Agenda item

To receive questions from the public under Part 4 Rules 4j2.1 – 4j2.13

 

A maximum time of 20 minutes, or six questions, whichever is the greater, will be allowed in the meeting to receive oral questions and answers.

 

In the event that more than six questions are received by the deadline (no later than 12.00 noon on Wednesday 6 December to committeeservices@horsham.gov.uk, including the name and address of the questioner), written answers will be provided within 10 working days of the meeting for those that cannot receive an oral answer.

 

In the interests of transparency and fairness, if similar questions that require the same or similar answers are submitted within the first six received, the first one submitted will receive an oral reply.    

 

Mr Trevor Leonard asked the following question:

 

‘A multitude of groups representing the Billingshurst community (which includes the Parish Council, the Billingshurst Sports and Recreation Association, the hugely respected Billingshurst Community Partnership, Billingshurst Tennis Club and importantly, a range of environmental and other groups including BilliGreen, Sussex Green Living, Save Little Daux and Sussex Wildlife Trust) have all written to HDC to give their support or preference for development to the West over East. Together these groups represent thousands of Billingshurst residents.  

 

Whilst developers to the East have consistently rejected attempts from the community to engage with them, the developers to the West have not only fully engaged but have entered into a legal binding agreement to ensure that commitments made to provide much needed community infrastructure are delivered at an early stage of any development.

 

Given this very clear community support and the symmetry between the requirements of the Levelling Up and Regeneration Act 2023, which requires new development to be “shaped by local people’s democratic wishes” and the Lib Dem 2023 manifesto pledge to “care about communities and their residents” and the slogan, a “Lib-Dem victory means the Council will be listening to YOU”, could you please confirm that you as a committee will not be supporting the Reg. 19 Local Plan as currently drafted by officers which proposes to totally ignore this clear community support and instead allocate land West of Billingshurst rather than development to the East of Billingshurst?’

 

Councillor John Milne, Cabinet Member for Planning & Infrastructure replied:

 

‘Thank you for your question. For clarity, a Local Plan is a matter for the whole council to decide, not just myself or the Cabinet. All the sites in the Plan face at least some level of local opposition. But at the same time, we’re obliged to choose at least some of them. So, from the start, it’s clear that not every public wish can be granted.

 

However, in practical terms the consultation has been very helpful. Officers have made numerous changes to the plan to reflect the concerns of communities across the District, within the constraints of national planning law. Many of these changes are detailed in appendix 2 of the Cabinet/Council report.

 

With any site, the primary consideration by far is that it meets planning law and stands a strong chance of approval by a national planning inspector at Examination. In the case of Billingshurst, while I note the claims that there is more support for the proposal to the West, we have received no clear evidence one way or the other. In the Regulation 18 consultation we received 11 supportive comments for the allocation of West of Billingshurst and 243 objections. The East of Billingshurst received 33 comments of support and 279 objections.

 

That’s the only formal evidence we have available, and it shows public opinion divided roughly 50/50. It was also apparent when myself and officers met with the Parish Council recently to discuss the Plan, that there were supporters and opponents of both options.

 

I would add that a majority of residents and the parish council would prefer no development at all. The West site allocation is for half as many houses again as the East, a very considerable extra difference. As we’ve successfully reduced our overall district target, this is many more houses than we actually need.

 

In the long term, allocating the West would open up the west side of the A29 to such an extent that further large-scale development would be very, very hard to resist on planning grounds. There’s just no obvious limit to the growth of Billingshurst once you break that barrier. I question whether that’s what residents really want.

 

I hope to arrange a meeting with the Parish Council in the new year to discuss additional civic investment in Billingshurst, using funds outside the Local Plan process.’

 

Ms Melanie Holliker asked the following question:

‘This question is regarding HDC’s draft proposal to allocate the east of Billingshurst for development rather than the west. The?developer proposing to develop the east site makes little effort to meet the criteria in?strategic policies 8 & 17 ‘Sustainable Design & Construction’ and ‘Green Infrastructure and Diversity’. It will build to current building regulations only. It would remove a significant green space valued by residents and commits to only 10% Biodiversity Net Gain. 

?In contrast, the developer proposing to develop the west site does much to fulfil policies 8 & 17. It proposes: 

·       To build to the Future Homes Standard, above and beyond current building regulations 

·       Sustainable design using the principles of?‘20-minute neighbourhoods’ 

·       Approximately 50% Biodiversity Net Gain by rewilding 90 acres of land to create a nature reserve, to be placed in public ownership improving access to nature for all Billingshurst residents. ? 

In our current climate and nature crisis, can you justify this decision in the light of policies 8 and 17?’

 

Councillor John Milne, Cabinet Member for Planning & Infrastructure replied:

‘Thank you for your question. Any development must be compliant with our new Local Plan policies. That includes Strategic Policy 8 ‘Sustainable Design and Construction’ and Strategic Policy 17 ‘Green Infrastructure and Biodiversity’ which sets a requirement for 12% biodiversity net gain (BNG). Land East of Billingshurst therefore must meet all policy requirements, and that includes the points you itemise.

Whilst I understand that new developments can cause adverse environmental impacts, there is a fundamental issue at stake. People need houses. All the large locations proposed to us are on greenfield sites. There’s no way an area like Horsham can avoid greenfield development under current government rules.

I also stress that the Local Plan hugely increases our ability to insist on carbon neutral building standards, as well as new protections for the wider environment.

Without an up-to-date local plan and a 5-year land supply, speculative developments will continue to come forward. Key policies such as the restriction on building outside the Built-Up Area Boundary would carry little weight. For example, HDC was obliged to accept an application for 83 homes at Duckmoor near Billingshurst, even though it was against district policy. And that’s far from the only example.

Land East of Billingshurst is a logical extension to the village, with defensible boundaries to inhibit further development. Much needed affordable homes can be delivered, in a timely manner, alongside a number of community facilities such as a new primary school, informal recreation space, and a community hub.  Its proximity to village facilities and services, including the railway station and secondary school, in conjunction with the proposed pedestrian and cycle routes, all combine to make the ambition of a ’20-minute neighbourhood’ genuinely achievable here.  This site is therefore well-placed to meet Strategic Policies 8 and 17 if not exceed them.’

Mr Andrew Bardot asked the following question:

 

‘SP9 para 1 concerning Water Efficient Design provides in sub paragraph a) that “new residential development is designed to utilise no more than 85 litres of mains supplied water per person per day.” As HDC and Natural England are aware, 85 litres is a purely aspirational and entirely theoretical consumption figure which flies in the face of readily available actual water use data for this district and nationwide which is very considerably higher than, and in many cases almost double, the 85 litres figure. The company which HDC, Crawley and Chichester retained in 2022 to retrofit 100 council properties in Crawley with flow restrictor devices provided HDC with its own actual use data for all properties fitted with its flow restrictor devices from 2020 to 2022. This data shows that after installation of water flow restrictors there is an average consumption of 166.52 litres per person per day.  

  

Furthermore, HDC has publicly stated (in the Woodfords application) that contrary to the very clear requirement and direction from Natural England it will not monitor water use in new build properties nor ensure enforcement of the 85 litres target.  

  

Why does this matter? It matters because the lower the target water use figure for new builds, the easier it becomes for developers to have their applications approved which will inevitably result in the building of houses across the district which will be very far from water neutral.   This will increase the very real threat to our district’s finite water supply until a permanent solution to sustainable water supply in our district has been devised, implemented, and tested.  

  

So, our question is why is HDC bending over backwards to benefit the house builders by endorsing and adopting this absurd 85 litres per day figure, needlessly exposing our District to the real risk of exhaustion of its finite wate supply when it should be requiring and enforcing a realistic daily water use target for new build development and challenging government housing targets?’

 

Councillor John Milne, Cabinet Member for Planning & Infrastructure replied:

 

‘Thank you for your question. There are two aspects to water neutrality. First, we have to ensure new development is as water efficient as possible.  Second, any additional water use must be offset against existing supply.

 

Our Policy will require that new developments are built to much higher water efficiency standards than applied in the past. In joint consultancy with Crawley and Chichester, the other affected areas, a new average usage figure of 85l per person, per day has been agreed.

 

I stress, the 85 litres standard for new builds is separate from our offsetting strategy for existing properties. We’re not attempting to get all homes working to an 85-litre average and it wouldn’t be possible anyway.

 

Older properties are inherently less water efficient. It’s correct to say that in the Crawley pilot, water use after retrofitting remains high at 166.52 litres per person per day. However, before the installation of flow restrictors, these properties used an even higher average of 199.85 litres per person per day. Therefore, retrofitting has cut that by 30 litres which can be used to offset new development elsewhere.

 

The trial has been a positive experience for residents. They continue to use appliances as normal, while benefiting from a significant cut in both their water and heating bills. Although that wasn’t the reason for doing it, it has turned out to be a useful contribution to the cost-of-living crisis. It might even catch on with private households in the long term.

 

This joint strategy was agreed with Crawley and Chichester and endorsed by Natural England last year. It’s important for the council to honour its commitments. Crawley’s Local Plan is currently at Examination stage and no relevant issues have been raised by the Inspector.

 

Over time, the Water Neutrality check on development is reducing. Applicants are increasingly able to demonstrate their own water neutrality schemes.  There’s no doubt this is going to happen more often, and with much larger sites.

 

For this reason, we recognise we’re in something of a race against time, to get the plan passed and regain control of district planning. Further delay, with no clear objective in mind, risks having much higher housing targets imposed on us. Potentially 2 or 3 times higher in the first years.’

 

Mr David Brown asked the following question:

 

“Why has the lack transport infrastructure for the development of land West of Ifield been ignored against the advice from multiple transport studies by both Horsham and Crawley on the aspirational concept of a "15-minute community?”  The published Horsham Transport Study Local Plan 2039 Transport Assessment - 2023 Update App 8.  to support the Local Plan identifies Land West of Ifield as the largest development in the area with no mitigation for traffic uptake, where previous studies identify needs and mitigation.”

 

On behalf of Councillor John Milne, Cabinet Member for Planning & Infrastructure, Councillor Ruth Fletcher, Cabinet Member for Local Economy & Place replied:

 

‘Thank you for your question. As part of the preparation of the Horsham District Plan, Horsham District Council has undertaken extensive transport modelling to ascertain the impacts of the plan. This is a mandatory requirement. We have used the WSCC approved methodology It would be difficult to diverge significantly from their assessment.

 

This document is available to view on the Local Plan evidence base pages. It identifies mitigation measures designed to accommodate levels of increased traffic in the area. These include the measures set out in Policy HA1, and the reference in paragraph 10.98 that require any impacts on Rusper to be taken into account.

In addition, there is an extension of high-quality Fastway bus services to serve the development. An active travel design concept will offer direct, attractive walking and cycling links to Ifield Station and village, and into Crawley Town centre.

If the plan is agreed this evening, further work on the detailed transport impacts arising from this scheme would still be necessary to support any eventual planning application.  Officers will continue to seek the necessary detail from Homes England and will challenge this data if they consider that impacts on Rusper or indeed the road network more generally have not been adequately addressed.’

 

Mr Chris Poland asked the following question:

 

‘Despite responding to your local consultation with over 120 letters of support, being included in your own Playing Pitch Strategy Actions and Recommendations as a club in need, receiving two letters of support from Sport England and England Hockey we appear to be unsupported by this proposed plan. 

  

I understand this Council has taken the decision not to include Horsham Golf & Fitness Village within the draft Local Plan and therefore deny Horsham Hockey Club the opportunity to secure a fully funded new home at no cost to the Council or the club. 

  

Given this decision, please can the Council explain how it intends to deliver the sports and leisure facilities it has identified as being needed within the District (specifically, new facilities for Horsham Hockey Club) which were proposed to be delivered as part Horsham Golf & Fitness Village and are not included in any other scheme, and why no Politician or Officer from the Council is actively engaging with my club to support us and our 320 members.’

 

On behalf of Councillor John Milne, Cabinet Member for Planning & Infrastructure, Councillor Jon Olson, Cabinet Member for Leisure, Culture & Green Spaces replied:

 

‘Thank you for your question.  The provision of facilities for Horsham Hockey Club is one of the council’s priorities with regard to leisure facilities. Officers across both Leisure and Planning departments have actively engaged with the Hockey Club during the plan preparation process. We have established your requirements, which are summarised as “two sand-dressed, floodlit artificial playing pitches, ideally as part of a sports hub with a clubhouse and associated ancillary facilities”. 

 

There has also been correspondence between the Hockey Club and planning officers during the Course of plan preparation.

Land at Horsham Golf and Fitness has not been proposed as an allocation in the Local Plan.  The results of this assessment are set out in Appendix 7a of the Cabinet report.  Investment in sports facilities is always welcome, but that can’t be the sole criteria. As a whole this proposal fails to meet the tests of sustainable development as set out in national policy and is therefore not recommended for allocation.

 

As you will be aware, separate to the Local Plan process a planning application has been submitted, for development at Horsham Golf & Fitness including Hockey pitches. This application is yet to be determined and I am therefore unable to comment further now. Officers have endeavoured to secure appropriate facilities within the allocated strategic sites and will continue to seek to actively engage in this respect.’

 

Ms Fenella Maitland-Smith asked the following question:

 

‘What is the evidence that residents have been properly consulted during the drafting of this Plan, their Neighbourhood Plans respected, and their concerns about over-development in the District as a whole taken into account in the Plan? My concern is that the plan is confused and not fit for purpose. Pretending to be is one thing, but at its heart it is something quite different. It does have strengthened environmental policies and this is welcome, but it does not present a vision for a sustainable future. In fact, I have struggled to find a statement of a 30-year vision at all and that is because at its heart it is still the same old plan for overdevelopment.

 

This plan perpetuates the existing rate of house building, pulling more and more people into the area, driving population growth at current rates which will cause house building targets to be even higher in the future. We now have the highest rate of population growth of any Local Authority in Sussex or Surrey and double the national average.

 

The Council and the plan need to acknowledge this, and call it to a halt, but instead the plan is full of aspirational policies and long lists of requirements on developers which are unlikely to be satisfied and I include the water neutrality strategy in this. There’s so much uncertainty around at the moment and such a lack of detail in the plan that I fear we’re heading for a mess: insufficient infrastructure, insufficient social housing and no end to developers and finance profiting at our expense and nowhere is this more the case than in the West of Ifield site.

 

Finally, Cabinet Members have made no secret of the fact that they’re pushing the plan through in case water neutrality requirements are pulled, and to stop speculative applications, but changes to the NPPF will be published in the next few weeks which could reduce risks like this and potentially offer further opportunities to reduce housing targets and have a properly sustainable plan for the future. Please do not vote for anything less.’

 

On behalf of Councillor John Milne, Cabinet Member for Planning & Infrastructure, Councillor Martin Boffey, Leader of the Council replied:

 

‘Thank you. I shall answer the question, as submitted. I disagree with your list of ’givens’ but to the question itself: in fact, the Council has extensively consulted residents during the Plan process. Two rounds of consultation were carried out under Regulation 18, in May 2018 and February 2020. In the second of these, the Council held public exhibitions, distributed 5,000 leaflets across the District, and extensively publicised the consultation via email and social media.

Over the last few years, bespoke consultation workshops focussing on potential development sites were undertaken with parish and neighbourhood councils, including in September 2021 and very recently in September 2023. Three open public events were additionally held in May 2022, in Horsham, Pulborough and Ashington.

 

For the local plan to be found sound, we are legally obliged to meet the requirements of the NPPF, the National Planning Policy Framework. That includes sufficient provision to meet our housing target. Failure to do so means planning by appeal and would completely undermine our ability to enforce higher standards in respect of both the environment and net zero construction.

I further note that parishes benefit from access to a Senior Neighbourhood Planning officer at the Council. Along with the Strategic Planning team, he has worked directly with parishes to align the Local Plan as closely as possible with both made and emerging Neighbourhood Plans across the District.

 

Finally, even where sites are recommended for inclusion against public wishes, this doesn’t mean consultation makes no difference. There have been numerous improvements to the plan reflecting community concerns. But often the local preference is for no development at all, and this is impossible to follow. You can find many of these changes in appendix 2 of the Cabinet/Council report.”