Savills for Crest Strategic

Inspector’s Matter 14
Savills for Crest Strategic Projects Ref. 846932
Horsham District Council
Horsham District Planning Framework (HDPF) Examination
Examination in Public (EIP)
EXAMINATION STATEMENT
Crest Strategic Projects
Submitted 17 October 2014
Matter 14: Crawley Extension Sites
14th November 2014
Crest Strategic Projects Examination Statement 6 (Reference 846932)
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Matter 14: Crawley Extension Sites
14th November 2014
Introduction
This Examination Statement has been submitted by Crest Strategic Projects (CSP) as part
of the Examination in Public on the Horsham District Planning Framework (HDPF) 20112031.
The Statement highlights and where necessary expands upon representations
submitted by CSP at the Proposed Submission (Regulation 20) stage of the HDPF process.
It does not repeat representations but responds to the Inspector’s questions. In respect of this Matter 14, the Statement is made in respect of CSP’s land promotion at
West of Kilnwood Vale (SA341).
Please note: A List of Alternative Sites was published by Horsham District Council (HDC) in
September 2014. This quotes land west of Kilnwood Vale as ‘SA341’. This is not consistent
with SHLAA (August 2014) which quotes the site as ‘SA291’. For clarity:
The land promoted by CSP is that outlined by SA341, this extends to circa 192 hectares
excluding the developable land.
The potential housing land includes part of SA291, which is incorporated within SA341
which extends to circa 34 hectares. The developable land within this extends to 21.81
hectares which therefore includes part of SA291.
Referencing
Crest Strategic Projects has referred to its representations submitted on the Proposed
Submission ‘Publication’ HDPF throughout the Examination Statement.
Appendices
1.
Crest Strategic Projects Representation: Crawley Local Plan (13 October 2014)
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Inspector’s Questions
41.
Should any/all of the omission sites be preferred, taking into account all of the
relevant factors including: sustainability of location, environmental impact,
infrastructure provision, viability and deliverability?
41.1
Land west of Kilnwood Vale (WKV) should be allocated for development (part of
SA341) via a Main Modification to the plan, and redrafted SA/SEA.
41.2
The NPPF requires that Horsham District Council (HDC) ‘significantly boost’ the supply of housing (@ para 47). This is in order to ensure choice and competition in
the market for land. It is not a case of ‘preferring’ one site to another, but instead robustly assessing the promoted sites to ascertain which are the more sustainable in
the context of achieving and exceeding the planned level of housing. Local Plans
should plan positively, and allocate sites to promote development and flexible use of
land (@ para 157). No cogent or technical reasons for not allocating part of SA341
have been provided by HDC. Part of the site has been dismissed as not suitable for
development in the 2014 SHLAA (SA291), yet no obvious assessment has been
made of SA341.
41.3
SA341 includes the opportunity for:
A logical extension to the consented land at West of Bewbush (Kilnwood Vale),
the delivery of which is underway.
21.81 hectares of developable land - equating to 750 dwellings.
Extensive greenspaces, including environmental mitigation and buffers (circa
11.98 hectares).
More extensive greenspaces, to be dedicated as an in-perpetuity Country Park,
separating Faygate from Crawley, and performing a long term separation of
Crawley and Horsham (scale and management to be confirmed).
41.4
This is all detailed within a Technical Appraisal dated May 2012, included at
Appendix 1 of CSP’s representations. This evidence has been with HDC for over
two years.
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41.5
Savills for Crest Strategic Projects Ref. 846932
Crest Strategic Projects (CSP) has outlined significant concerns in respect of the
approach to housing, neighbourhood planning and the SA/SEA in Statements
relating to Matters 1, 2 & 6. This Statement focuses on the benefits of the proposed
allocation on WKV. The land is available, suitable and achievable. It is developable
and can contribute to the 6 – 15 year housing land supply.
Crawley’s unmet Housing Needs
41.6
There is historic precedent of both Crawley Borough and Horsham District Council’s working collaborating on the Joint Area Action Plan (JAAP) to accommodate housing
needs.
41.7
CSP has recently submitted representations on the Crawley Borough Local Plan (pre
submission version), the front end of these are included at Appendix 1. In summary:
Crawley Borough Council’s approach to housing needs is inconsistent with its approach to employment, and also fails to account for the housing needed to
address affordability. It does not account for the objectives of the Coast to Capital
Local Enterprise Partnership (LEP).
Therefore, Crawley’s objectively assessed needs are likely to be in the order of
650 dpa against urban capacity of 326 dpa - a greater unmet need.
The Crawley Local Plan should include a clearer policy commitment to embrace
potential urban extensions.
41.8
Regardless of whether or not Crawley amends its opinion on the objectively
assessed level, even at their stated level of 535 dpa, there are still unmet needs
which need to be accommodated in either Horsham or Mid Sussex. This is
acknowledged in Crawley Borough Council’s evidence base (Duty to Co-operate
Statement – August 2014). A shortfall of circa 105 dpa is identified.
41.9
Furthermore, Mid Sussex is yet to publish a proposed level of housing in its re-draft
District Plan (2014-2031). A draft for Committee (October 2014) did however indicate
their present opinion that the housing level which would be required if demographics
and migration followed recent trends would equate to 516 dpa, which is no increase
on past assumptions.
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41.10 CSP is therefore of the opinion that the greater unmet needs of Crawley must be
factored in the HDPF. The obvious location for these needs to be accommodated is
on land adjacent to Crawley.
41.11 As a further footnote, Reigate & Banstead has acknowledged unmet needs (as
outlined in CSP’s representations/ Statement on Matter 6). The logical location
to accommodate HDC’s proportion of these would be within the north east of the District.
Sustainability of the Location
41.12 CSP has outlined in the Statement relating to Matters 1 and 2 that Crawley should be
recognised in the HDPF as a dominant and sustainable settlement, and hence
referred in the settlement hierarchy.
This would best reflect the present JAAP
allocation at Kilnwood Vale, and provide a positively prepared solution.
41.13 The proposed site allocation is medium to long term. It must therefore be viewed as
an urban extension owing to the present build out of Kilnwood Vale. The outline
consent for Kilnwood Vale is consistent with the JAAP/ Neighbourhood Principle and
hence delivers a range of infrastructure, notably:
Local centre/ retailing
Potential railway station with 200 car parking spaces
Primary School (2FE with reserve land for 3FE)
Community facilities (including healthcare and library)
Extensive formal and informal recreation
Integration with the Fastway Bus Network
41.14 HDC in the SHLAA update 2014 outlines for SA291 only that the site is unsuitable for
residential, and hence no dwelling capacity is attributed:
“The site adjoins the west of Bewbush strategic location and is being proposed
as an extension of this site. At the time permission was granted for 2,500
homes West of Bewbush, the transport assessment stated there was not any
capacity for development further west of the site. Development of this site
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would result potential coalescence of Crawley and Faygate and have a
significant impact on the landscape meaning it is not suitable for
development”.
41.15 CSP addresses the core concerns of the SHLAA assessment in turn:
Transport & Highways
41.16 Technical Highways evidence prepared by URS was submitted in May 2012, and is
included within Appendix 1 of CSP’s representations.
This assessed 750
dwellings, accessed via the new A264 roundabout now constructed for Kilnwood
Vale. No significant highways impacts were found, with enhancements identified.
41.17 WSP has more recently reviewed the URS evidence for CSP, which demonstrates
the following:
Pedestrian and Cycle Connectivity: The site is adjacent to the consented
Kilnwood Vale development. The A264 does not represent a barrier to movement
in connecting WKV with existing development, particularly for pedestrians and
cyclists.
The Kilnwood Vale development includes new pedestrian and cycle
connections that do not cross major road corridors into the Bewbush area in
western Crawley. Pedestrian connections can be provided at-grade.
Access to Public Transport: The proposed station at Kilnwood Vale can be
accessed on foot and by bicycle from WKV. The proposal for a railway station at
Kilnwood Vale has been supported in principle by Network Rail, following
submission of a Business Case. Public transport provision being delivered by
Kilnwood Vale will provide for logical extensions of services to WKV, not requiring
the introduction of new services and helping to strengthen the long-term viability of
existing services. The location of WKV will mean that public transport services are
able to make the most of connections to Fastway for journeys into Crawley.
Operation of the Highway Network: The transport assessment demonstrates
that the local road network can accommodate traffic resulting from the
development, with minimal effect on off-site junctions.
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Transport Serverance: Connections (at-grade) by foot, cycle and public transport
will be provided between the site, Kilnwood Vale, and Bewbush.
Coalescence
41.18 HDC alleges calescence of Crawley with Faygate, in addition to landscape impacts.
These points have not been quantified or qualified by HDC.
41.19 CSP’s first concern is the extent of the SHLAA assessment, as no summary is provide of the wider site area, SA341.
41.20 CSP provided a Landscape Capacity Study within the May 2012 evidence Appendix
1 of CSP’s representations. This highlights the visual containment of the proposed
developable area (21.81 hectares). As a direct consequence of the development,
addition greenspaces/ structural planting would be needed to the north and west to
assist delivery. This provides an in-perpetuity opportunity for an established and
landscaped gap. A positive approach to development would therefore achieve the
objectives of the gap between Horsham and Crawley.
The provision of an in-
perpetuity Country Park would provide the ultimate defensible boundary.
Environmental Impact
41.21 An initial response to environmental factors is all detailed within a Technical
Appraisal dated May 2012, included at Appendix 1 of CSP’s representations.
Infrastructure Provision
41.22 As WKV is a logical extension to the commenced Kilnwood Vale site, the transition to
enable delivery shall be relatively smooth. The infrastructure required to deliver the
site would be minimal in relative terms.
41.23 As outlined, there is a significant amount of infrastructure provided with Kilnwood
Vale, notably the opportunity to expand the primary education capacity to 3FE.
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Viability & Delivery
41.24 The land is controlled by the same landowner who has the long term interest in
Kilnwood Vale. CSP has interests in the wider area.
41.25 Based on the emerging affordable housing policy requirement of 35% (policy 15) and
proposed CIL rate (£125 per sq m), subject to the level of residual Section 106, CSP
can confirm the site as viable and deliverable in the medium term. The infrastructure
costs may be managed through phasing, and the site is not known to have any major
drainage or contamination constraints.
41.26 There is strong market potential in Horsham District, and wider unmet housing needs
to address, as outlined in the CSP Statement on Matter 6. Evidence was provided by
CSP with the representations on market capacity, indicating that a greater level of
housing may be supported (Appendix 2 of CSP’s representations).
The
development would be provided as a direct response to addressing Crawley’s unmet needs.
41.27 The phasing of development shall need to complement land at Kilnwood Vale. WKV
could deliver 100 dwellings in the 6 - 10 year period, without compromising delivery
at Kilnwood Vale. Beyond this, the majority of the site would come forward from
2024/25. The planning process would therefore need to commence in 2020/21.
41.28 The site would form logical addition to the medium to long term land supply.
Kilnwood Vale*
Years 1 to 5
Years 6 to 10
2013/14
2014/15
2015/16
2016/17
2017/18
2018/19
2019/20
2020/21
2021/22
2022/23
30 (delivered)
80
120
160
220
280
280
290
300
275
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Land west of
Kilnwood Vale
50
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Kilnwood Vale*
Years 11+
2023/24
2024/25
2025/26
2026/27
2027/28
2028/29
275
190
Land west of
Kilnwood Vale
50
150
200
150
100
50
*Based on HDC assumption on delivery as per Position Statement 5 – Housing (July 2014)
Other Sites Around Crawley
41.29 Land west of Ifield (SA101) has been promoted for a number of years, and formed a
competing site option when HDC/ CBC chose to allocate Kilnwood Vale via the
JAAP. SA101 is understood to comprise a 200 hectare site of which 2,500 dwellings
may be delivered over 62 hectares. The major constraint with the delivery of this
land is access, and the prospect of a second runway at Gatwick Airport. These
matters shall need to be overcome, which may well necessitate a plan review.
41.30 HDC does not consider this land to be developable in the 2014 SHLAA update:
“There are a number of constraints on this site which make the site unsuitable for development at the present time. The site is located within Flood Zones 2
and 3 and is part of the Airport Safeguarded area for a second runway at
Gatwick Airport. The land also adjoins Ifield Conservation Area meaning
development could adversely impact the setting of this area. At this stage
development is severely constrained by access to the site and while this could
be overcome, the proximity of the site to the proposed allocation of 2,500
homes on land North of Horsham could mean that the viability of the scheme
could be compromised in the short term due to a saturation of the market in
this area. Development of this land would also need to be brought forward in
partnership with Crawley Borough Council. Due to these constraints and
issues, the site is assessed as not currently developable at the present time”.
41.31 CSP disagrees with HDC’s argument in respect of market capacity, as this is unsubstantiated. It is clear though that major constraints to the delivery of West of
Ifield exist. The site would likely need a western bypass to come forward, the option
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for which has not been pursued by West Sussex County Council post adoption of the
JAAP.
41.32 The other promoted site is land off Rusper Road (SA468). CSP is neutral in respect
of the site, and simply wishes to note that the available capacity is outlined by the
2014 SHLAA update as 80 dwellings. It is therefore not strategic and not able to
substantially address the unmet needs.
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Conclusions
What parts of the HDPF are unsound?
The absence of a development allocation for the CSP site land West of Kilnwood Vale is
unsound (SA341). It is not a matter of whether this site is ‘preferred’; the site is required to
meet the pressing housing needs, and deliver homes over the plan period, notably the
unmet needs of Crawley.
Which NPPF tests of soundness it fails and why?
The HDPF fails all four test of soundness prescribed by the NPPF (@ para 182). It is
ineffective as acknowledged, available, suitable, and achievable land in a very sustainable
location has not been allocated for development. It is unjustified, as the SA/SEA test is
flawed, subjective and fails to properly recognise the key attributes of the promotion. It is not
positively prepared, as the clear opportunity to embrace a site to meet the overall housing
needs have not been taken. The HDPF is therefore inconsistent with national planning
policy.
How can the HDPF be amended to ensure soundness?
The failings may be deemed fundamental to warrant rejection of the HDPF and hence trigger
a potential re-write of the Proposed Submission. Should the Inspector consider that the
HDPF can be made sound via Main Modifications then the following is requested:
Part of the area SA341 would form part of a new allocation for residential-led
development for approximately 750 dwellings, to be accessed from the existing A264
roundabout, and to be integrated with the consented proposals at Kilnwood Vale. An
element of the SA341 allocation should be incorporated as a country park/ strategic
green space.
The SA/SEA should be amended to re-assess the site objectively including the SA341
area which has been promoted since 2012. The amendments should include:
o The positive impact on housing provision including affordable at a policy compliant
level (35% rather than the assessments of 30% and 40%).
o The opportunity to embrace education capacity including a third form of entry at the
proposed Kilnwood Vale school.
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o Positive leisure and recreation benefits notably via the proposed Country Park.
o Fair assessment of archaeology and cultural heritage.
o Fair assessment on the impacts on equalities and social inclusion.
o Positive effect on biodiversity and management.
o Neutral impact on landscape via design.
o Positive transport benefits owing to infrastructure and public transport improvements,
and overall accessibility of the location.
In addition, the infrastructure and potentially CIL evidence should be amended to justify
the site allocation.
The housing trajectory amended to include 100 dwellings in the land supply period
2019/20 - 2023/24, and the full site build out prior to 2031.
END
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Appendix 1: Crest Strategic Projects Representation: Crawley Local
Plan (13th October 2014)
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REPRESENTATIONS ON THE CRAWLEY BOROUGH
LOCAL PLAN 2015 - 2030
SUBMISSION CONSULTATION DRAFT
Prepared for:
Crest Strategic Projects
Land East of Billingshurst
Land West of Kilnwood Vale
Savills
2 Charlotte Place
Southampton
SO14 0TB
023 8071 3900
October 2014
Contents
1.
INTRODUCTION ............................................................................................... 4
2.
REPRESENTATION ......................................................................................... 7
3.
CHANGES REQUIRED TO MAKE THE PLAN SOUND ................................ 25
APPENDIX 1: LAND EAST OF BILLINGSHURST SITE SUMMARY ..................... 27
APPENDIX 2: A TECHNICAL APPRAISAL OF LAND WEST OF KILNWOOD
VALE (SAVILLS, MAY 2012) .................................................................................. 28
Land East of Billingshurst
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Executive Summary
Crest Strategic Projects (CSP) is promoting deliverable sites that may contribute to meeting Crawley
Borough Council’s (CBC) unmet housing needs.
Within the Northern West Sussex Housing Market Area (NWSHMA) there is an identified shortfall in
housing provision, primarily resulting from under provision within Crawley Borough. There is a wider
shortfall in housing provision arsing from unmet needs within the Sussex Coastal Housing Market
Area, Reigate & Banstead and Greater London.
CBC’s objectively assessed estimates of required housing provision within Horsham District and Mid Sussex District are not sufficient to cater for Crawley’s unmet needs. CBC has failed to demonstrate
that effective co-operation and joint working has been undertaken within the Housing Market Area to
ensure that there is adequate housing provision within existing or proposed Local Plans to cater for
this unmet need.
Furthermore the Strategic Housing Market Assessment that justifies the Crawley Local Plan (CLP) is
outdated and predates the Planning Practice Guidance (PPG).
As a result it is considered that
Crawley’s objectively assessed housing need is greater than that put forward in the draft Local Plan.
In order to demonstrate that CBC has met the Duty to Co-operate, the Authority will need to more
positively embrace potential urban extensions to the town within adjacent Authority areas. This needs
to be reflected in the vision, and policies on employment, housing and infrastructure.
Furthermore, the given objectively assessed housing need within the CLP (535 dpa) is unlikely to
provide enough housing to meet the employment growth aspirations of the Borough, as the proposed
level only supports 399 new jobs per annum (B-Class), and falls considerably short of meeting the
total baseline Economic Growth Assessment (EGA) level (16,440 jobs/ 822 jobs per annum).
Furthermore this assessed housing need will not provide a suitable amount of affordable housing to
meet the demands of the current waiting list, and therefore this figure would be most suitably stand at
630 dpa. Overall the objectively assessed needs are likely to be in the region of 650 dpa.
In order to comply with the Coast to Capital LEP and Gatwick Diamond economic growth aims, CBC
will have to demonstrate a higher provision of B-Class employment land, above the 77.2ha
recommended within the CLP. This needs to be supported by a credible objectively assessed housing
need, in order that across the sub-region, Authorities pro-actively act to deliver new homes.
Land East of Billingshurst
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Land East of Billingshurst
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1.
Introduction
1.1.
On behalf of Crest Strategic Projects (Crest), Savills is responding to Crawley Borough
Council’s (CBC) Submission Consultation Draft Crawley Borough Local Plan 2015 - 2030
(CLP), published September 2014, which will, once adopted, comprise the Local Plan for the
town.
1.2.
CSP has a successful track record of creating pleasant and sustainable communities through
a commitment to high quality design and the integration of appropriate physical and social
infrastructure to support their schemes. A case in point is the Kilnwood Vale development,
which is under construction and will deliver circa 2,500 new homes in Horsham district, but as
an urban extension to Crawley.
1.3.
The Government, through the National Planning Policy Framework (NPPF), is seeking to
greatly increase the amount of housing being provided across the country. In light of this it is
necessary for Local Planning Authorities to objectively identify and sustainably address local
housing requirements. This task must be taken in the context of a Duty to Co-operate and
hence be ‘more than local’.
1.4.
CSP wishes to promote sites that are sustainable and will be successful in contributing to
meeting the identified housing needs of the Northern West Sussex Housing Market Area
(NWSHMA). Crest is promoting sites in Horsham District which are now omission sites, as
they are not proposed for development by the Horsham District Planning Framework (HDPF)
and as such may not contribute towards meeting the identified unmet housing need arising
from Crawley Borough (Land East of Billingshurst and West of Kilnwood Vale).
Land East of Billingshurst
1.5
Land East of Billingshurst (refer to Figure 1, Appendix 1) is 26.1 hectares in size and lies
within the countryside and comprises a number of fields, which are in agricultural use and also
an area of semi woodland/ scrubland. The site is located between Coneyhurst Road (A272)
and the eastern settlement boundary of Billingshurst. Detail related to the site is included in
Appendix 1.
Land East of Billingshurst
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Land West of Kilnwood Vale
1.6
Land West of Kilnwood Vale covers an area of approximately 33.79 hectares and is located to
the east of Horsham and is an extension of the allocated Kilnwood Vale neighbourhood to the
east, with Bewbush, Crawley further east of this and Faygate to the west and extends from the
A264 in the south to Ifield golf course in the north. It comprises agricultural fields, woodland
and a recreational sports pitch. The mainline railway line runs through the southern section of
the study area along an east-west axis. To the north is the Ifield golf course with a number of
woodland areas and to the south is an Area of Outstanding Natural Beauty comprising
woodland, grassland and agricultural fields. Detail related to the site is included in Appendix
2.
1.7
The following section sets out detailed representations to the draft CLP.
Land East of Billingshurst
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2.
Representation
2.1
Crest objects to the draft CLP as, in its current form, the Plan is considered to be unsound.
These representations focus upon the following Plan aspects:
Duty to Co-operate
Objectively Assessed Housing Need
Employment Land
2.2
Changes are therefore requested to the vision/ key diagram, employment policy (EC1) and
housing policy (H1).
Duty to Co-operate
2.3
Paragraph 47 of the National Planning Policy Framework (NPPF) states that Local Planning
Authorities (LPA) should “... use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area
...” Should an Authority’s evidence show that there is an unmet housing need, it is the duty of
the Authority to utilise the Plan preparation process to identify a solution.
2.4
Crest’s position is that Crawley’s evidence shows that there is a clear unmet housing need in
the Borough and CBC has failed to identify a workable solution.
2.5
Paragraph 1.35 of the CLP states that “Crawley cannot meet the housing and employment needs of a growing population within its own boundary in full”. As stated in the Council’s evidence base (Topic Paper 5: Unmet Needs, paragraph 2.10): “Based upon the most up-todate figures, the shortfall between the objectively assessed need and housing supply is
anticipated to be 3,130 dwellings.” (209 dpa). Policy H1: Housing Provision in the CLP makes
provision for the development of at least 4,895 net dwellings in Crawley over the period 20152030 (326 dwellings per annum (dpa)).
2.6
Whilst Crawley’s stated objectively assessed housing need of 535 dpa is to be questioned in
these representations, a further key issue to be addressed is whether CBC has effectively cooperated with other bodies to enable the identified unmet housing need to be addressed.
2.7
Crawley’s Duty to Co-operate Statement (August 2014) (DTC) states at paragraph A.7 that:
“Crawley’s housing market functions within a wider housing market area (HMA) known as the
Land East of Billingshurst
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northern West Sussex HMA”.
As a result a Joint Strategic Housing Market Assessment
(SHMA) was commissioned by the NWSHMA authorities, CBC, Horsham District Council
(HDC) and Mid Sussex District Council (MSDC), first in 2009 and updated in 2012. As stated
in the joint SHMA: “This evidence highlights the strong relationships between the authority areas as a functional housing market.” However, the joint SHMA pre-dates the Planning
Practice Guidance (PPG).
2.8
The NPPF clearly outlines (paragraphs 178 - 182) the duty of local authorities to co-operate
on planning issues that cross administrative boundaries. The NPPF highlights two key plan
making criteria in paragraph 181:
“Local Planning Authorities will be expected to demonstrate evidence of having effectively cooperated to plan for issues with cross boundary impacts ...” and;
This co-operation should result “... in a final position where plans are in place to provide the land and infrastructure necessary to support current and projected future levels of
development.”
2.9
It is considered that CBC has failed to demonstrate evidence of effective co-operation and that
this has resulted in plans not being in place to provide necessary land and infrastructure. For
example Crawley’s Topic Paper 5: Unmet Needs states at paragraph 4.4 that (Savills underlining):
“Crawley’s Local Plan confirms that, despite the constrained nature of the borough,
approximately 60% of the objectively assessed housing needs and, at least, 50% of the
objectively assessed economic needs over the period to 2030 will be accommodated within
the borough boundaries. This will mean housing and economic growth will be broadly
balanced, albeit that the total needs for both cannot be met. The majority of the shortfall can
be captured within close proximity to Crawley’s boundaries through current planned development proposals. In addition, some of the identified future speculative development
could come forward, particularly to meet the longer term needs arising from the growth of the
town ...”
2.10
The above statement clearly demonstrates a lack of effective co-operation and plan creation.
2.11
Firstly, the currently planned development in adjoining boroughs that is referred to is, under
the current and proposed Plans, required to meet the needs of those authorities. Should this
development provide for Crawley’s shortfall, the result may only be the creation of a shortfall
Land East of Billingshurst
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in provision within the host authority.
2.12
Secondly, the claim that some of the future speculative development could come forward
places a reliance upon an unplanned possibility. The NPPF is very clear that identified unmet
needs should be met through the next Local Plan, meaning the one that is in preparation, and
not through reliance upon subsequent Plans. Even were it the case that certainty could be
given to development coming forward in the next but one Plan period, this can hardly be
considered as meeting current unmet needs. Additional land allocations are required.
Lack of Effective Co-operation
2.13
The DTC states on page 6 that, as a result of being unable to meet the identified housing
need within the Borough, CBC is “... working with other authorities to ensure that, so far as
possible, unmet needs are met within the wider housing market area.”
2.14
The NWSHMA authorities have signed a Joint Position Statement (JPS) setting out how they
have worked together on strategic planning matters. A key outcome of the JPS is that the
authorities recognise that the Local Plans currently in production will not meet the objectively
assessed housing needs of the NWSHMA. However, the JPS states, in paragraph 6.16 that
“[The authorities] each consider that they are doing the maximum reasonable to meet the objectively assessed needs of the area as a whole, taking into account local constraints, and
the need for sustainable development.”
2.15
The above statement is at odds with both the requirement of the NPPF that plans should be in
place to provide for developmental needs and the statement in paragraph 6.17 of the JPS that
the NWSHMA authorities “... will leave no stone unturned ...” to ensure that as much housing
as possible can be delivered in their boundaries.
2.16
Table 1 in the DTC sets out the NWSHMA authorities’ position on the objectively assessed
housing need and planned provision within the HMA. For ease of reference this table is
reproduced below.
Land East of Billingshurst
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Table 1: Objectively Assessed Housing Needs and proposed provision (per annum) – Northern
West Sussex Authorities
Mid Sussex
Crawley
Horsham
TOTAL
1,611dpa
Objectively Assessed Need
516dpa
535dpa
560dpa
1,506dpa
Proposed Housing Provision
530dpa
326dpa
650dpa
Source: Crawley Borough Council Duty to Co-operate Statement (August 2014)
2.17
As can be seen, based upon the stated figures, CBC states that the NWSHMA’s housing shortfall results from the significant under provision in Crawley, but that this is partially allowed
for by (alleged) overprovision within Horsham.
However, Table 1 is not considered to
represent the reality of housing needs and supply in the NWSHMA. Rather, the objectively
assessed housing needs are substantially higher than stated, resulting in a much bleaker
picture of unmet housing need across the NWSHMA. This is outlined by the local authority in
the subsequent paragraphs.
2.18
Furthermore, consideration of housing needs across the wider southern region, incorporating
unmet needs arising from London and the Sussex Coast HMA, places yet further pressure on
the NWSHMA authorities to identify land to meet strategic housing requirements.
Horsham
2.19
Horsham’s submission draft HDPF proposes a housing target of 13,000 dwellings over the Plan period (650 dpa). If adopted, the HDPF will form the Local Plan for Horsham District.
2.20
Public Examination of the draft HDPF is currently underway and a significant amount of
evidence has been submitted by a number of different developers/ landowners, including an
Examination Statement prepared by Savills on behalf of Crest Strategic Projects (CSP),
demonstrating that the proposed housing target of 650 dpa does not meet the District’s objectively assessed needs. It is considered that, to provide for elements of Crawley’s unmet need alongside that of London and the wider area, Horsham needs to adopt a housing target
in excess of 730 dpa. The objectively assessed level for Horsham alone is likely to be 700
dpa+.
2.21
An extract from CSP’s Examination Statement relating to Horsham’s objectively assessed housing need taking into account employment growth is reproduced below:
“In 2012 HDC commissioned a report from DTZ titled “How Much Housing Does Horsham Need?”. Although this document did not give a precise figure of housing requirement it outlined the suggestions made to the Council by various private bodies and companies.
Land East of Billingshurst
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This report also stated the options created by GL Hearn in the 2011 Update of the Locally
Generated Needs Study (LGNS):
Option 1: 635 homes pa (+12,700 homes): The report notes that this option is based on
the ‘baseline’ employment scenario, which allows total growth in District based
employment of 3,000 jobs over the period 2011-31 (+4.5%), based on assumption of a 1to-1 relationship between growth in jobs and labour supply.
Option 2: 670 homes pa (+13,400 homes): The report notes that this option is based on
the ‘successful repositioning’ employment scenario in the Employment Land Report, which allows total growth in District based employment of 3,880 jobs over the period 2011-31
(+5.9%), based on assumption of a 1-to-1 relationship between growth in jobs and labour
supply.
With respect to Option 2, the report notes that job growth beyond the District boundaries
and wider sub-regional market dynamics could create additional demand pressures for
housing provision within the District, particularly taking into account commuter dynamics. In
the light of this, GL Hearn recommend two additional options for testing which would
provide a stronger contribution to meeting wider sub-regional development needs and
supporting economic growth across the Gatwick Diamond.
Option 3: 730 homes pa (+14,600 homes): This would allow total growth in District based
employment of 5,500 jobs over the period 2011-31 (+8.4%). GL Hearn note that this level
of housing provision is higher than that implied by the CLG 2008 household projections
(c680 dpa) (which now stand at 690 / 699 dpa based on the 2011 household projections).
Option 4: 820 homes pa (+16,400 homes): The LGNS indicates that this would test what
the theoretical development capacity of the District might be; and that it implies a rate of
housing growth of 1.5% pa which GL Hearn regard as the maximum that could realistically
be achieved in the absence of significant public sector support for infrastructure
investment.
A range of 635 - 820 dpa was therefore assessed, with at least 730 dpa standing as a level to
achieve employment growth. This excludes any further provision related to London, or unmet
needs from elsewhere.”
2.22
It is clear that the proposed housing target in the draft HDPF is not sufficient to meet the
District’s own needs, when factoring in the achievement of employment growth, let alone
providing for the unmet needs of neighbouring authorities, as is stated by CBC.
2.23
The lack of effective co-operation between CBC and the NWSHMA authorities is made clear
in Crawley’s 2014 SHLAA. The DTC states at paragraph A.26 that “joint work has progressed between the three northern West Sussex Authorities to identify the strategic sites and broad
housing locations across the Housing Market Area within the administrative boundaries of
Land East of Billingshurst
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Crawley, Horsham and Mid Sussex, which will be set out in a shared appendix to each
authority’s SHLAA.”
2.24
Appendix K of Crawley’s SHLAA – Strategic Housing Sites within the Northern West Sussex
Housing Market Area identifies only three strategic housing sites within Horsham as suitable,
available and achievable at the present time and, most importantly, states that “These sites have been allocated through the Horsham District Planning Framework (HDPF) to address
HDC’s identified housing need.
2.25
In actual fact only two have been proposed for allocation in the submission draft HDPF (Land
North of Horsham and West of Southwater). This implies that the potential existed, and had
been identified, for the demonstration of effective co-operation between HDC and CBC
through the additional allocation of Land East of Billingshurst for the express purpose of
contributing towards Crawley’s unmet needs. That this site has not been allocated in the
HDPF, and is only consented in part (475 dwellings), suggests that effective co-operation did
not take place.
2.26
A further point to note in relation to Horsham’s position on meeting unmet need is that whilst
the HDPF states in paragraph 6.6 (replicated in the DTC) that the new neighbourhood of
Kilnwood Vale, on the boundary between CBC and HDC, has accommodated some of the
needs of Crawley, by way of catering for in-migration, this is not actually the case. The
population and household projections, upon which the HDPF is based, already include cross
border and migratory flows. As such, the projections form the basis for calculating objectively
assessed need and the Kilnwood Vale development would only be contributing towards
meeting Horsham’s identified needs. Additional land may be required at Kilnwood Vale as an
apportionment of Crawley’s needs.
Mid Sussex
2.27
The draft Mid Sussex Local Plan (MSLP) went to Examination in November 2013.
The
submitted Plan proposed a housing target of 10,600 dwellings over the Plan period (530 dpa).
However, this figure was never tested as the Examination focussed upon whether MSDC had
met the Duty to Co-operate. MSDC was judged, by the Inspector, to have failed to meet the
Duty to Co-operate on the basis that they had not accounted for the unmet needs of the
neighbouring authorities, including Crawley. As a result, MSDC withdrew the draft Plan and is
in the process of preparing a revised version.
2.28
Table 1 in the DTC is based upon MSDC producing a revised Local Plan still only delivering
Land East of Billingshurst
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530 dpa. DCLG’s 2011 Interim Household Projections suggest that between 2011 and 2031
Mid Sussex will need to provide approximately 11,000 new dwellings just to meet the baseline
demographic need (567 dpa). Should Mid Sussex produce a revised Local Plan that is based
upon 530 dpa (as previously proposed), it is clear that, irrespective of meeting the needs of
Mid Sussex, it would not be contributing towards the unmet needs of Crawley (and likely not
its own needs either).
2.29
As stated, a housing target of 530 dpa would not be sufficient to provide for any of Crawley’s unmet need. CBC’s apparent acceptance of the withdrawn housing figure, given that MSDC
was deemed to have not met the Duty to Co-operate, implies that CBC has not effectively cooperated with Mid Sussex over the need to provide sound policy to meet the objectively
assessed housing need within the NWSHMA.
Reigate and Banstead
2.30
As stated in Topic Paper 5: Unmet Needs “... part of the housing market area extends into the southern part of Reigate and Banstead.” However, the statement in paragraph 2.15, that cooperative working between CBC and Reigate and Banstead Borough Council (RBBC) has
achieved an effective outcome through RBBC accommodating some unmet need from the
NWSHMA, is fallacious.
2.31
As concluded by the Inspector at the Examination of the recently adopted Reigate and
Banstead Core Strategy (July 2014) (RBCS) at paragraph 29 of the Inspector’s Report, Reigate and Banstead’s objectively assessed housing need is an average of 600-640 dpa
across the Plan period.
2.32
However, the housing figure in the adopted RBCS is only 460 dpa. This target is stated by the
Inspector to “... meet the full numeric need arising from the existing population and allow for some continued migration into the borough from other parts of the housing market (and wider)
area).” As such, whilst this target does not meet the full objectively assessed needs of
Reigate and Banstead, it was agreed that this was all that could be sustainably provided
within the Borough and that a higher provision, fully meeting the objectively assessed housing
need, would not accord with the NPPF (paragraph 32).
2.33
RBBC also held the position that the lower housing target was justified on the basis that the
objectively assessed housing need was based upon the 2011 Interim Household Projections
which, by accounting for RBBC’s participation in the New Growth Point initiative (NGP),
inflated figures for in-migration over the latter half of the Plan period.
Land East of Billingshurst
Page 13 of 28
2.34
Whilst this may be true, the fact still remains that 460 dpa is not sufficient to make any
contribution towards providing for the unmet needs from within the NWSHMA (if anything,
additional unmet need will be generated within the Borough, a proportion of which will require
meeting within the NWSHMA), and reflects a lack of effective co-operation between the
relevant Local Authorities, including CBC, to put plans in place to address cross boundary
strategic issues.
Sussex Coast HMA
2.35
The authorities within the Sussex Coast HMA (Adur, Arun, Brighton & Hove, Chichester,
Lewes and Worthing) jointly commissioned the Housing Study (Duty to Co-operate) Report, in
May 2013, to consider the balance between potential housing demand and supply at both a
district and HMA level.
2.36
The Study identified an overall shortfall in potential housing supply when compared to the
objectively assessed housing requirements of the HMA, as set out in Table 2 below:
Table 2: Indicative Comparison of Housing Needs against Maximum Potential Supply Levels
Requirement
(Minimum) (dpa)
Adur
Arun
Chichester
Worthing
Brighton & Hove
Lewes
Total
215
550
480
430
800
430
2,905
Maximum Delivery
considered
achievable
200
700
470
250
565
225
2,410
Minimum
Likely Shortfall
20 Year
Shortfall
15
-150
10
180
235
205
485
300
-3,000
200
3,600
4,700
4,100
9,900
Source: GL Hearn Housing Study (Duty to Cooperate) (May 2013)
2.37
As stated in paragraph 6.13 of the Study: “The analysis suggests that housing delivery over the period to 2031 across the HMA, based upon current evidence, is likely to fall at least 20%
below objectively assessed needs. A significant shortfall equivalent to at least around 495
dwellings per year arises.” Measures suggested to address this identified shortfall include “... potentially working jointly with other authorities within Northern West Sussex.”
2.38
It is clear that the identified housing shortfall arising within the Sussex Coast HMA and the
aspiration to work jointly with the NWSHMA authorities, places yet further demands upon HDC
and MSDC to contribute towards meeting wider unmet needs. Table 3 below summarises the
Land East of Billingshurst
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strategic housing context in terms of Crawley’s neighbouring Authorities.
2.39
In summary, the sub-regional position is bleak:
less housing is planned per annum than the former Regional Spatial Strategy (RSS); and
housing needs (based upon ONS populations projections) across the area greatly exceed
locally planned levels of housing (emerging plans fall 2,584 dpa short)
Table 3: Strategic Housing Context – NWSHMA and Sussex Coast HMA
Arun
Adur
Brighton
Chichester
Crawley
Lewes
Horsham
Mid Sussex
Mole Valley
Waverley
Worthing
Total
RSS
requirement
(annualised
2006 - 2026)
Dwellings
per annum
(dpa)
Historic
Shortfall
against RSS
requirement
(2006 - 2013)
565
105*
570
480
375
220
650
855
188
250
200
4,458
-355
+218
-556
-591
-36
+239
-2,490
-2,683
+347
-110**
+312
-5,705
‘What Homes Where’ 2008 ONS
Requirement#
(based on
most recently
published
plan period)
dpa
983
282
944
673
597
512
690
564
363
466
550
6,624
2014
Population
Projection
(based on
Holmans
principle of
1.04% p.a.
expansion)
dpa
693
280
1264
518
444
438
571
597
372
512
489
6,178
Locally
Planned
Level (most
recently
published
plan or post
2004 plan)
dpa
580
140*
565
410
326
225
650
530
188
226
200
4,040
*Excludes 10,000 dwellings at Shoreham Harbour – a reduced allocation of 1,050 is now proposed as factored
within the 140 dpa. Also excludes South Downs National Park.
** Period 2006 - 2012
# http://www.howmanyhomes.org/5.html
London
2.40
Nathaniel Lichfield and Partners (NLP) undertook an assessment of London’s unmet needs as
part of representations on the Further Alterations to the London Plan (FALP), on behalf of
Gladman Developments, in April 2014. This included a review on the potential impacts for
Councils in the wider south east. London’s unmet needs are a relevant consideration as part of both the duty to co-operate and objectively assessed needs.
2.41
Understandably, demand for housing within London is high, and still growing. The emerging
Land East of Billingshurst
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FALP sets a planned provision of 42,000 dpa within London. However this falls short of the
projected need of 49,000 - 62,000 dpa identified within the 2013 London Strategic Housing
Market Assessment (SHMA). Therefore there will be an unmet need of between 7,000 and
20,000 dpa, and it has been indicated that the figure of unmet need could be even higher.
The areas surrounding London are required to meet London’s unmet needs, as evidence has shown London’s housing market extends well beyond the capital.
2.42
Although the full amount of London’s unmet need is unclear, NLP estimated the figure to stand at 200,000 dwellings over the London Plan’s period of 10 years. NLP created two
scenarios using a large evidence base which included datasets surrounding house prices,
commuting and infrastructure provision. Eighty four Districts were recognised within London’s Housing Market Area (HMA), each of which were included in the scenarios.
Crawley
Borough, Horsham District and Mid Sussex District were three of the 84, although Crawley
Borough was not apportioned any of London’s unmet need on the basis that it was unlikely to meet its own needs.
2.43
The first scenario looked at how London’s unmet need would be most suitably distributed throughout the surrounding Districts based on commuting and migration patterns, with those
most affected located directly adjacent to the GLA boundary. The second scenario applied
the Metropolitan Green Belt as a fundamental constraint. This would mean that any authority
area which is covered by Green Belt (i.e. the majority of a District’s area) has no capacity to accommodate any of London’s unmet needs.
2.44
The overall implication for Horsham and Mid Sussex Districts is between an additional 56 484 dpa and 54 - 473 dpa respectively over the first 10 years of their plans.
Table 4: London Overspill into Horsham and Mid Sussex Districts
Scenario 1
Scenario 2 (Green Belt)
Share of
Additional
Additional
Share of
Additional
Additional
London’s Supply
Supply
London’s Supply
Supply
unmet
Required
Required
unmet
Required
Required
needs
(proxy of
(proxy of
needs
(proxy of
(proxy of
70,000 unmet 200,000
70,000
200,000
needs over
unmet needs
unmet needs unmet
10 year
over 10 year
over 10 year
needs over
London Plan
London Plan
London Plan 10 year
period)
period)
period)
London Plan
period)
Horsham
Mid
Sussex
0.79%
0.78%
556
543
1,588
1,522
Source: NLP Representation for Gladman (April 2014)
Land East of Billingshurst
Page 16 of 28
2.42%
2.36%
1,694
1,655
4,841
4,730
Potential for Effective Cooperation and Joint Working
2.45
As set out above, it is clear that effective co-operation has not taken place between the
NWSHMA authorities and that this has resulted in a lack of provision within plans being in
place (or put forward) to meet the identified unmet need arising from either the NWSHMA or
the wider strategic housing area.
2.46
In particular, reference to Crawley Borough, whilst the NWSHMA authorities have signed the
JPS, this document only refers to the difficulties faced by Crawley, but makes no commitment
to undertaking a comprehensive joint review of local plans within the HMA to establish a
solution. There are no positive commitments in the CLP to make this happen.
2.47
Paragraph 1 of the Duty to Co-operate section of the PPG (ID: 9-001-20140306) states that
“local planning authorities will need to bear in mind that the cooperation should produce
effective and deliverable policies on strategic cross boundary matters.
2.48
Paragraph 3.3 of the JPS includes housing need as one of the “... specific strategic matters which the three authorities have determined are relevant across the boundaries of the
authorities ...”
2.49
In order for the NWSHMA authorities to demonstrate that effective co-operation and joint
working has taken place in relation to the strategic issue of housing provision, CSP considers
that one of two approaches could be taken:
i. Prepare a Joint Local Plan for the NWSHMA
ii. HDC and MSDC prepare individual Local Plans that provide for a specific number of
dwellings that will go towards meeting Crawley’s unmet need, alongside selective
amendments to the CLP
2.50
Either way CBC’s Plan must clearly identify the issue of unmet needs and outline positive spatial responses to addressing this within the CLP.
Joint Northern West Sussex Local Plan
2.51
In light of the obvious interrelationships between the local authority areas within the NWSHMA
(reflected in the work reported in the JPS and Crawley’s DTC) and the localised constraints that present difficulties for individual authorities (namely Crawley) to meet their housing needs,
Land East of Billingshurst
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it would seem that an effective solution would be to plan collectively for the NWSHMA through
a joint Local Plan. A joint Local Plan would provide an effective framework for co-operation
and joint working between the NWSHMA authorities to provide for the cross boundary
strategic needs of the HMA.
2.52
Such an approach is being undertaken by the Greater Manchester Combined Authority
(GMCA). The GMCA is a statutory body which has been built on the work of the Association
of Greater Manchester Authorities (AGMA), which was a voluntary body. The functions of the
GMCA include transport functions, and some economic development and regeneration
functions. The GMCA is formed from the 10 Greater Manchester Local Authorities.
2.53
In September 2014 the GMCA produced a draft joint plan known as the Greater Manchester
Spatial Framework. This plan is currently undergoing initial consultation until November 2014.
The Spatial Framework will manage the supply of land to support jobs and new homes, and it
will be the overarching Development Plan Document managing land for jobs and homes for all
10 planning authorities.
2.54
The priorities for the Spatial Framework fall under four categories:
Town Centres – redesigning the offer that town centres can make as a response to
growing e-commerce and out of town retailers.
Land Supply – ensuring that land is available in locations that are attractive to the market.
Infrastructure – driving competitiveness and economic growth by increasing productivity,
reducing costs and extending the reach of business.
Housing – a committed target of delivering 9,200 new homes per annum by 2015, and
retrofitting 25,000 per annum.
2.55
As stated in paragraph A.22 of the DTC, CBC has explored cross boundary plan making with
HDC in relation to“... further potential urban extensions immediately adjacent to the Crawley urban area.” This has been successful in the past with the Joint Area Action Plan for West of
Crawley being prepared by HDC and CBC for the new Kilnwood Vale neighbourhood.
2.56
The continuation and expansion of such an approach to the entire HMA would enable the
NWSHMA authorities to plan collectively for the strategic needs of the Plan area that cross
administrative boundaries. In doing so the barriers to effective plan making presented by the
current plan boundaries, which do not reflect the close proximity of Crawley’s main settlements to adjoining authority areas, could be avoided.
Land East of Billingshurst
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Specific Local Plan Provision
2.57
It can be seen that whilst the issue of Crawley being unable to meet its housing requirements
within its boundary, this is well documented by the NWSHMA authorities, none of the
authorities’ Local Plans, be they adopted, currently or recently in preparation, propose to deliver a workable solution. As things stand the NWSHMA authorities will not address this
unmet need until after 2031.
2.58
Given that, with the exception of RBBC, none of the NWSHMA authorities have an adopted
Local Plan, it is considered an optimum time for effective co-operation to be undertaken to
prepare robust evidence on housing need and produce plans to meet the identified needs of
the HMA.
2.59
Should it not be feasible to prepare a joint Local Plan across the NWSHMA, a suitable
alternative could be to re-examine the objectively assessed needs of the HMA, taking into
account unmet needs from the Sussex Coastal HMA and London.
2.60
On the basis of this newly produced housing evidence that accurately establishes the overall
needs of the HMA, specific and co-ordinated provision could be made within the Horsham and
Mid Sussex Local Plans sufficient to meet not only their own assessed needs but also a
proportion of unmet need from Crawley and the wider area.
2.61
This specific provision could be referenced within Crawley’s Local Plan enabling each authority to demonstrate that effective co-operation has been undertaken to enable plans to
be put in place to cater for any unmet need arising from within the wider HMA. The CLP could
be amended now to outline this mechanism, and also incorporate more positive wording in
respect of housing provisions in adjacent authorities within the vision/ key diagram and
supporting policies.
2.62
As stated previously in relation to meeting the Duty to Co-operate, an element of this process
has already been undertaken with the identification of the possibility of urban extensions to
Crawley within Horsham District and the identification of potential strategic sites for housing
provision. Such sites, including Land East of Billingshurst and Land West of Kilnwood Vale
represent suitable locations for specific provision within Horsham for meeting Crawley’s unmet need.
Land East of Billingshurst
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Crawley’s Objectively Assessed Housing Need
2.63
In considering CBC’s objectively assessed housing need it must be recognised that, due to the developmental constraints present in Crawley, there is a difference between the
unconstrained housing need and the level of housing that can realistically be provided within
the Borough boundary. Given these constraints it is considered probable that, as stated in the
draft CLP, 4,895 dwellings are all that can currently be provided within Crawley’s Plan area.
However, it is still necessary to properly establish what Crawley’s objectively assessed housing need actually is.
2.64
Establishing Crawley’s housing need may seem academic given the acknowledged lack of capacity within the Borough. However, if Crawley’s unmet housing need is to be catered for,
either through a Joint Northern West Sussex Local Plan or through more effective cooperation between the NWSHMA authorities, it is essential that Crawley’s objectively assessed housing need is accurately represented.
2.65
The stated objectively assessed housing need of 8,100 (535 dpa) in the CLP is based upon
the 2011 Locally Generated Needs Study (LGNS) and corresponds to the 2008 ONS baseline
demographic projections.
However Crest believes that 535 dpa is unlikely to be the
objectively assessed level as a result of employment growth needs and affordable housing
provision.
Employment Growth
2.66
The recent Economic Growth Assessment (EGA) prepared for the Councils of Crawley
Borough, Mid Sussex District and Horsham District (April 2014) identifies a ‘baseline’ quantitative need for at least an additional 16,440 jobs equating to 822 jobs per annum (total
jobs), as well as the qualitative need reflecting the limitations of future potential at Manor
Royal. The EGA also sets out two higher job targets based on a ‘high growth scenario’ and a
‘potential sites scenario’. The former adopts predictions for sector growth taken from work by
the Coast to Capital Local Economic Partnership (LEP) and the Gatwick Diamond initiative to
arrive at a forecast job growth of 20,130 (1,007 jobs per annum). It is worth noting that the
LEP goal is to create an additional 100,000 jobs across the Coast to Capital sub-region over
the period 2010 - 2035, with the ‘Heart of the Gatwick Diamond’ (Crawley-Gatwick) identified
as one of the nine strategic business locations to accommodate much of that growth.
2.67
Topic Paper 4: Economic Growth outlines the EGA position that to achieve the quantitative
need of 16,440 jobs over the period 2011-2031, 822 new jobs would be required per annum.
Land East of Billingshurst
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The ‘higher growth scenario’, which is more aligned to the Gatwick Diamond/ Coast to Capital LEP aspirations states quantitative need for ‘at least’ an additional 20,130 jobs of which 8,310
jobs would be B-Class (1,007 and 415 jobs per annum respectively).
2.68
The evidence base which supports the economic aspect of the CLP sits at odds with 535 dpa
which CBC states would only support 399 jobs per annum (Paragraph 6.5 of Topic Paper 2:
Housing Need, August 2014). More homes are needed to meet wider jobs aspirations.
2.69
It is insufficient to plan to only meet part of the B-Class employment needs, as this neglects
the needs arising from other key sectors of society, teaching or nursing for example.
In
addition, jobs growth is required to sustain the planned levels of retail.
Affordable Housing Needs
2.70
The Northern West Sussex Strategic Housing Market Assessment Update (SHMA) (GVA,
2012) looked at the Northern West Sussex HMA and specifically focussed on affordable
housing provision, using different scenarios of growth.
Three possible housing delivery
options were included for Crawley named 1, 2 and 3 (300, 400 and 542 dpa respectively).
These were run through two scenarios – High, which accommodates the entire affordable
housing waiting list, and Low, which accommodates only those households on the waiting list
in ‘Reasonable Preference’ categories.
Scenario
Planned Household
Growth Formation
(dpa)
Net Annual
Affordable Housing
Need (dpa)
Annual Need as %
Housing Requirement
300
400
542
300
400
542
240
299
382
82
141
225
80%
75%
70%
27%
35%
42%
Crawley 1 High
Crawley 2 High
Crawley 3 High
Crawley 1 Low
Crawley 2 Low
Crawley 3 Low
2.71
The Low Scenario, at a housing provision of 542 dpa, would equate to an affordable need of
225 dpa, or 42% of all new dwellings, which is higher than the CLP affordable housing
requirement of 40%.
Furthermore this scenario only provides for households within the
Reasonable Preference categories, and therefore only the need for rented accommodation,
not for intermediate homes. As a result, it is clear that the stated objectively assessed needs
of 535dpa is insufficient to factor the full affordable housing needs.
Land East of Billingshurst
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2.72
A housing requirement of 630 dpa would be more appropriate for the CLP in order achieve
enough affordable housing for the current waiting list (Table 3.4, Locally Generated Housing
Needs Assessment, NLP, 2011).
Crawley’s Employment Land
2.73
The Economic Growth Assessment (EGA) for Crawley, Mid Sussex and Horsham (April,
2014) indicated the quantitative need for employment land for each of the local authorities in
order to achieve employment growth. Crawley was identified to need a baseline figure of
77ha of employment land for the 16,440 jobs required over the period 2011-2031. The EGA
sets out two higher land requirements based on a ‘high growth’ scenario and a ‘potential site’
scenario. The former was in line with the Coast to Capital Local Economic Partnership (LEP)
and the Gatwick Diamond initiative, and reflected a higher employment land requirement of
88ha as a minimum figure.
2.74
The Local Plan (Policy EC1) acknowledges the need to provide for at least 77ha of
employment land, but that the available supply is only 42ha, leaving a shortfall of at least 35ha
over the Plan period. Crest is however of the view that an additional 46ha would be required,
giving a total of 88ha, to meet the middle of the three scenarios tested in the EGA and to best
reflect the wider LEP priorities.
Conclusion
2.75
Crest believes that Crawley’s evidence shows a clear unmet housing need in the Borough and CBC has failed to identify a workable solution within the CLP. The adjacent Boroughs are
unlikely to deliver their objectively assessed housing need, and these figures have not taken
into account London’s unmet need as outlined by the NLP representation on the emerging
London Plan. There is identified emerging shortfall within both the Sussex Coast and the
Northern West Sussex Housing Market Areas (NWSHMA), and it is clear that effective cooperation has not taken place between the NWSHMA authorities. This is evident in that none
of the NWSHMA Local Plans, be they adopted, currently or recently in preparation, propose to
deliver a workable solution. This needs to be recognised by the NSWHMA Authorities, either
through the creation of a joint Local Plan, or the referencing of specific provision to cater for
any unmet need arising from within the wider HMA.
2.76
An element of this process has already been undertaken with the identification of the
possibility of urban extensions to Crawley within Horsham District. However, at this time both
Land East of Billingshurst and Land West of Kilnwood Vale are not allocated to meet this
Land East of Billingshurst
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need. Both represent suitable locations for specific provision within Horsham’s emerging plan. 2.77
Although it is recognised that there are developmental constraints present in Crawley, it is still
necessary to establish what Crawley’s objectively assessed housing need actually is. Crest
believes the CLP stated housing requirement of 535 dpa is not a robust objectively assessed
level.
2.78
Firstly CBC believes that 535 dpa will provide 399 new jobs per annum, however this figure is
not a reflection of the additional jobs required in accordance with the recent EGA, which
recommends a ‘higher growth’ scenario of 415 new B-Class jobs per annum, to align with the
Coast to Capital LEP and Gatwick Diamond initiatives. Therefore more homes are needed to
meet these wider jobs aspirations.
2.79
Furthermore, both the ‘baseline’ and ‘higher growth’ EGA scenarios envisage substantially more total jobs, which the present CLP makes no provision for within the objectively assessed
needs.
2.80
The 2012 SHMA update calculates the net affordable housing need within Crawley to be
between 382 dpa and 225 dpa for High and Low scenarios respectively. The objectively
assessed level of needs must exceed 535dpa, as at that level CBC would need between 42%
- 70% of all new dwellings to be affordable, which is inconsistent with the policy target of 40%
and would unlikely be viable. 630 dpa would be more appropriate to achieve enough
affordable housing for the current waiting list.
2.81
CSP is therefore of the view that the objectively assessed level of housing is in the region of
650 dpa as this:
Aligns more comfortably with employment aspirations
Would enable, viably, the provision of affordable housing to meet needs
Corresponds with recent evidence of migration trends (see LGHNA – November 2011)
2.82
An ongoing acceptance of in-migration is important, given Crawley’s past and future economic role, notably emphasised by the EGA and Coast to Capital LEP.
2.83
Finally the Local Plan acknowledges the need to provide for at least 77ha of B-Class
employment land, however in order to reflect the aims of the Coast to Capital LEP and the
Gatwick Diamond initiative, CBC needs to provide for 88ha. Therefore, as 42ha is available,
there is a requirement for an additional 46ha, and not the 35ha as stated within the CLP.
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2.84
In many respects, Crawley is better placed to accommodate sub-regional employment needs,
ahead of housing, owing to urban capacity. This provides justification to plan for greater
levels of employment growth, and to identify a clear and transparent objective assessment of
housing needs.
2.85
This mismatch must be recognised and addressed in the supporting text of the Plan, with
positive policy wording to address the wider cross boundary issues to achieve both the
required jobs and housing growth in the wider sub region.
unsound.
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Otherwise the Plan is fatally
3.
Changes required to make the Plan sound
3.1
Crest objects to the draft CLP as, in its current form, the Plan is considered to be unsound.
As a result the following amendments are required.
3.2
Paragraphs 1.30-1.36 should be revised to demonstrate more positive and effective cooperation in respect of the cross boundary development required in adjacent districts, to cater
for CBC’s unmet housing need. 3.3
The Key Diagram should be amended to outline ‘potential areas of search’ for urban
extensions outside of Crawley, to include land West of Kilnwood Vale. The notation to make
clear that these areas will be subject to ongoing dialogue with adjacent Authorities, and
subject to allocation via their plans and the application of the ‘Ongoing Co-operation’ policy (to
be included in the CLP).
3.4
A new policy inserted:
Ongoing Co-operation within the Northern West Sussex Housing Market Area
(NWSHMA)
The Borough Council commits to ongoing work and dialogue with adjacent Local Authorities
and Key Stakeholders to enable the delivery of the required homes, employment and
infrastructure to ensure the full objectively assessed development needs are met in a
sustainable way. This process will be reviewed on an ongoing basis as reported in Annual
Monitoring. The Borough Council commits to leading on a spatial framework plan, which shall
address four broad categories:
Town Centres/ retailing objectives – redesigning the offer based on wider needs.
Land Supply – ensuring that land is available in locations that are attractive to the market.
Infrastructure – driving competitiveness and economic growth through supporting
infrastructure.
Housing – the establishment of SWSHMA needs, and ongoing review.
Specific and co-ordinated development provision may be made within land beyond the
Borough Council’s boundaries as a result of the spatial framework plan process. Potential areas of search are shown by the Key Diagram.
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3.5
A new paragraph is required within The Vision which supports working with adjacent
authorities to allow for sustainable urban extensions to Crawley, to account for CBC’s unmet housing needs (to link back to the proposed ‘Ongoing Co-operation’ policy).
3.6
Crest objects to Paragraphs 2.17-2.26 and 6.11-6.13 on the grounds that the stated housing
requirement does not reflect the true objectively assessed housing need for the Borough.
These housing needs should be amended to reflect the employment growth aspirations and
the affordable housing need from Crawley Borough. The objectively assessed level is in the
region of 650 dpa.
3.7
Furthermore Crest objects to Policy H1 and Paragraph 6.40 as these do not include any
reference to unmet needs, nor any positive steps to address this with adjacent Local
Authorities.
These paragraphs and Policy H1 also fail to allow for sustainable urban
extensions to Crawley, which should be referred on the Key Diagram as ‘potential areas of search’. 3.8
Policy EC1 should be amended to replace “35ha” with “46ha”, to reflect the 88ha employment
land provision. Furthermore in the reasoned justification for Policy EC1, the text should be
revised to reflect a demand-led approach to the provision of business-focussed employment
needs and the role of land east of the Airport in meeting the quantitative and qualitative
strategic employment land requirements for the Plan and sub-regional areas.
3.9
Paragraphs 5.18 and 5.20 should be amended by deleting references to “16,500 jobs”,
“77.2ha” and “35ha” and replacing with ‘20,130’, ‘88ha’ and ‘46ha’ respectively.
The
equivalent changes should be made to the section of the plan entitled ‘Economic Growth’ (Paragraphs 5.8-5.15).
END
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Appendix 1: Land East of Billingshurst Site Summary
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Appendix 2: A Technical Appraisal of Land West of
Kilnwood Vale (Savills, May 2012)
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