What might a 30 year plan for Horsham Look like?


The Government announced changes to the National Planning Policy Framework (NPPF) on Tuesday 20 July, without notice. These changes have significant implications on the Horsham District Local Plan.

Horsham District Council is now required to prepare a Local plan detailing 30-year vision.  The current draft Plan prepared under the previous requirements sets out planning policies and proposals to guide development up to 2038 only.

We have sought legal advice and it is clear that we will need to commission some additional work to support this new 30-year vision requirement. Consequently, we have been recommended to delay the development of the Local Plan.

As a result of the changes required and the legal advice sought, the meeting of full Council on 28 July to approve the Regulation 19, Pre-Submission Horsham District Local Plan document will be postponed.

Leader of the Council Cllr Paul Clarke said:

This is hugely disappointing news. We have sought help from MHCLG to reduce our housing requirements without any substantive success. As a result we have worked hard to prepare a plan that would pass muster with a Planning Inspector in order to protect the District against speculative development.

The Government consulted on the possible requirement for Local Plans to include a 30-year vision some months ago and we responded asking for guidance on how this could be evidenced. We received no feedback and had no advance warning of this substantive change in the NPPF. Worse still, no guidance has been published alongside the changes to the NPPF to explain what Local Authorities need to do to meet this new requirement.

Our legal advice is clear that we have no choice but to delay our Plan.”

The reference is to Para.22 of the new NPPF. Without notice errr it was in the consultation draft.

Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.

Which is subject to the following footnote, which wasnt in the consultation draft.

For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published (for Spatial Development Strategies this would refer to consultation under section 335(2) of the Greater London Authority Act 1999).

This seems a major cock up by the ministry in not giving a period of grace post NPPF amendment.

The policy change of course cam about because of the North Essex Garden Communities fiasco where units planned beyond the end date of the plan counted for nothing.

Lets out this into context. The Gatwick Diamond area, apart from being the least constrained area in the London to Brighton corridor is also an area of major growth. Horsham and Crawley then are going to have to mop up growth constrained by the sea and South and North downs.

Oddly Horsham itself was planned for no new strategic allocations (other than redevelopment of a retail park and adjoining land)- bizarre, and the only rail based strategic site was a relatively small one based at Billinghurst. Eastwards expansion of Crawly was put in as a major area of search for long term growth, which seems much better than a car based new settlement at Buck Barn, based at the interection of the two major roads in the district it would be entirely car based, and at 3-3,500 units far too small to be relatively self contained or meet overspill needs of the South Coast.

A 30 year vision needs to be looking at a new settlement or major expansion of Crawley or Horsham of at least 25,000-30,000 homes, rail based at Christs Hospital, Billinghurst or Faygate. Buck Barns, very controversial, is only in because members blocked a site at Rookwood Golf Club within the inner ring road.

What is needed is a strategic study across Sussex for 30 year horizon zero carbon locations for development.

Just how much frontloading is needed for Zoned Sites?

An issue that frequently comes up is that more frontloading is needed for zoned sites.

I would frame the issue like that. Is any more frontloading required for a zoned site, where only the principle of development and number of units is in a local plan compared to avoiding costs on an appeal on an outline application refused despite being allocated in a conventional local plan.

Less – probably.

In order to be sure that the number of units in a draft allocation is ‘deliverable’ the LPA and the site promoter need to put in a minimum amount of work. If there are habitats issues they need to be sure conditions on SANG etc. can be delivered. They need to know how much of the site may be undevelopable because of protected species etc. They need to know the access to the site can deliver the number of units.

On a large site in outline only it is normal not to reserve the main site accesses in order to test and prove the site capacity. The highways authority should be giving advice on this anyway.

If you have allocated a site where the sequential flooding test applies you don’t need to do it again.

A minimum of habitats work needs to be done anyway as part of the AA of a development plan.

So some additional work is needed but no more than good practice in determining if a site is deliverable, and probably less in cost if an LPA refuses an allocated site and is awarded costs against them on an appeal.

Of course you could really front load costs and work with LPA funded masterplanning, but that is an optional extra, masterplans and design codes can and should be required by LPAs for large allocated sites prior to outline approvals come forward.

The concern I fear about frontloading comes from poorly resourced authorities who are unable to do the work on many small and medium size sites to demonstrate they are deliverable, and so are forced to allocate a large buffer of sites in the expectation that many of them will not be.

SoS to be given powers to call in cases where EA advice on flooding ignored


New powers will also be given to the Housing Secretary to block “inappropriate development” on land threatened by flooding.

The Government is introducing the reforms after 866 homes were granted planning permission in 2019/20 despite formal warnings from the Environment Agency (EA) about flood risk.

Mr Eustice revealed that new guidance would be issued to “drive up compliance” with flood advice by forcing local planning authorities to refer decisions to Robert Jenrick, the Housing Secretary, in cases in which the EA has raised an objection on those grounds

Alongside Robert Jenrick, the Communities Secretary, I am announcing that new guidance will be issued to drive up compliance with planning rules to ensure that local planning authorities refer planning decisions to ministers when the Environment Agency is sustaining an objection on flood risk so inappropriate development is guided away from flood risk areas. 

Cressingham Estate Redevelopment Quashed over Failure to Examine Heritage Issues

Several times we covered Lambeth’s crazy plan to demolish 3 of the finest Council estates in London all of which should be conservation areas. BTW in London EH can do moe than recommend they re declared conservation areas, they should declare them.


Lambeth Council has quashed the planning permission it gave to one of its controversial estate regeneration schemes, instead of fighting a legal challenge from residents

In February, Lambeth’s planning committee approved plans by Homes for Lambeth, the local authority’s wholly-owned housing company, to demolish 12 homes on the Cressingham Gardens estate.

Last week it was announced that residents had been granted a judicial review of the scheme, which would have been the third legal challenge over the Ted Hollamby-designed estate’s regeneration.

Residents had launched a crowdfunding campaign to raise money for the challenge but yesterday (21 July) the council took the surprise decision to cancel planning permission for the scheme, instead of spending more taxpayers’ money in court.

The challenge would have focused on whether or not the council had properly considered the heritage aspects of the regeneration scheme, which was drawn up by Conran and Partners.

Instead of a court battle, the council said Homes for Lambeth would commission a further heritage assessment, which will then be submitted to the planning authority. The council will then need to re-consult all interested parties.

A Lambeth Council spokesperson said it regretted the scheme would be delayed but added: ‘We’re not prepared to spend more taxpayers’ money contesting a challenge that could end up delaying these new homes for at least another year while we wait for a court date.

‘Quashing the original permission, and ensuring that an updated plan is put before the Planning Applications Committee, is the cheapest and quickest way of resolving this issue in the interests of everyone in Lambeth.’

Residents fought the latest demolition plans, arguing that the council was seeking to ‘salami-slice’ the estate by securing approval for piecemeal demolitions.

Then in 2016 the council was challenged again over its decision to approve redevelopment, but a judge ruled the council had acted lawfully.

In 2020, the mayor of London withdrew about £35 million from three estate regeneration schemes in south London, including Cressingham Gardens, after they slipped behind schedule.

The estate has already brought two legal challenges against the council. In 2015, Lambeth was forced to rerun a consultation after a court ruled an option for refurbishment had been unfairly dropped.

The funding withdrawal means the council will now have to ballot residents on its plans for Cressingham Gardens, if it involves the demolition of any social homes and the construction of 150 or more homes.

Cressingham was designed and built between 1969 and 1979 by a team of Lambeth Council architects led by architect Ted Hollamby. It comprises 306 homes arranged around a series of connected walkways.

Resident Jo Parkes of Save Cressingham Gardens said: ‘We hope that Lambeth will finally recognise the heritage importance of Cressingham and give it the conservation status that English Heritage suggested back in 2013, rather than wasting time and money on demolition proposals that do not have resident support.’

Doncaster Inspector Endorses Jobs Led Local Plan Target – So why isnt the Darlington Inspector?

Doncaster Inspector

.The significant uplift is intended to allow additional people to live in the
Borough to ensure a sufficient working population to take account of the
number of additional jobs that the Plan aims to accommodate. This is based
on reasonable assumptions about economic activity rates, unemployment,
double-jobbing and commuting. If all those assumptions are correct, and the
1% job growth were to be achieved every year of the Plan period, the
evidence indicates that nearly 1,100 new homes could be needed every year.
Such household growth would be broadly in line with the number of new
homes built in recent years, although significantly higher than the longer term
average level of completions,

Predicting household growth is not an exact science, and I am satisfied that
the uplift of over 60% from the standard local housing need figure is based on
proportionate evidence and can be regarded as aspirational but deliverable
given the number of homes built in recent years

This is exactly the same pretty much as Darlington – the chancellors poster child for levelling up – so why is the inspector such a different anti-jobs conclusion?

Buckinghamshire complains Aylesbury Link Dropped From East West Rail – Err you Withdrew from Arc Leadership Group, Actions have Consequences

MK Citizen

Councillors in Bucks have urged the government to commit to building a rail link between Aylebury and Milton Keynes.

‘The Buckinghamshire Line’ would be a spur line of the East-West Rail link and would provide easy access between MK and the county town.

The project would also include work to dual the track between Princes Risborough and Aylesbury

Councillor Mark Winn, who represents the Aylesbury East Ward of Buckinghamshire Council, said: “We welcome the £760m that the Government has announced it is investing in East-West Rail and the 1,500 jobs it will create.

“However, we remain concerned that this recent funding announcement did not commit to the completion of the proposed spur between Aylesbury and Milton Keynes. This spur was originally conceived as a key part of this project.”

Cllr Winn added: “So many residents in Bucks, not just in Aylesbury, but along the current route of the current Chiltern line in Buckinghamshire would benefit from the building of a North South railway along the entire length of the county and the dualling of track between Aylesbury and Princess Risborough.

“I am therefore urging government to rename this line “the Buckinghamshire Line” to reflect the significance to the whole of the county.

“The track is there, the need is there, but we now need the Government to put in the investment to get the trains running.”

Sadly Salcombe Proves Second Home Restrictions are Unworkable and Counterproductive

Devon Live

South Hams District Council, when they met last week, unanimously agreed an amendment to the existing neighbourhood plan for the picturesque town of Salcombe which would ensure that all newly built homes could only be used as a primary residence.

Around 57 per cent of homes in Salcombe are already classed as ‘second homes’, and a principle residency condition already applies in the existing neighbourhood plan for any new dwellings requiring them to be occupied by people with a local tie to the area.

But over a number of years, these ordinary planning conditions tend to get lost or are overlooked when a house is resold, councillors were told, allowing them to quickly become second homes.

Therefore, an amendment to the plan to strengthen the condition has been proposed and backed by councillors to introduce a legal condition on all new housing in the parish.

New open market housing will only be supported where there is a Section 106 agreement to ensure its occupancy as a principal residence, and the occupancy restriction will require the imposition of a legal agreement, the policy says, adding: “New unrestricted market homes will not be supported at any time.”

I used to belive in such restrictions. But now the evidence is clear NOWHERE where they have been tried have they worked.

The first point how are obligations more enforceable than a BCN. Nothing is as easy to enforce against as a BSN or breach of a conditions prescient following the rotherham case.

Thre really is one on situation where you would favour a s106 over a condition. Where you cant impose a conditions precient of x before y because you need to obligate a developer to x alongside y, such as building something as part of a phase. There is no point imposing an occupancy condition by obligation, indeed it is weaker as you are forced to go straight to EN or injunction. It is a condition wth a bonus prize of money for nothing legal fees to planning lawyers. Can any commentator here explain any befefit.

What is worse research shows such conditions are unenforceable or counterproductive.

St Ives for example

Falmouth Packet

A second home ban in the tourist hotspot of St Ives has backfired according to a new study – and priced locals out of the market.

Residents in the Cornish coastal town voted three years ago to ban the sale of new houses as second homes.

It was hoped that this would make housing more affordable for local people who were being priced out of the market by wealthy summer-dwellers.

But a fresh report has claimed the reality of the ban has had an opposite impact – and has made the situation worse.

The study by the London School of Economics argued the bans have been damaging to the local construction and tourism industries.

It is claimed it has caused the pool of available homes to shrink as house builders walked away – leading to even higher prices.

And with the demand for second homes remaining sky high, the ban has just moved focus away from new builds onto the limited stock of existing primary residences.

Professor Christian Hilber, who led the study, said: “In St Ives, where primary homes can easily be converted into second homes, demand has switched from new-build to existing homes and, possibly, to other nearby towns.

“This has led to an increase in the price of existing homes as summer dwellers are competing for existing homes with local residents.”

He said he believes the ban could increase the ‘ghost town effect’ and be detrimental to local people.

He added: “Tourist towns face a fundamental trade-off. They can restrict second home investors, with possibly positive effects on amenities and affordability.

“But this always comes at the cost of a significant adverse effect on the local economy. Any policy that succeeds in keeping second home investors away will hurt the local economy, mainly the tourism and construction sectors.”

He believes a better option would be a local annual tax on the value of a second home.

He says this could generate revenue for the local authority which could then be used to provide or improve services.

If you must use planning obligations impose one where every week a new build house is not used as a primary residence, including short term lets, impose a 5,000 pound charge and use the fines to build affordable housing, that would do it.

CPRE Oxfordshire Says Oxfordshire 2050 a ‘have it all tick box exercise’, ‘silent on the tough choices’ I agree

For once I agree. I have previous ciriticised this here and on twitter as ‘all must have prizes’ planning designed to avoid triggering anyone (which of course produces entitled cry babies).

Oxford Mail

Countryside charity CPRE have attacked the public consultation on the Oxfordshire Plan 2050 as “an unrealistic, ‘have it all’ tick box exercise”.

The plan will guide the development of Oxfordshire for the next 30 years.

The next stage in its formation is to ask residents to consider policies on climate change, improving environmental quality, creating strong and healthy communities, plans for sustainable travel and connectivity and creating jobs and providing homes.

A public consultation on the plans, which is one of the commitments made by all six Oxfordshire authorities as part of the £215m Housing and Growth Deal, opens on Friday July 30 for 10 weeks.

CPRE Oxfordshire said while it was supportive of the Oxfordshire 2050 Plan in principle, it was concerned that the consultation document was not ‘fit for purpose’.

Helen Marshall, director of CPRE Oxfordshire, said: “The Plan document does not attempt to address what level of growth is consistent with protecting our environment and rural character.

“It talks about ‘good growth’ but makes no clear assessment of the different impacts of the three options (the lowest of which is still 50 per cent above actual need) or the five spatial options outlined.

“It is not only silent on the tough choices that will be needed between meeting targets for carbon and nature and the push for economic growth but implies that we can effectively have it all.”

She said it will let the Arc dominate.

“As the Oxfordshire 2050 documents euphemistically put it, that will ‘be an increasingly important influence’.

And it will undermine the role of our local councillors as “we are presented with a wide range of policies (albeit many very desirable) which are to be imposed on all our local councils because otherwise ‘different approaches might be taken and this could result in less certainty and clarity for developers’.”

Ms Marshall said there should be a revised consultation document, “or at the very least an additional paper, that sets out the preferred growth and spatial options and provides adequate information to allow the impacts, risks and benefits to be compared.” [cough cough as statutorily required by the SEA regulations – why is this so hard]

“Environmental constraints must be a key consideration,” she said. “We need a plan that assesses the growth the county can bear within the constraints of maintaining its rural character and environment.

“A plan to ensure we don’t lose this character whatever Government seeks to impose.”

By the way of course the best way of maintainig rural character is concentrating development into large Garden Citties so 90% of the County remains rural. The worst way is developing so little that all the roads into Oxford and Science Vale become congested and polluted by people driving into work.

What does the focus on ‘overheating’ mean for Strategic Planning

Boris’s recent speech on ‘levelling up’ had a strong focus on ‘overheating’ in a spatial, rather than national economic sense, it is many years, since the mid 1980s, that we have heard much of that in planning.

Then we had a couple of examples. In Hampshire it had a no growth policy, restricting economic growth in case it generated more need for housing. A few counties such as Hertfordshire briefly adopted similar policies. SERPLAN also adopted a special policy for the so called ‘Western Arc’ west of London, where defense orientated industries were the major growth force. Neither lasted long in the face of GOSE objections.

In economics ‘overheating’ means price rises when shortages of a factor of production, land, labour or capital, leads to excessive rises in cost. Then the owners of that factor can charge a scarcity price for that factor, reducing overall consumer surplus in favour of excess profits and rising economic inequality.

In spatial terms the key issue is the reason for the shortage. Labour shortage can be caused by shortage of land for housing. The key issue is what causes the shortage, lack of land allocated for housing, lack of infrastructure so housing lags behind economic growth or a genuine shortage of lack of land suitable for housing. The last of the three is rarest but does exist on coastal areas, islands and areas with strong nature conservation and landscape constraints.

Thinking for two generation had been shaped by the flawed analysis of the Barlow report. It commissioned two background papers by pioneer of economic geography Sir Donald Mc Dougall, later head of the Government Economic Service and author of George Brown’s National Plan.

Dr Daniel o Donohue

The regional policies that followed the Barlow Report were heavily influenced by papers written for the Barlow Commission by Sir Donald MacDougall. The first of these papers was included as an appendix to the report itself and introduced the shift-share methodology to the analysis of regional employment growth, and has subsequently been shown to be flawed.

The second paper considered the urban hierarchy and growth but was never fully developed. Consequently, post-war regional policy focussed on the contribution of industrial structure to employment growth (industry-mix effect) without fully taking into account the urban hierarchy or regional locations of that employment (region-effect).

This is very wonkish but very important, if you analyse shift share (the industry effect) without fully looking at the urban/region effect., you get spatial autocorrelation. What seems like excessive concentration (at the time) of small industries in London and the West Midlands, which by implication would creates new industry economies of they were restricted to grow and forced to move, has been shown by more sophisticated analysis to be just residues of an urbanisation effect. These cities had productivity advantages from their growth that declining cities lacked. What poorer areas lacked was fast growing cities as incubators for growing industries. The New Towns programme only partially locked onto this, it did well in Telford and Scotland, ok in Runcorn and spectacularly poorly in Peterlee and Skelmersdale (until recent years).

Of course overheating is only ever a concern at the peak of booms. In recessions it soon becomes forgotten.

What this means is a careful analysis of the causes of land shortages. No one for example could seriously claim in the relatively ‘left behind’ Thames Estuary that there is a shortage of land, it is just almost all the land needed to meet the growth needs is Green Belt, and there hasn’t been a plan since the 1960s to meet the infrastructure needs of the area.

In parts of Surrey though there are genuine constraints such as AONB and SPA, which requires other areas to mop up the growth. The areas suitable for major growth are few, a Crawley-Horsham supercity maybe, we just have to go for if the housing market London to Brighton is not to overheat forever.

Beyond the Green Belt the ‘shortage of cities’ between the Metropolitan Green Belt and West/Midlands- South-Yorkshire needs acknowledging by creation of new cities in less constrained areas, like in the Arc, West of Swindon and South of Norwich. There are candidates in the North too, like around Crewe and a couple of satellite cities around York. The arc is just the start.

Just when did the Government Back Down from ‘1 million homes’ for Arc – or Have they Backed down at all?

The origin was the NIC report of course published alongside the Budget in 2017.

Which was criticised in the house a ciuple of weeks ago as being ‘balirite’ and ‘not conservative’ simply because Andrew Adonis used to be its chair. I.e. Go on Boris do another U Turn.

The Commission’s central finding is that rates of house building will need to double if the arc is to
achieve its economic potential.

If the arc is to maximise its economic potential, current rates of house building will need to double –
delivering up to one million new homes by 2050. It is equally important that new development
improves quality of life – this means engaging architects, developers and designers in the process of
building new homes in well-designed, liveable and connected communities which respect and enhance
the natural environment and the quality of life enjoyed by existing residents.
It is unlikely that this level or quality of development can be delivered if growth is focused exclusively
on the fringes of existing towns and cities, or through the development of small garden towns and
villages. Government and local authorities will need to plan for, and work with investors, developers
and housebuilders to deliver, large new settlements and major urban extensions – including the first
new towns in over a generation.

We have not had such a clear and simple statement since.

In the budget itself Hammond botched it.

Last week the National Infrastructure Commission published their report on the Cambridge-Milton Keynes-Oxford corridor.

Today we back their vision and commit to building up to 1 million homes by 2050.

Completing the road and rail infrastructure to support them.

And as a down-payment on this plan, we have agreed an ambitious Housing Deal with Oxfordshire to deliver 100,000 homes by 2031.

The speech didn’t mention why 1 million, nothing about job creation.

The red book was clearer

The government recognises the need, highlighted by the NIC’s report, to build up to 1 million new homes in the area by 2050 to maximise its economic potential, starting with a housing deal with Oxfordshire for 100,000 homes by 2031, and working with Central and Eastern sections on commitments in 2018. The government will also consider significant
new settlements and the potential role of development corporations to deliver these using private finance.

Note this was referring to the research element of the NIC report. As a need figure based on the transformational economic model projection plus an element of overspill from land constrained areas in and around London and other constrained town in the south east. A need figure NOT a target. The chancellors speech made it a target, probably without proper consultation with MCHLG.

Things were more nuanced in the 2018 red book

The government supports the NIC’s ambition to deliver up to 1 million new homes in the Arc by 2050 to maximise sustainable economic growth. The government recognises that the environmental requirements to underpin sustainable growth need to be considered at a pan-Arc level, and that the Arc is valued for its wildlife and natural
places. The Arc is an opportunity to demonstrate the ambitions of the government’s 25 Year Environment Plan.

Note this was the Budget where the Government made its full policy reponse, as opposed to initial reaction, to the NIC report.

So when the May government fell was there a change – well no.

Look at the March 2019 Government ambition and joint declaration between Government and local partners.

Signed by none other than Robert Jenryk.

Following its response to the National Infrastructure Commission’s report on the Arc in October 2018, the Government re-affirms in this document its long-term economic ambitions for the Arc, including an ambition for up to one million high-quality new homes by 2050, to tackle the severe housing affordability issues faced by many, and unlock the Arc’s full potential.

Note this was a government AMBITION, not a shared one, nor a government target or a shared target.

However every single government policy statement since has not mentioned a number, rather they all say

‘housing needs to be met in full’

Picher has twice said in parliment, its not a target

I have always been at pains to express that this is not about house building; it is about economic development of a very large region for jobs, skills and the transport and other infrastructure required to build the hopes and opportunities of the people who live there. It is about housing too, but housing is not the central thrust of what we are trying to achieve. When I hear talk from the Chamber of 1 million additional homes, points that were made in a report of some five years’ standing, I reply by saying that is not a Government target and it is not a Government policy.

I pointed that out to my hon. Friend the Member for North East Bedfordshire in this Chamber, but I suppose the best way to keep a secret is to make a statement in the House of Commons. I think the only way that we can put to bed or break open this particular secret is to keep repeating the point that 1 million homes is not a Government target. More homes are what we need and require, because in certain parts of the arc space, Cambridge being an example, average house prices are 12 times the average salary of a local resident. In other parts of the arc, house prices are as expensive, so we do need to build more homes with the right infrastructure for the people who need to live in this space.

Lets be clear about this.

Since the 2018 Budget the government has never described it as a target but an Ambition.

Jenryk has used that phrase and never withdrawn it.

The govrnment has described the NIC report as a needs figure, the description of a ‘report of 5 years standing’ is not disowning the NIC report but simply describing that the evience is 5 years old. Almost certainly with the new census the need will be much higher.

The government has never withdrawn the statement that the one million figure is an ambition.

All Pincher has done is stated the one million figure was not a government target, which it has never been since 2018.

So is it still a government AMBITION. Of course if Jenryk withdraws this what incentive is their for local leaders to keep their half of the joint declaration. If the government withdraws its ambition local authorities will reduce housing numbers and still say, give us the growth funding as its no longer part of the deal.

Hence why its much more important to look at what Pincher did not say rather than what he did say.