‘If we don’t have a plan we’ll get housing development anyway with no control’

The Horsham district has to take extra housing and without a new plan in place it would have the development anyway but without control, senior council officials have warned.
Cabinet member Claire Vickers with a copy of the local planCabinet member Claire Vickers with a copy of the local plan
Cabinet member Claire Vickers with a copy of the local plan

Horsham District Council is consulting on its draft local plan until the end of March and is asking the public for its views on levels of housing development and potential allocations for large strategic and smaller development sites.

This week we put the commonly asked questions to Claire Vickers, cabinet member for planning and development and director of place Barbara Childs, who both stress that no decisions have been made at this stage.

What is HDC doing and why is it doing it?

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CV: We are currently consulting on our local plan. We have to do this every five years and we are out to consultation. We had a call for sites and some 500 were proposed by developers and landowners. We are consulting on everything we have not made any decisions as yet. I genuinely mean that we have not made any decisions. There are a number of options. But the housing number that we have been told by Government through the standard methodology figure is 965 homes a year and that does not include any duty to cooperate with our local neighbour authorities who can’t meet their own needs.

What lobbying of the Government has the council done on the proposed housing figure?

BC: When the Government first proposed a standard methodology we challenged that straight away [in 2017]. We have written letters to the Secretary of State.

CV: We have had holding letters that have not been conclusive in their answers. We have then gone to our MPs and that’s Andrew Griffith and Jeremy Quin. We had a face to face meeting with them earlier this year. They have gone away to see what they can do to help us because they understand the huge pressure that we are under.

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Is the district taking a ‘double whammy’ as it is being expected to find extra homes due to unaffordable house prices on top of meeting unmet need from neighbouring areas?

CV: We had 800 homes a year currently of which 650 were for our own housing need and 150 were for Crawley. The inspector told us that was the number we had to take for Crawley. However my understanding of the standard methodology for the 965 does not include any duty to cooperate figure it is basically our own need.

BC: We have to work with our neighbours and we have to demonstrate how we can meet any of their unmet needs.

CV: We have to cooperate with them, that does not mean we have to meet all their unmet needs because they are enormous.

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BC: We have to go through the process and explain what and whether and how many and whether we can meet any of their needs.

CV: I think the reason we were asked to do Crawley is because we are in the same housing market area. That housing shortfall was shared between us and Mid Sussex. They [Crawley] have a significant shortfall because they say they are built right up to their boundaries.

Will you argue that while you might be able to take some extra houses the district does have some environmental constraints?

BC: There are a number of arguments. Environmentally, what the district can actually accommodate, it’s what the market could actually sustain.

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CV: It’s all very well allocating lots of land for housing, but they are not going to build all at the same time because they will be in competition with each other, so they will not necessarily deliver so there’s this market forces element.

BC: And what infrastructure is needed to support such significant levels of growth.

CV: That’s one of the points we made with our MPs is that if we have to make such a huge increase in numbers what can you do to help us to get the infrastructure that we desperately need and I mean highways improvements, education, health, all those provisions that we are under strain.

BC: There’s a timing issue here because significant infrastructure takes time to deliver so how can we provide that number of homes before we have that infrastructure investment?

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CV: We are always playing catchup. You want the infrastructure up front really before you start delivering all these homes because it impacts on the existing community.

BC: Sometimes we need the infrastructure before any development can go ahead. For example if we were to need a new sewage treatment works that would need to be in place before development went ahead.

Horsham delivered more than 1,300 new homes in 2018/19, but you’re expecting that figure to be a peak not the norm?

CV: We had an extremely good year of delivery because the major strategic sites all came forward at the same time, it was like a blip, but we do not see that being sustainable into the long term. Kilnwood Vale did a considerable number of completions.

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BC: It means that the numbers are a lot less as you go to the end of the plan period, but it averages out at 800 homes per year. But this time we are being required to provide a minimum of around 1,000 houses a year, that’s over the entire plan period.

CV: That’s without the duty to cooperate and we need a five per cent buffer as well.

With the buffer do you get punished when you under-deliver but not rewarded when you over-deliver?

CV: I made that very clear to our MPs. I can see why you’d be penalised for not delivering, but you should not be penalised again for over-delivering.

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BC: The Government’s answer to that is that if you under-deliver you have to give a 20 per cent buffer, and we are being ‘rewarded’ by only having to provide a five per cent buffer, that’s the Government’s response.

CV: We have to demonstrate a five year housing land supply, but we think we should only have to show a three year land supply.

BC: That’s one of our asks to the MPs.

CV: We are challenging the numbers. There are people out there saying; ‘why don’t you just say no to the Government and say no we can’t do that’.

What would the outcome be?

CV: We would have the development anyway. We would have no control so all those developers and all those proposals would come forward as planning applications which we as a district council would probably refuse, they would go to appeal and the Government inspector would say you haven’t got a five-year land supply and then we’d lose them.

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We’d have no control over infrastructure, community benefits, all those things people need and we would be having development in places that are not suitable in terms of what we think.

Is there any evidence of developers slowing down their build rates?

BC: We have, so our developers have got quite a lot of stock that is built but not yet sold. Part of that was to do with Brexit, but even after the blip at the end of last year the market still has not picked up locally here. It’s steady, but it’s certainly not as buoyant as it was.

We are doing a bit of extra evidence base work looking at delivery and what is possible going forward.

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CV: The prices have held up, they have not gone down because we have built lots of houses.

BC: We’ve done a bit of work on that and there’s absolutely no evidence at all that house prices come down when the number of homes built increases.

CV: That’s one of the reasons why we’ve challenged the standard methodology. We’ve got no evidence to show that building all those houses has reduced house prices.

BC: People will pay a premium to live here.

CV: A lot of people want to live here because it’s an easy commute to London, it’s got lovely countryside, it’s near the coast, it’s got good schools and everything.

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On the housing numbers we are between a rock and a hard place. We are instructed by Government, if we do not do it we are going to get it anyway so we need to have control and we need to make sure that we make the best possible decisions and we know that it’s not going to be popular.

Wherever you put development on a large scale you will get opposition. There’s no hiding from that.

We have had a fairly good response so far since we published this consultation document.

What are the primary misconceptions or things people are confused about?

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CV: That we have already made a decision and we are doing them and it’s our proposals and the district council has proposed these sites - we haven’t.

We did a call for sites and developers and landowners have put forward some 500. Some of those have been ruled out as being undeliverable but the majority are out for consultation and we have not made any decisions. There’s a misconception that these are going to go ahead and we will build all of it.

BC: Developers had been promoting their sites and holding exhibitions and people have seen those as council proposals.

CV: There is a difference between allocations and planning applications. There are no planning applications for any of these sites.

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BC: And if there were, the decision would be very straight-forward. Refusal, because clearly it’s contrary to our adopted local plan.

CV: We have a five-year land supply and we do not have to go outside that development plan.

BC: Another misconception is that our larger strategic sites are preparing their planning applications because we know that they want to submit them before we have an examination. The reason they do that is so they can demonstrate to the inspector they hope their site is genuinely deliverable, but we would not make a decision on any application such as that which comes in before the examination. We would not be making a decision other than refusal on any of those, not until we’ve adopted our plan.

Why do discussions with developers take place behind the scenes?

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BC: We are treating the developers all in exactly the same way, there’s no preferential treatment to anybody. We have to do that because ultimately whether sites are allocated or not we have to do the due diligence, we have to understand and we have to test the evidence that the developers are putting to us.

CV: Wherever we haven’t allocated, they will sit before the inspector and say we should have done, like they did last time. We have to treat them all exactly the same and have the evidence as to why we have chosen what we have, which is the really the difficult bit.

As members we take advice from officers, they have done site evaluations on all of those sites and then at the end of the day when all the responses come back we will have to make a decision and it’s not going to be an easy one, I can tell you.

Because the council is the owner of Rookwood how do you make sure that this strategic site is dealt with fairly?

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CV: That’s why we are consulting on it in exactly the same way as all the other sites, the evaluation will be completely transparent.

BC: There’s a Chinese wall in essence between the property department and planners and they have assessed that in a completely independent way.

What should public consultation responses be focusing on?

CV: ‘I don’t like it’ doesn’t work. They have to come up with really good planning reasons why this won’t work - even if it’s two or three people saying it rather than a thousand people signing a petition saying don’t go here.

We want more people to say this is an unreasonable request and these housing numbers will cause environmental damage or harm to our locality, it’s going to affect people who already live here and their quality of life. If there’s demonstrable evidence that says this level of development is going to have a significant impact on infrastructure, there are health issues in terms of health provision, there have been school issues but these are outside the council’s control.

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We can allocate sites for a hospital, or doctors’ surgeries or schools, but we can’t provide the doctors or the teachers or the running of these facilities.

It’s not the district council either building these homes or community facilities. We want people to tell us what the impact of those levels of developments would be.

BC: What’s been helpful is people writing to us with evidence of flooding. There will be no development in a flood plain, so it’s really important for us to understand where flooding is happening. The Environment Agency gives us information, but if locally people have information such as that flood plain is not accurate then we have the evidence to go back to the Environment Agency to ask them to do more modelling in this location.

What other policies are in the local plan?

BC: There are policies on climate change and biodiversity. We have strengthened our policies both in terms of biodiversity, requiring a ten per cent increase. We have strengthened our policies on the sustainability of actual developments and requirements as they relate to building regulations and we have got other policies that seek to address the issues around climate change. There’s a whole raft of environmental policies in there which we have worked hard to enhance and improve.

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CV: The climate change policies have certainly been beefed up.

What are the next stages after consultation?

BC: The next stage will be the proposed submission, that’s when it becomes council policy. Depending on what comments we get back almost certainly there will be further work we need to do before we finalise our policies and members have the very difficult decision to make.

CV: We are hoping in that time period the MPs might come back with some help for us.

What happens in November?

CV: Our plan will be five years old in November so automatically our housing number goes up to 965 from 800 whether we have got any further with this or not. Our housing trajectory looks good at the moment.

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BC: But in order to maintain it we would have to allocate other land.

Between November and when the new plan is adopted do you think you’ll have enough permissions in the bank?

CV: It does give us some comfort we’ll have a plan coming forward.

BC: Whilst members have got some very difficult decisions I do not think anyone is underestimating the challenge we have before us now.

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It’s unprecedented in my career. At the end of the day it will be the inspector who makes the decision. The plan will go to an independent inspector representing the Secretary of State and he or she will then determine whether we have done enough and if the housing number is correct or if additional housing sites have to be found and they may well direct us to where those should be.

The final test is outside all of our control.

To comment on the local plan visit the council’s website.

If you are unable to comment online, we can send you a comment form by email or by post. Please email [email protected] or call 01403 215100.

Copies of the draft local plan can also be viewed at the council offices at Parkside, Chart Way, Horsham, RH12 1RL (between 9 am and 5 pm on weekdays) and in district libraries.

What do you think about the local plan? Send your thoughts or comments to our letters page.