Response to HDC's Local Plan Review
Published: 23 March 2020
Whilst we appreciate the work that goes into developing the local plan and the challenges of developing a plan the whole district will be comfortable with, we believe the draft local plan contains a number of factual inaccuracies and has reached conclusions that do not appear to be based upon solid information.
Under strategic policy 6; we notice that the standard methodology calculations result in a requirement of 965 dwellings per annum. We note that The Ministry of Housing, Communities and Local Government committed in September 2019 to review the standard methodology formula using national statistics data. The Office for National Statistics (ONS) is also in the process of revising its household projects, which are due to for publication in late spring or early summer 2020. Given that the ONS household projections have been consistently lower since 2014, that Government focus is on growth in the Midlands and North of England and the impact of Brexit on immigration it would be a fair assumption that the revised methodology will result in a lower housing allocation. Given that the HDC local plan will span up to 2036 it seems foolhardy to commit to figures based upon a soon to be outdated methodology which could result in excessive housing being built in the district. There is a recent example of excessive development which we would like to note; when Crawley figures were tested it was found that Crawley were delivering about their expected trajectory.
Policy 14, Housing provision; we believe this policy is inconsistent with the spatial objective number 3, which states that development should be promoted appropriately within existing settlement hierarchy and diversity of settlements. If this objective were to be achieved the settlement of Horsham would need to meet ~40% of the housing growth. From the plan it would appear that the settlement of Horsham is currently allocating 15% of the requirement based upon a housing figure of 1,000 dwellings per annum. The plan should be looking to allocate more sites based upon the settlement hierarchy. Should it be deemed unsustainable for Horsham Town to deliver a fair allocation then the next level down in the hierarchy should be looked at to deliver the required development.
Policy 14, Strategic sites; the draft local plan refers to the strategic site at land north east of Henfield (SHELAA Reference: SA414) as “Land North East of Henfield (Mayfield)”, which is inaccurate and misleading. There is no such place as Mayfield in Horsham District, as such the site name that has been applied in the draft local plan is misleading. The title of all the other strategic sites within the document simply refer to “land at [location of land]”, to label this site as Mayfield not only infers a degree of acceptance to the developer’s proposals, it also misleads the reader and does not acknowledge the fact that this a green field site.
The site description is inaccurate; referring to the landscape beyond the site as countryside with the south western boundary being located close to Henfield. The hamlet of Blackstone, part of Woodmancote Parish, is located extremely close to the southern boundary of the proposed site. Blackstone has a strong cultural heritage, has a dwelling named in the doomsday book, which was completed in 1086, contains at least 5 listed buildings and the vast majority of Blackstone is a designated conservation area. Blackstone already has a significant issue with traffic using it as a cut through route to and from the A281 to the B2116 which would be exponentially increased should development take place at proposed site to the north. Additional traffic, and the emissions that it would bring, would destroy the heritage of Blackstone and have a devastating impact on its historical rural character, not to mention the risk of in the longer term of the historical and new settlements coalescing. To omit the proximity of Blackstone to the proposed development site is to omit a vital detail from the document that misleads the reader as to the impact development of this site would have upon the cultural heritage of Blackstone and as such is unacceptable. Blackstone is only six miles from Devils Dyke, awarded Dark Sky Status and a large-scale development would result in significant light pollution. The omission to consider Blackstone as part of the assessment of strategic site suitability may also explain why the site has been rated as having a neutral impact with respect to archaeology/heritage. Anyone who has visited the southern part of the site and Blackstone would see that development at this site would have a very negative impact on heritage and which would be unlikely to be mitigated given the current and proposed transport infrastructure in the area.
We are appalled to see the assessment applied to transport for this site was unfavourable, with the potential for mitigation. The road network in the area consists of rural roads that are already struggling with the current volume of traffic. As noted in the assessment of the site, there are no A roads within the vicinity. The rural location of the site means that cycling to the key employment areas of Crawley, Gatwick and Brighton is quite simply not possible. The public transport in the area has been in decline for some time and has limited operating hours, as such it is not a viable option for commuters. As such residents of any development will have to use cars for transportation, not to mention the number of delivery vans that online shopping will generate for 7,000 houses. The nearest railway stations to the site are located in Mid Sussex at Hassocks and Burgess Hill. To reach Hassocks station a 9km drive through the rural villages of Albourne and Hustpierpoint is required, with Hurstpierpoint already representing a significant bottle neck and unable to support any increase in traffic volume. It should also be noted that parking facilities at both Hassocks and Burgess Hill stations are already over capacity and therefore these stations would not be able to support the increase in use that would be required should this development proceed. I note the impact on air quality has also been raised in the site assessment. For these reasons it is clearly not possible to mitigate the impact of additional traffic, even if a new road to the A23 were to be built by the developer, as such this should be rated as unfavourable, with impacts unlikely to be mitigated.
The subject of transport infrastructure should of course be taken into consideration when reviewing the developers claim of creating 7,000 new job through the provision of B1 and B8 uses. Whilst the developer could of course build B1 and B8 units they can make no claim in terms of attracting businesses to occupy these spaces and thus create jobs. Given the proposed transport infrastructure any reasonable person would find it highly implausible that a storage and distribution company (B8 unit) would find the location conducive to the success of their business. Equally the type of company that would occupy a B1 unit (offices, light industry and R&D) would find the inaccessibility of the site counterproductive and therefore would be highly unlikely to rent such units. The additional volume of traffic on the rural road network would of course also have a negative impact on existing businesses in the locality. We believe these points should be taken into consideration when rating the economic attractiveness of this strategic site, and as such the impact would be unfavourable.
The proposed site contains three water courses including the River Adur (which is tidal up to Shermanbury), it is on a flood plain and virtually all on clay which floods in the winter. Indeed, the site has recently been subject to extensive flooding as evidenced by a recent article in the County Times. Flooding that takes place in the upper catchment area (Adur East and West Branches from Henfield / Shermanbury to Burgess Hill), sees a significant amount of water held within the associated floodplains but also within many areas of surrounding land which is not recorded or referenced by computer modelled flood maps and is therefore overlooked by local authorities. Local people are only too aware of the flooding that takes place with flooding, in the Lower Adur catchment as far as Albourne on the Adur East Branch. Roads are flooding with increased frequency and whilst only water entering a property is considered in terms of flood defence erection, the disruption to local travel and risk to people’s health should not be overlooked by events outside of people’s properties. The A281 road often floods at Mock Bridge Shermanbury, as does the A2037 at Woods Mill, the B2116 from Henfield and the roads eastwards to the A23 through Wineham and Albourne roads. Any attempt to mitigate the flood risk through the use of techniques such as the use of SUDS will not work when placed in areas of high soil moisture and groundwater conditions (such as the proposed strategic site) as there will be limited capacity to contain the necessary amount of flood water. Given the increased volume of water outflow that 7,000 houses will create, the existing extensive flooding, the site being located on flood plains, the downstream flooding impact of the site and the inability of SUDS to address these issues we believe the flooding/drainage impact has been incorrectly rated. A report on the potential impact of large-scale housing developments on the River Adur was submitted to HDC, by the IPG in the last quarter of 2019, which clearly demonstrated the site should be rated as red (very unfavourable impacts where impacts are unlikely/unable to be mitigated).
The fact that the proposed site is situated on a flood plain also raises the question as to the viability of replacing the electricity pylons on the site with underground cables. Replacement of pylons is known to be costly, given the additional complexities of doing so on a flood plain it is felt that is highly unlikely the developer would be able to deliver on such a commitment. It is highly unlikely that this would be economically viable. We request that evidence as to the costs and economic viability of this part of the proposal are considered before the inclusion of this element in the decision-making process.
The assessment of the strategic site at land north east of Henfield (and north of Blackstone) also contains a commitment from the developer to supply four new schools (early years, primary and secondary schools as well as SEND provision). We highlight that whilst a developer can construct the buildings it is the responsibility of the County Council to actually operate and run the schools and clearly, there is a major expense involved in this. Equally the mere possibility of a link to Plumpton College is spurious unless the developer can provide evidence of a commitment from the college to run these offered schools. Without the commitment of WSCC or Plumpton college to adopt and run these four sites this claim is without any real meaning and as such should be removed from the site assessment.
The assessment of the strategic site at land north east of Henfield (and north of Blackstone) also contains a commitment from the developer to construct a healthcare facility. Again, whilst the developer can construct such a building it is the responsibility of the Clinical Commissioning Group (CCG) to operate such a facility. Unless the developer can provide evidence of an agreement with the CCG to adopt such a facility this claim is without any real meaning and as such should be removed from the site assessment.
With regards to biodiversity; given that the site is home to multiple red listed species we find it implausible that any developer can claim
to be able to deliver a 10% net biodiversity gain by building 7,000 houses on the site. Whilst we appreciate that is this a stipulation that Horsham District Council has for all strategic sites without any substance to back up these claims from the developer such a commitment is meaningless. The mere offer not to build upon ancient woodlands (development of which would not be permitted anyway) and the laughable claim to leave all hedgerows in situ does not constitute a viable plan to achieve such an ambitious target. As such this claim from the developer should be discounted.
Finally, the deliverability of the strategic site is questionable. We are aware that many of the owners of the land within the strategic site are firmly against this proposed development. Many have stated that they will never sell their land for development. We believe this represents 30-50% of the total landmass of the whole strategic site as such there is no possibility of this development ever being delivered to anywhere near the proposed vision of the developer. This site should be discounted by Horsham District Council on these grounds alone, let alone all the points made above.
Woodmancote Parish Council firmly objects to this strategic site and we ask that Horsham District Council rejects this site immediately.