Agenda item

To receive questions from Parish and Neighbourhood Councils, as an extension of 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 from Parish and Neighbourhood Councils.

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 answer are submitted within the first six received, the first one submitted will receive an oral reply.   

The representative for Storrington & Sullington Parish Council asked the following question:

‘Following the Regulation 18 consultation in 2020 there were 622 comments. The vast majority of these were objections, including from several Parish Councils and also from Andrew Griffith, M.P. The support, unsurprisingly, was mainly from developers. There was further consultation of PCs in September of this year. Speaking for Storrington & Sullington, we objected very strongly to the sites proposed for inclusion in our parish and offered alternative sites more acceptable to the public. We believe that other PCs were equally dismayed.

Given that the Government has stated that development plans should be “bottom up” can you please explain how you consider that this complies with that requirement and what changes were made to site allocations following these meetings? We were clearly told that our objections would be considered yet, certainly for Storrington & Sullington, there have been no changes in allocations since the previous incarnations of this plan.

We have a made Neighbourhood Plan which designates one green gap between Storrington and West Chiltington. The allocated sites lie immediately within that gap. The Neighbourhood Plan is the most recent evidence of what the public will support and has been completely disregarded by HDC. How is this “Bottom up” planning?’

Councillor John Milne clarified that there were over 6000 representations, as opposed to 622 quoted. On behalf of Councillor John Milne, Cabinet Member for Planning & Infrastructure, Councillor Sam Raby, Cabinet Member for Housing, Communities & Wellbeing replied:

‘Thank you for your question.

As you will be aware, Horsham District Council must prepare plans which are in accordance with the NPPF. Plans must be consistent with national policy and be based on proportionate evidence. They must also cover a 15-year period starting from the date plans are adopted.

Existing Neighbourhood Plans across the district cover the period to 2031. The new local plan, if agreed, will cover the period to 2040.  This means the Council must allocate a significant number of additional sites, or we would end up with a 9-year hole in the numbers with zero allocation. This an innate flaw of the planning process, as Local Plans and Neighbourhood Plans have different obligations to be fulfilled over widely different timescales.

All allocations must meet NPPF requirements. As you note, we have worked with Parish Councils to consider whether the suggested alternatives meet the criteria for allocation. Where these have not been included, it’s because officers concluded they could not demonstrate the minimum NPPF criteria of being suitable, available and achievable.

I realise this plan contains sites which will contradict local preferences, and in practice it’s hard to see why this wouldn’t happen with every local plan. But we still incorporate your views where we can. 

For example, draft policy ST01 specifically requires an application must be supported by a Landscape and Visual Impact Assessment. In the case of Land North of Melton Drive, our strategy is to permit development but only in the southern half of the site, while landscaping the rest. We believe this to be the most effective way to create a long-term defensible landscape boundary. It's hoped this will protect the parish against the concerning precedent set by an unwanted approval at appeal of a neighbouring site, which might otherwise encourage further expansion towards West Chiltington.’

The representative for Itchingfield Parish Council asked the following question:

‘My question relates to page 173 of the draft Plan. The preamble to the section of the Plan dealing with set allocation reads (at para 10.133) The Parish has made good progress with the preparation of its neighbourhood plan. Following a successful examination, at the time of writing the plan has been unable to proceed to referendum in light of the Position Statement on water neutrality. The plan is expected to enter the final stages of plan making, and applicants should therefore be mindful of the content of the Neighbourhood Plan in this parish. 

With this in mind, why does the District Plan allocate for development three sites, two of which were rejected by the parish after careful analysis and which are therefore considered by the parish to be unsuitable for development? In this context it should be noted that HDC has, until now, fully supported the content of our draft plan, including the allocation of development sites.’

On behalf of Councillor John Milne, Cabinet Member for Planning & Infrastructure, Councillor Sam Raby, Cabinet Member for Housing, Communities & Wellbeing replied:

‘For clarity, as the page numbers you refer to won’t match the page number on all printed copies, this question relates to Strategic Policy HA6: Barns Green.

Existing Neighbourhood Plans cover the period to 2031. The new local plan, if agreed, will cover the period to 2040. This is to ensure it’s in accordance with the NPPF requirement that a plan must run for 15 years from adoption.  Therefore, the Council must allocate a significant number of other sites beyond what’s in neighbourhood plans, in order to ensure delivery over the entire period, not just till 2031.

In doing this, we have taken account of feedback provided to us through both formal consultation and Parish workshops, the most recent of which were held in September this year. We’ve specifically referred to the progress of your neighbourhood plan to take account of this feedback.’

The representative for Southwater Parish Council asked the following question:

‘The Local Plan designates Southwater as a village/small town suitable for development and a Strategic Site. The plan states that development up to 2040 will be an extra 285 homes (plus 450 homes in the Southwater Neighbourhood Plan), 735 homes plus the build out of the existing Berkeley site (of Broadacres) circa 300 in total over the plan period to 1,035 homes and another 265 for the period beyond 2040 at a build out rate of 50 per year will take the development period to 2045.  Also noting the impact of the peripheral sites of Rascals Farm and Woodfords of just under 200 additional units right on the boundary of Southwater.  The Local Plan will effectively turn Southwater into a building site for the next 22 years.  Is this fair to the residents of Southwater and is it sustainable?’

The representative then asked why the Southwater Neighbourhood Plan review must be delayed, to await the revised National Planning Policy Framework (NPPF), whilst the District Local Plan would go ahead. It was confirmed that the review would need to be in accordance with the NPPF, as well as the District Local Plan.

On behalf of Councillor John Milne, Cabinet Member for Planning & Infrastructure, Councillor Sam Raby, Cabinet Member for Housing, Communities & Wellbeing replied:

‘Thank you for your question. I am only going to be able to respond to the question as submitted because I am [acting as spokesperson] and so I am not going to be able to add the supplementary information, but I will read out the [response] that has been prepared to your question. Southwater is designated in Policy 2 of the Horsham District Planning Framework (HDPF) (November 2015) as a “small town and larger village”.  Such locations are classed as “settlements with a good range of services and facilities, strong community networks and local employment provision, together with reasonable rail and/or bus services. 

After Horsham, Southwater along with Billingshurst, Broadbridge Heath, Henfield, Pulborough, Steyning and Storrington, was classed as one of the next most sustainable locations in the 2015 Local Plan and this remains the same today.  

Like local authorities across the country, we have a mandatory housing target requiring us to build 1,000s of houses over a very long period. I don’t see how this can be done without implying continuous construction wherever it is. But only a part of the site will be operational at any one time. Some of the houses we approve today won’t even start for 20 years.

Compared to earlier drafts of the plan, we’ve managed to cut the number to 1,000 from 1200 as it was in all previous versions, or indeed the 1500 that was applied for in October 2022. 450 of this 1,000 are already agreed anyway in the Neighbourhood Plan.

The development will be expected to provide new infrastructure including a new secondary school, which will serve the needs of both the new and existing community.  The policy requirements HA3 sets out a wide range of requirements to ensure that the development which takes place is sustainable.’

The representative for Thakeham Parish Council asked the following question:

‘For a small village with virtually no facilities, infrastructure, and poor highways/transport options, surely there needs to be a clear steer from Planners on which option they favour; a) several less larger plots OR b) one large one (which is not currently in the plan but will undoubtedly be put forward by the developer Bellway Homes).  

We are not against reasonable housing development, but it needs to be proportionate and clearly set out in the Plan. Currently, the Parish council would like to know how Horsham District Council considered the appropriateness of setting a housing allocation of 65 dwellings across various plots in Thakeham Parish which, if development proceeded on at least two of them - would exceed the housing numbers by more than a 10% variance as listed in the plan? Accumulatively, this would represent a very significant number of dwellings (65 plus 55 off Rock Road) when the possibility of hundreds of houses on the former mushroom farm is currently out for consultation but not included in the draft plan. Therefore, in asking this question - we seek an answer that would explain how these significant developments would impact on the capabilities accounted for in the proposed plan as there seems to be no contingency in place other than the Objection to large scale developments due to the strains put upon infrastructure as the delivery of infrastructure across Thakeham, our neighbours in the outlying Parishes and the district as a whole is predicated 65 +10% and not 620 (at our last count of potential dwellings).’

On behalf of Councillor John Milne, Cabinet Member for Planning & Infrastructure, Councillor Sam Raby, Cabinet Member for Housing, Communities & Wellbeing replied:

‘Thank you for the questions.  With regard to the large site you mention, until it’s actually promoted for inclusion in the Local Plan process, we can’t comment. Clearly, sites not formally presented can’t qualify as either available or deliverable.

We have tested various options for growth in our Sustainability Appraisal process. This analyses the ability of the District to accommodate different levels of growth, and where it might be located. This process was mostly carried out under previous HDC administrations and indeed the readying of sites for potential approval is a matter of many years, not months. It was decided that growth should be concentrated around Horsham, urban extensions and some growth of villages and towns in accordance with the level of services and facilities to be the most sustainable option. 

A full appraisal of all options was then undertaken, and the results compared to ensure that only the most sustainable mix of sites was taken forward to allocation. It is those sites which have been included in the Regulation 19 document.

The Council has sought to allocate two sites on High Bar Lane which together could deliver 65 homes.  Our evidence indicates that, as a settlement, Thakeham (as in The Street and High Bar Lane), is able to accommodate such growth. There were a number of other sites in the Parish which have not been recommended for allocation. 

In addition, we recognise too that the site on Rock Road, a proposed allocation for 55 homes is within Thakeham Parish.  This is referenced in the draft Regulation 19 document as well as in evidence documents, such as the Site Assessment Report.  However, as the site immediately abuts the settlement of Storrington, if developed it would form part of the Storrington Built Up Area. In assessing the site, the Site Assessment Report recognises that any future resident would likely rely upon services in Storrington.  Accordingly, we have identified the site in the Storrington section of the Regulation 19 Local Plan.’