Strategic planning for the Crawley sub-region

Introduction

On 21st February 2024 Crawley Borough Council declared a Housing Emergency referencing one pound in every three of the net revenue budget being spent on temporary accommodation.

What the Council might have further referenced is a submitted Local Plan that generates at least 7,500 homes unmet need.? To put this in context, this is the equivalent of five 1,500 home urban extensions.? Context also comes in the form of a current proposal to designate new Green Belt.

Furthermore, the Council might have referenced the inability of neighbouring local authorities to provide for Crawley’s unmet housing need.? Indeed, the majority of Crawley’s neighbours are themselves generating unmet need.?

Is this the point to throw in the towel, and accept unmet need that will stay unmet or, alternatively, the point to explore potential long term strategic solutions?? The latter.? Always the latter.

As such, this note imagines a large sub-region of 30 LPAs centred on Crawley and considers the latest situation in respect of providing for housing needs.? The aim is to inform consideration of long term strategic solutions.

Set out below is:

• Summary analysis
• Analysis of each LPA in turn
• Conclusions

Summary analysis

The summary analysis involves categorising the 30 LPAs as follows:

• Red – clear concern in respect of generating unmet need
• Amber – some concern
• Green – no significant concern
• Dark green – some potential to provide for unmet need

The conclusions are as follows:

• Red - 57% of LPAs
• Red or amber – 80% of LPAs
• Dark green – one LPA (being generous)

Also, if Crawley can be considered to relate most closely to East Surrey and the Sussex Authorities, then the situation is considerably worse (mostly red, with all three amber ratings somewhat marginal to the downside).

Finally, the wider regional context is as follows:

• West Kent – there is an element of unmet need concern.
• M4 corridor – Slough’s unmet needs have long been a concern.
• South Hampshire – see the recent PfSH Position Statement.?
• East Kent – is reviewed for completeness.

Figure A: Summary analysis

Summary reasons by LPA are as follows:

• Adur – Red – adopted plan generates unmet need; review not commenced.
• Arun – Amber – or red noting statements in current consultation?
• Ashford – Green – or amber given provision in plan to 2030 and no review?
• Brighton – Red – significant unmet need.
• Canterbury – Green – draft plan provides for need in full.
• Chichester – Red – publication plan generates unmet need.
• Crawley – Red – submitted plan generates at least 7,500 homes unmet need.
• Dartford – Green – non-committal on Gravesham’s unmet need.
• Dover – Green – submitted plan provides for need in full.
• Eastbourne – Red – significant unmet need.
• East Hants – Green – draft plan leaves door open to unmet need.
• Elmbridge – Red – submitted plan generates unmet need.
• Epsom and Ewell – Red – draft plan generates significant unmet need.
• Folkestone and Hythe – Green – adopted plan provides for need (eventually).
• Gravesham – Red – seemingly very likely to generate unmet need.
• Guildford – Green – adopted plan is proactive and a review is underway.
• Hart – Green – adopted plan provides for unmet need from Surrey Heath.
• Hastings – Red – significant unmet need.
• Horsham – Red – publication plan generates unmet need.
• Lewes – Red – HELAA capacity suggests unmet need is likely.
• Maidstone – Amber – “minimal undersupply” against stepped requirement.
• Medway – Amber – HELAA capacity but challenges & last plan 2003.
• Mid Sussex – Dark green – perhaps capacity for unmet need.
• Mole Valley – Red – submitted plan generates unmet need.
• Reigate and Banstead – Amber – or red given lack of a plan review?
• Runnymede – Amber – or red given plan period and decision not to review?
• Rushmoor – Green – an adopted proactive local plan, but no plan review.
• Rother – Red – the recent Wealden plan states that unmet need is likely.
• Sevenoaks – Amber – arguably green but context of withdrawn plan.
• Spelthorne – Red – given recent vote to amend the submitted plan.
• Surrey Heath – Amber – unmet need is provided for in Hart District.
• Swale – Green – or amber given plan pause and current targets work?
• Tandridge – Red – recent unsound plan sought to generate unmet need.
• Thanet – Amber – or red given plan period and lack of immediate review?
• Tonbridge & Malling – Amber – arguably green given recent commitments.
• Tunbridge Wells – Amber – or red given proposal to reduce the plan period?
• Waverley – Green – similar to Guildford.
• Wealden – Red – draft plan generates unmet need.
• Woking – Red – well-established that unmet need is an issue.
• Worthing – Red – recent plan generates unmet need.

Detailed analysis

LPAs are considered in seven clusters, and in ascending order of links to Crawley.

1) North / West Surrey and North East Hampshire

The most recently adopted Local Plan here is Runnymede, where the Inspector’s Report (para 39) explains that the decision was taken to shorten the plan period such that it ends in 2030.? The Inspector requires an immediate Local Plan Review taking into account “on-going work by the Local Strategic Partnership to develop a longer-term, joint approach to growth in Surrey.”? However, in June 2023 the Council decided to wait to prepare a new Local Plan under the new proposed planning system.? The report does not reference the Local Strategic Partnership but acknowledges “following through with [our] promise to [review]”.? It then concludes that “there is simply no need to review the plan ahead of the introduction of the new system, as the existing Plan remains up to date.”

The next LPA to consider is then Spelthorne, which links closely to Runnymede.? The submitted Local Plan does not generate unmet need.? However, on 29th February 2024 the Council voted to amend the plan such that it generates unmet need (particularly in early years), referencing recent clarity on ‘mandatory targets’.? The report explains that the decision will trigger work under the Duty to Cooperate (DtC), but what will happen to unmet need in practice is unknown.

Immediately to the west is then Woking, where the Council is aiming to adopt a new Local Plan before the current plan ends in 2027.? The new plan will likely generate significant unmet need, although it is noted that recent delivery has not been too far below standard method need.

The situation is then more positive in respect of authorities to the west:

• Guildford and Waverley – adopted plans several years ago and have both recently commenced reviews.? The adopted plans provided for needs in full – as understood at the time – and also together made provision for Woking’s unmet need in full.? The Guildford plan also notably identified a supply 37% higher than the housing requirement (a ‘supply buffer’), but this was judged necessary due to delivery risks (a ‘supply buffer’).? A meeting on 21st February 2024 resolved to commence a Local Plan Review.
• Surrey Heath – published a draft Local Plan in 2022 that proposed a housing requirement that provides for need after having accounted for a small proportion of need being provided for in Hart District.? The accompanying SA Report also explored two higher growth scenarios, with an identified supply as high as the requirement plus 25%.? However, it was clear that this was with a view to providing more fully for locally arising need, rather than unmet need from elsewhere.
• Hart – the adopted plan provides for need in full and also some unmet need from Surrey Heath.? Hart had notably sought to identify an area of search for a new settlement to provide for housing needs beyond the end of the plan period (2032), but this was deleted by the Inspector.
• Rushmoor – is a mostly urban authority, but nonetheless was able to adopt a Local Plan in 2019 that provides for housing need in full along with a healthy supply buffer: “The estimated capacity for housing which can be delivered up to 2032 of about 8,900 dwellings is sufficient to meet the objectively assessed need for 7,848 dwellings identified in the SHMA.”

Figure B: Rushmoor housing trajectory (not stepped; supply buffer)

2) West Kent

Beginning with Sevenoaks, the adopted Local Plan ends in 2026 and provides for 165 dwellings per annum (dpa) in contrast to a standard method need figure of 712 dpa.? Recent delivery has also been low (a score of 51% in the 2022 Housing Delivery Test, HDT).? The Council submitted a plan generating unmet need in 2019 but failed the DtC.? Most recently, a Draft Local Plan presented three alternative approaches to supply, where one would certainly generate unmet need and another could potentially (subject to further detailed work on supply).? The third option would involve an identified supply amounting to need plus at least 10%, but the assumption is that this would not generate flexibility to provide for unmet need.? The possibility of providing for unmet need was considered closely as part of a previous high level ‘issues and options’ consultation in 2022 (see 35 references in the SA report), and eight authorities responded stating the potential for unmet need. ?However, in 2023 providing for unmet needs was ruled out (53 references in the SA report).

With regards to Tunbridge Wells, a Local Plan was submitted in 2021 that did not generate unmet need.? However, at the time of writing (February 2024) the Council is consulting on deletion of a garden village leading to significantly reduced supply.? Rather than formally generating unmet need, the proposal is to reduce the plan period, such that it covers only 10 years from plan adoption.

Also, by way of further context:

• Dartford – recently received their Inspector’s Report.? The plan provides for need in full, and the Inspector explains:
• “As there is no clear evidence before me of the scale of Gravesham’s unmet housing need, it would be unrealistic to assess… how Dartford may have been able to meet it. I also recognise that whilst the extent to which the Council may be able to assist Gravesham remains unknown, the Council had confirmed that the door had not been closed to providing assistance.”
• Tonbridge and Malling – the adopted Local Plan ran out in 2021 and provided for 435 dpa whilst standard method need is 835 dpa.? The Council submitted a plan in 2019 providing for 696 dpa (with a supply buffer), which was understood to be the need figure at that time, but then failed the DtC.? Most recently, the Council has committed to providing for need in full.? However, there are clear constraints, and the HDT (2022) records average delivery of 460 dpa over the 2019-21 monitoring years.
• Medway – the adopted local plan ran out in 2006.? In 2023 an early consultation document explained that the Land Availability Assessment (LAA) suggests capacity to provide for standard method need, which is 1,667 dpa, but that there are a range of strategic challenges, particularly transport-related following withdrawal of Government ‘HIF’ funding.? The document presents arguments for housing need being lower on the basis of the 2018-based household projections. ?It is also noted that the HDT (2022) records average delivery of 1,124 dpa over 2019-21.
• Maidstone – adopted a Local Plan in 2017 and have been delivering very well (191% on the HDT, 2022).? However, the new Local Plan proposes a stepped requirement and - even with this - a “minimal undersupply [that] can be addressed during the plan, or through a subsequent review.”?
• Swale – a Regulation 19 plan in 2021 provided for housing need in full, and the SA report also explored higher growth scenarios that could potentially enable flexibility to provide for a modest amount of unmet need.? However, the Council then took a step back and consulted under Reg 18, before pausing local plan-making.? Housing delivery has recently been strong and the Council is currently commissioning a study to examine housing targets.
• Canterbury – a draft plan (March 2024) provides for need in full over a 15 year plan period (or perhaps 14 years) without resorting to a stepped requirement and with a healthy supply buffer of 9.7% (over the plan period as a whole).? A previous draft plan had proposed a 20 year plan period and, in turn, significantly more supply.? However, without examining the SA Report there is little reason to suggest potential capacity for unmet need.
• Ashford – the adopted plan ends in 2030 and limited progress has been made on a review.
• Thanet – the adopted plan (2020) committed to an immediate review.
• Dover – the submitted local plan provides for need in full.
• Folkestone and Hythe – draft plan includes a very stepped trajectory.

?Figure C: Maidstone housing trajectory (stepped; limited supply buffer)

Figure D: F&H housing trajectory (stepped; limited supply buffer)

3) The west of West Sussex and the east of East Sussex

Beginning with Chichester, at the west of West Sussex, a Regulation 18 consultation document in 2018 proposed providing for need in full, mindful that:

“In July 2015, the Council adopted the Chichester Local Plan...? However, due to uncertainty about delivery of future infrastructure… the Plan was not able to meet the full identified housing need for the area.? To address this, the Council committed to undertake a Local Plan Review….”?

However, following much detailed work, the Regulation 19 plan (see page 99) generates around 1,000 homes unmet need (and does not make provision for unmet need from the South Downs National Park, SDNP).? The SA report explores higher growth options, but there are extensive constraints.? Also, unmet need is arguably higher than ~1,000 homes, as the housing requirement is set at 10,350 homes in the context of 10,359 homes identified supply, i.e. there is no ‘supply buffer’ (partly reflecting ‘capped’ capacity on the A27).?

Unmet need from Chichester might feasibly flow towards Waverley or East Hampshire; but links are not strong.? Focusing on East Hampshire, a current draft plan provides for 14 dpa unmet need from the SDNP only, explaining:

“As detailed in the Partnership for South Hampshire (PfSH) Spatial Position Statement (December 2023) there is an unmet need across the sub-region of approximately 12,000 homes to 2036….

… no assumptions are made on the unmet needs of other neighbouring local planning authorities (with the exception of the SDNPA), but any homes surplus to the identified requirements could be attributed to any future identified unmet need, particularly in the South Hampshire sub-region.”

Moving to the east of East Sussex, the current Local Plan for Wealden ends in 2027 and provides for 450 dpa in contrast to a current standard method need of 1,200 dpa.? Most recently, on 8th February 2024 the Council voted to consult on a Draft Plan under Regulation 18, which generates at least 4,071 homes unmet need (higher if there is a need for a supply buffer, as per Chichester).

There is no discussion regarding what might happen to the unmet need generated, but the consultation document does present a helpful discussion of the unmet need challenges facing neighbouring authorities, including the following explanation of the Eastbourne situation:

“In November 2022, Eastbourne Borough Council published a Growth Strategy Consultation… [which] indicated that there would be a shortfall of 8,359 dwellings in their plan period…”

The Wealden consultation document also states that Rother is “unlikely to meet their local housing need”.? The situation here is: an adopted plan that ends in 2028 and provides for 335 dpa in the context of a SM need figure in the region of 737 dpa; and a consultation document in 2021 stating: “Once the Council has considered its development strategy, it may be necessary to engage with neighbouring LPAs to request their ability to help meet any unmet… need.”?

Finally, with regards to Hastings, a draft plan published in 2021 that proposed a stepped housing requirement totaling 4,275 in the context of 8,600 homes need.?

4) The south coast around Brighton

Beginning with Brighton itself, the adopted Local Plan ends in 2030 and provides for 660 dpa in the context of housing need understood at the time to be 1,506 dpa and a current standard method housing need of ~2,328 dpa.? The Inspector’s Report explained: “Formal requests were sent to other Councils… . No positive responses were forthcoming, mainly because other authorities are finding it difficult to meet their own needs.”? A Local Plan Review has now commenced.

To the east of Brighton, Lewes District also links to aforementioned Eastbourne.? The adopted Local Plan ends in 2030 and a review is underway, with a consultation under Regulation 18 held in late 2023.? The consultation document explains that the plan area (outside the SDNP) has struggled to provide for its adopted housing requirement of 275 dpa, and so delivering standard method need (602 dpa) could be highly challenging.? The consultation document identifies a HELAA capacity figure significantly below standard method need.

Figure E: Historic housing delivery in Lewes

To the west of Brighton is then Adur and Worthing, which are both constrained LPAs similar to Brighton itself.? The Adur Local Plan ends in 2032 and provides for 177 dpa in the context of housing need understood at the time to be 325 dpa and now shown by the standard method to be lower, at ~250 dpa.? The Inspector’s Report explained:

“The [West Sussex and Greater Brighton Strategic Planning Board (SPB)] produced the Local Strategic Statement in 2016 (LSS2) [and] is currently considering an up-date of LSS2 (to be known as LSS3). This will provide the opportunity to reconsider cross-boundary issues...?

… It has been suggested that… the [plan] should be found to be not sound and that measures to deal with the unmet need should be agreed now. In other circumstances that may be an appropriate way forward but there are three factors that enable me to conclude that a more pragmatic approach…”

The recent Inspector’s Report for the Worthing then also relies on LSS3, and goes on to conclude:

While this may not be the solution that everybody wishes to see, it is nevertheless clear evidence of long-term and ongoing engagement... on strategic matters.

… Concerns were raised that a failure to agree a solution to housing need in Worthing, and the remainder of the West Sussex area, is a sign of collective failure of the Duty....?However, while a solution to the housing problem has not been reached, the Council has still sought to address the issue... In doing so, I am satisfied it did not seek to defer finding a solution...”

Finally, to the west is Arun District, where the adopted Local Plan to 2031 provides for 1,000 dpa albeit with a stepped requirement.? A Local Plan Review is underway, and an initial consultation is timetabled for March 2024.? It emphasises that, whilst standard method need is 1,400 dpa, this is only a “starting point” for the task of setting a housing requirement and that a focus will be: “Ensuring that the housing target… is realistic, set at a level that achieves sustainable development and supported by infrastructure capacity that can be viably financed... over the plan period.”? On this basis, unmet need is likely.

Figure F: Historic housing delivery in Arun

5) Horsham and Mid Sussex

These two authorities are Crawley’s immediate neighbours in West Sussex:

• Horsham – the adopted plan ends in 2031 and provides for 800 dpa.? The current Regulation 19 Local Plan Review explains that Horsham would ideally provide for significant unmet housing need, but that it is unable to do so, primarily on account of constrained water resource availability.? It identifies a total supply of 13,212 homes which it proposes should be set as the housing requirement (777 dpa).? It then also proposes a stepped requirement (480 dpa and then 901 dpa).? It then states that the effect will be to generate 2,275 homes unmet need, but this should be considered a minimum figure.? With regards to the unmet need generated:
• “Horsham Council will work with its neighbouring authorities, particularly those who form the Northern West Sussex Housing Market Area, in exploring opportunities and resolving infrastructure and environmental constraints to meet this need in sustainable locations.”
• Mid Sussex – the current Reg 19 Local Plan proposes a housing requirement set at standard method need (without a stepped requirement).? The identified supply is then ~1,000 homes above the proposed housing requirement (5%).? The plan states that this is to be used for “resilience and unmet need”; however, it would be very surprising if there is capacity to provide for unmet need within the identified supply, noting that it is very common for Local Plans to plan for a supply buffer well in excess of 5% - see Figure G.?The plan also provides an update on strategic planning:
• “At its meeting in September 2017, the [Brighton and West Sussex] Board agreed to explore options for meeting the unmet housing needs... to commit to preparation of an updated strategy and to commission work to provide an evidence base to support the development of a longer-term strategy to address spatial options for meeting housing, employment and infrastructure needs over the period to 2050 - known as LSS3.”

Figure G: Contrasting Dover (10% supply buffer) and Mid Sussex (5% supply buffer)

6) East Surrey

Taking the five authorities from west to east:

• Elmbridge – the adopted plan ends in 2026 and provides for 225 dpa in the context of standard method housing need at ~647 dpa.? It is also important to note that Elmbridge has an affordability ratio of 20, which is higher than all bar three London boroughs.
• A Local Plan is currently being examined and the Inspector has recently asked: “The housing requirement for Elmbridge has been calculated at 9,705 homes. ?Policy SS3 sets out that the Plan will deliver at least 6785 net additional homes over the Plan period. This equates to some 453 dpa and will leave an unmet need of some 2920 dwellings over the Plan period. This is a significant shortfall.? Is the Plan justified in not meeting the full LHN?”?
• However, the unmet need may be higher, because: a) the Inspector requests that the plan period is extended by two years; and B) the submitted plan does not include a supply buffer. ?The plan also states: “… it is highly unlikely there will be any significant opportunities during the plan period to accommodate need outside of the borough boundary.”
• Epsom and Ewell – has an affordability ratio only slightly below that of Elmbridge and is also notable for having very high affordable housing need.? A Draft Local Plan was published for consultation in 2023 which, in the context of standard method need at 652 dpa, identified a supply of 327 dpa and, in turn, proposed a requirement of 300 dpa (a 9% supply buffer).? Hence the proposal was to generate 352 dpa unmet need per annum, or 6,340 homes in total.? The SA report presented a discussion of potential options for accommodating unmet need.
• Mole Valley – the adopted Local Plan ends in 2026 and provides for 188 dpa, in the context of standard method housing need at 456 dpa.? As can be seen from the figure below, the submitted Local Plan proposed to generate significant unmet need, and the latest proposal (ED54) is to reduce the housing requirement to 340 dpa with no supply buffer.? A buffer of ~25 dpa would reduce the requirement to 315 dpa, leading to 141 dpa unmet need.

Figure H: A figure from the submission Mole Valley Local Plan

• Reigate and Banstead – the adopted plan ends in 2027 and provides for 460 dpa in the context of standard method need at 644 dpa.? In 2019 the Council decided that there was no need to review the Local Plan.? However, it is recognised that recent housing delivery has been fairly strong (albeit the extent to which this has been plan-led is unclear).? The HDT (2022) records average delivery of 670 dpa over the 2019-2022 monitoring years.
• Tandridge – the adopted plan ends in 2027 and provides for 125 dpa in the context of standard method need at 642 dpa.? A plan was submitted in 2019, but recently found unsound, with the Inspector’s Report explaining: "The Plan… would give rise to significant unmet housing need…? In this round of Plan making [neighbours]... have stated that they are unable to help…?
• The report also notably explained: “Also relevant is the wider Surrey context…? The ILSS published in December 2017 identified... that Surrey was only likely to be able to meet approximately 50% to 75% of its objectively assessed housing needs over the next 15 years and that few adjoining authorities will be able to contribute to meeting any unmet needs of others.”
• The Inspector also discusses cooperation with Sevenoaks, but this was not referenced in a recent submission to the Sevenoaks Reg 18 consultation.

7) Crawley itself

The Inspector recently wrote to Crawley setting out that ,whilst the plan will generate over 7,500 homes unmet need the DtC has been complied with.? Further details will be provided in the forthcoming final Inspector’s Report; however, it seems likely that the Inspector will report no clear plans for dealing with any of the unmet need.? The Submission Local Plan discusses the need to rely on Horsham, Mid Sussex and (to a lesser extent) Reigate and Banstead.

It is also understood that the identified supply of 5,330 is also the housing requirement, i.e. there is no supply buffer (but were one to be proposed the housing requirement would reduce and unmet need would rise accordingly).

Conclusions

The Crawley sub-region warrants being a focus of attention, because: A) it is bounded by notably distinct sub-regions; and B) unmet need is a major issue.

Indeed, the majority of LPAs are generating or at risk of generating unmet housing need. Taking published evidence at face value:

• Only one LPA has identified potential to provide for modest unmet need.?
• Guildford, Waverley and Hart stand out as not having recently published evidence of no capacity for unmet need, but poor links to Crawley.
• The only other LPA without recent evidence to suggest no capacity for unmet need is Reigate and Banstead, but this is an unlikely option.?
• Attention also potentially focuses on East Hants, but they are constrained and better suited to providing for unmet need from South Hampshire.

The situation across the sub-region serves as clear evidence that standard method housing need could never be effectively applied as a mandatory target for local plan-making.? However, it has historically been sold as such.

The Duty to Cooperate has failed.? It is overly procedural with insufficient focus on outcomes.? Future processes are relied upon that do not materialise or prove ineffective, namely local plan reviews and sub-regional strategic planning.? The primary case in point is recent reliance a Greater Brighton and West Sussex LSS3.

There is a clear need for strategic planning, e.g. as evidenced by the reference in the Tandridge Inspector’s Report to “rounds of planning”.? There are no established rounds of planning, hence the concern is that timing is too easily used as an excuse not to provide for unmet needs.?

In the absence of strategic planning, there must be a new emphasis on exploring what will or could happen to unmet need as a prerequisite for soundness. In other words, the potential to generate unmet need must, to some extent, be dependent on the risk of the unmet need staying unmet.? The bar need not be set high. However, as a minimum, there is a need to acknowledge challenges and risks at the earliest opportunity when considering unmet need generation.

Also, in the absence of strategic planning, there is a need for guidance on:

• Reducing plan periods to avoid unmet need.
• Allowing a stepped housing requirement to avoid unmet need – stepped requirements are increasingly not the exception.? They are also a major complicating factor for those seeking to understand plan-making.
• Providing for a supply buffer – is standard practice where the proposal is to set the housing requirement at need, but not where the proposal is to set the requirement below need.? Is there a clear basis for this?
• Exceptional circumstances – there is a need for urgent clarification on whether this applies to both need and the requirement / unmet need. Also, before concluding a need figure below the standard method, is there a need to consult with neighbouring LPAs?
• Decisions on whether to review – must factor-in unmet need.

As well as very high levels of unmet need, as measured against the standard method, what is also evident is the lack of a plan-led approach to growth in many areas over many years, i.e. all or much growth being ‘speculative’.? To repair the national reputation of planning we need a plan-led system.

There is current unmet need from London that has not been provided and has not been factoring-in.? The Enfield Local Plan (2024) proposes significant Green Belt release but nonetheless explains “by the end of the plan period, there will... be an estimated shortfall of approximately 38,000 homes in the Borough when compared against… housing need.”?