and will seek more permissions at Appeal to build on unallocated sites.
Doubtless, too, Billingshurst’s residents will be surprised that the Inspector considers that ‘some development’, additional to that already approved, ‘may have some potential to relieve some of the pressure for new housing in some coastal authorities’; ‘some’ geographical confusion here on Mr Salter’s part.
Furthermore, contrary to Mr Salter’s understanding, the 475 houses to be built on fields east of Billingshurst village were approved by Horsham District Council, not ‘on appeal’ by the Inspectorate. His error shows an inattention to detail.
Surprising, too, is Mr Salter’s misunderstanding that the North of Horsham development will provide 35 per cent affordable housing ‘in accordance with Policy 15’ of the HDPF.
Although the Inspector was advised at the examination of the HDPF last November that the site would deliver 35 per cent, this commitment was subsequently rescinded – and, at the HDPF ‘Further Hearing’ held this year on 3 July, an HDC officer advised Mr Salter that the number was subject to negotiation; inattention again to detail.
That the Inspector regards his 800 houses per year to be an interim target is made clear by his requirement that HDC review the District’s ‘objectively assessed need’ for housing within three years of the HDPF’s adoption and his instruction to HDC that it play ‘its part in addressing the needs of the wider area’, including ‘those of the coastal area authorities and possibly London’.
This is an open door for developers to press for yet more houses to be added to Mr Salter’s excessive initial target – and the inclusion of additional sites.
Dr ROGER F. SMITH
Trustee, Campaign for the Protection of Rural England (CPRE) Sussex, for CPRE Sussex (Horsham District), Bashurst Copse, Itchingfield
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