Arun District Council Local Plan
Nick has written to members of the Arun District Council Local Plan Sub-Committee ahead of their meeting on Thursday 28 November.
I am writing to you ahead of your meeting later today (Thursday 28 November) where you will be considering gaps between settlements in the local plan and locations for housing supply.
I continue to believe that the Strategic Housing Market Assessment (SHMA) process adopted by the Council is flawed. Nevertheless, it having been accepted by the Sub-Committee, it is important not to confuse the figure arrived at for housing need with the housing numbers set in the plan. It is inherent to the principle of sustainable development that these can be different. The ORS report's claim that it validates a housing "target" for Arun in the range of 550-650 houses a year over 15 years is a fundamental error. The SHMA does not set the housing number in the Plan, and a consultancy employed only to validate the SHMA process has no business doing so. Equally, your Committee should not have simply translated this figure into a proposed housing number (580 a year over 15 years) for full Council to agree.
The National Planning Policy Framework is clear that a local plan CAN deliver a lower number of houses than the objectively assessed need "... if any adverse impacts of doing so would significantly and demonstrably outweigh the benefits ...." (NPPF, para 14 - see here).
This was acknowledged by the Cabinet Member for Planning, who at your last Sub-Committee meeting said :
"This, however, did not mean that Arun should not continue to be vociferous in its opposition to the numbers because sustainability was a key factor. When the strategic allocations were considered at the next meeting (28 November 2013) sustainability of the sites would be an important consideration and whether they could actually be delivered" (ADC Local Plan Sub-Committee meeting, 31 October 2013, para 9 - see here).
I would like to draw to your attention to Hastings Borough Council's plan. This proposed a housing number that was HALF their objectively assessed housing need. Significantly, the Planning Inspector has just passed the plan, specifically endorsing the lowered housing number, on the basis that protected landscapes and "exceedingly pleasant ... open land ... providing an integral part of an attractive rural setting" present "constraints [which] are valuable assets which give the Borough its unique charm, character and appeal" (Report, 21 October 2013, paras 55 and 56 - see here).
Clearly every area is different, and particular constraints may have applied in Hastings - although some, such as the limitations imposed on coastal towns and the prevalence of protected landscape, notably also apply to Arun. However, the key point is not to compare Hastings and Arun directly: it is that the principle that lower housing numbers CAN be set has been established and endorsed by the Inspectorate. This case was drawn to my attention by the Planning Minister when I raised these issues with him.
We are all well aware of the significant constraints to development in Arun, where a high proportion of the landscape is protected and there are already problems of inadequate local infrastructure, including flooding, congested roads, and pressure on local public services.
Prematurely conceding higher housing numbers (580 a year) is leading the Council towards choosing strategic sites, including two in my constituency - Angmering and Barnham/Eastergate - which would otherwise not be necessary. I continue to object strongly to these proposals. Angmering has already expanded substantially, and 500 further houses will put even greater pressure on infrastructure, especially local roads. A new settlement of 2,000 houses in the Barnham/Eastergate area will destroy the green gap between villages, create a suburban-style conurbation, and build on an area prone to flooding. Both proposed strategic developments are severely undermining neighbourhood planning and the public support which is necessary for this process.
I do not accept the Cabinet Member for Planning's view, expressed in an e-mail yesterday (27 November) to my constituents, that strategic developments are necessary to produce sufficient funds for infrastructure - "tossing a rock in the planning pond". This is a circular argument, since developments on the scale proposed will themselves put considerable additional pressure on infrastructure. On this flawed logic, even greater housing numbers would be the solution to our infrastructure deficit in West Sussex. The supposed infrastructure gains from these strategic allocations are not properly quantified, and a cost-benefit analysis has not been undertaken.
I therefore strongly urge the Sub-Committee:
1. To set a realistic housing number which properly recognises local constraints on delivery.
2. To reject the 'strategic' housing allocations at Angmering and Barnham/Eastergate.
Clearly it is essential, if the Plan is to set a lower housing number than the assessed housing need, that the constraints on development are thoroughly evidenced. If the Sub-Committee has insufficient evidence available to take into account these constraints, then I strongly urge it to instruct a proper audit BEFORE a final housing number is set and the allocation of sites is made.
Should Arun District Council set a housing number which simply matches the level of assessed housing need, without properly taking into account the constraints on the delivery of these numbers, I believe the process will be judged to be flawed, and that the Plan will continue to face the strongest local opposition - including my own.
With kind regards.