(“Bellway”) and Crest Strategic Projects (“Crest”)...Enhancements to green infrastructure,...

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11 August 2020

Neighbourhood Planning Officer Horsham District Council Parkside Chart Way North Street Horsham RH12 1RL

Dear Sirs Billingshurst Neighbourhood Plan Regulation 16 Consultation Consultation Representation in relation to Land East of Billingshurst, Little Daux.

Introduction

1.1 This representation is submitted to the Horsham District Council (HDC), on behalf of Bellway Homes Ltd (“Bellway”) and Crest Strategic Projects (“Crest”), in relation to the Billingshurst Neighbourhood Plan Regulation 16 Consultation.

1.2 This representation specifically relates to the key aspects of the Billingshurst Neighbourhood Plan (BNP) that are relevant to the Land East of Billingshurst, Little Daux (the Site). It follows the representation made to the previous consultation on the Regulation 14 Draft BNP, and seeks to highlight any comments or concerns to help ensure full consideration and enable the basic conditions to be met.

1.3 Significantly, it is highlighted that the summary of representations to the Regulation 14 consultation, as contained in the Consultation Statement (February 2020), does not refer to our previous correspondence with Billingshurst Parish Council (BPC) or our submitted representations made on behalf of Bellway and Crest. Clarification is therefore sought as to the reason why this representation is not acknowledged and whether the details and comments raised were in fact taken into consideration in preparing the Regulation 16 BNP. For ease of reference, the Regulation 14 Representation, dated 25 September 2019, is appended to this letter (Appendix A).

1.4 The BNP is now at the final consultation stage before being taken to Examination. As such it is essential that the plan meets the Basic Conditions, as confirmed in paragraph 37 of the National Planning Policy Framework (NPPF). This states:

“Neighbourhood plans must meet certain ‘basic conditions’ and other legal requirements before they can come into force. These are tested through an independent examination before the neighbourhood plan may proceed to referendum.”

1.5 The Basic Conditions set out within the Planning Practice Guidance (PPG), the Localism Act (2011) and paragraph 8 of Schedule 4B of the Town and Country Planning Act 1990 (as amended), are as follows:

a) “having regard to national policies and advice contained in guidance issued by the Secretary of State, it is appropriate to make the order or neighbourhood plan;

b) the making of the order or neighbourhood plan contributes to the achievement of sustainable development;

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c) the making of the order or neighbourhood plan is in general conformity with the strategic policies contained in the development plan for the area of the authority (or any part of that area);

d) the making of the order or neighbourhood plan does not breach, and is otherwise compatible with, EU obligations;

e) prescribed conditions are met in relation to the order or plan and prescribed matters have been complied with in connection with the proposal for the order or neighbourhood plan;”

1.6 The NPPF also makes clear the importance of the hierarchy of Plans. For Horsham, the BNP must therefore be in general conformity with the adopted Local Plan – the Horsham District Planning Framework (HDPF). It is relevant that HDC is progressing the emerging Local Plan Review which will replace the HDPF in approximately 18-24 months. Therefore it is important to ensure that the emerging BNP will not conflict with the emerging Local Plan Review, if it is to avoid future conflict and the possibility of becoming quickly out of date.

1.7 In this regard, the NPPF paragraph 29 makes clear that Neighbourhood Plans must not undermine strategic policies. There is no expectation for any strategic decisions to be made by Neighbourhood Plans and as NPPF paragraph 69 highlights, Neighbourhood Plans which make allocations should consider opportunities for small and medium sized sites. In this case, the BNP does not allocate sites for development, instead focusing on the sites that have already gained planning permission since 2011 or been allocated by HDC in the HDPF.

1.8 For the avoidance of doubt, this representation makes reference to S106 contributions and Community Infrastructure Levy (CIL). However, as BPC will be aware, the Planning White Paper consultation (August 2020) proposes to replace these levies with a new post development tax (‘Infrastructure Levy’). Therefore, where this representation refers to S106 and/or CIL, this should also be interpreted to mean any alternative that may supersede them as a result of the White Paper recommendations.

The Site

2.1 The site is being actively promoted through Horsham’s Local Plan Review for a residential led development. It is identified by HDC as one of the strategic housing options that may come forward in the emerging Local Plan Review (part of Site SA118). It lies to the east of Billingshurst and is outside of, but immediately adjacent to, the existing settlement boundary.

2.2 The site has an area of circa 37 hectares and comprises a number of agricultural land parcels located to the north of the railway line, albeit land to the south of the railway line has also been promoted for a longer term strategic development on behalf of Bellway only.

2.3 The Rosier Business Park is adjacent to but outside of the site and forms an existing business centre. There are two listed buildings adjacent to the site, comprising the Grade II Listed farmhouse at Little Daux Farm (listing ID: 1354140) and the Grade II Listed Rosier Farmhouse (listing ID: 1027129). Approximately 3.2 hectares of the site is designated as a Site of Nature Conservation Importance (SNCI), this will be enhanced as part of the development proposals.

2.4 The site’s western boundary abuts the existing settlement and is demarcated by trees, and the rear gardens of properties fronting Broomfield Drive and Brookers Road. There is an existing access into the site from Brookers Road and a footpath link from Broomfield Drive. Further access points are provided off Coneyhurst Road (A272) to the east and off the A272 to the north. This currently serves Little Daux Farm.

Strategic Development Opportunity at Little Daux

2.5 Representations sent to HDC in March 2020 indicated that the site (north of the railway), known as Little Daux, has capacity for delivery of 650 homes, including 35% affordable housing provision (circa 228 affordable homes). In addition to much needed housing, the proposed development at Little Daux will also deliver:

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A new community hub with the potential to offer a café, community hall, co-working space and an Ambulance Community Response Post;

Land for a new primary school at the heart of the development;

Dual-use playing fields as part of the primary school for use by the wider community;

An outdoor adult gym, park with a equipped play and recreation space, as well as links to a circular trim trail;

Enhancements to green infrastructure, including improvements to the SNCI on the site;

Additional Station Parking; and

Land for additional commercial floorspace at the southern gateway to the site.

2.6 In total, the site will deliver circa 18 hectares of green space, in addition to open space provision, ecological enhancements to Wilden’s Meadow SNCI and biodiversity net gains of 17.12% habitat units and 12.10% hedgerow units.

2.7 Notably, the development at Little Daux makes provision for all relevant infrastructure, including the provision of a new primary school, as part of the strategic allocation. As such, there is less uncertainty surrounding the delivery of this infrastructure in Billingshurst.

2.8 The site would be accessed from a new access onto the A272 to the east.

Representations to the Regulation 16 Neighbourhood Plan

3.1 The Regulation 16 BNP was published for consultation on 17 June 2020 and invites comments until 12 August 2020. Where relevant to the site, the following provides comments, concerns and areas of support for the Plan to help inform the final stages of the Neighbourhood Plan process.

Objectives

3.2 The BNP has not allocated sites for development. However, it remains prudent for the Parish to facilitate the development at Little Daux to safeguard the vitality of the village. Notwithstanding this, the benefits of the site should be highlighted, particularly in relation to the 6 identified objectives on page 9 of the BNP:

Objective 1: The site will deliver high quality, sustainable, new housing that reflects the existing village vernacular and respects the character of the wider locality.

Objective 2: The development will provide new infrastructure to support the community, including a new primary school, central hub, with provision for flexible office space for home working, and the potential for medical facilities on the site. This is in addition to the various area of public realm set out above all of which will be available for use by the existing and new community of Billingshurst.

Objectives 3: New connections will be provided to the railway station and towards the centre of the village, to ensure that the development provides a safe environment for all road users. The proposed scheme will emphasise the benefits of sustainable transport modes, providing legible and attractive pedestrian and cycling routes connecting the site with the village.

Objective 4: Crest and Bellway are committed to creating a sustainable extension to the village, ensuring that this development will complement, support and enhance the local economic activity in the Parish. Benefitting from to its proximity to the High Street, this development will reinforce the vitality of the existing

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services and facilities in Billingshurst. Notwithstanding this, additional complementary employment or community facilities will be provided as set out in relation to Objective 2 above, benefiting the village overall.

Objective 5: Little Daux will incorporate appropriate mitigation to ensure that there is no increased risk of flooding in the area resulting from this scheme. In addition, biodiversity enhancement and net gain will also be delivered (exceeding the 10% recommendation of the NPPF As set out above). The development parcels proposed have been informed by the native hedgerows and trees on the site, which will be enhanced as part of the green infrastructure proposals. In addition, the development will provide new walking routes that connect to Wilden’s Meadow SCNI, promoting wildlife and access to nature. With provision of new employment space and public amenities on site, as well as greater access to the train station, residents and visitors will not need to use private vehicles to travel. These factors, in combination with Crest and Bellway’s commitment to the high standard of Building Regulations, will ensure that the development minimises and mitigates impact on climate change.

Objective 6: This development will be sensitively designed to reflect the location of Little Daux. The scheme will be landscape led in its overall layout and design, including extensive areas of public open space and new landscaping, to create a high quality environment throughout. This was demonstrated in the representations to HDC in March 2020, through the vision document and illustrative masterplan, both of which can be forwarded to BPC if requested and are provided at Appendix B to this representation

along with the remainder of that representation (dated March 2020).

Key Issues

3.3 The BNP identifies a number of key issues for Billingshurst on page 10. In relation to these, the benefits of Little Daux should also be highlighted as follows:

Road Congestion: Little Daux will provide all necessary infrastructure to accommodate the development itself, and in particular with regards to traffic. This includes a new roundabout to access to the site from the A272, which will also offer the benefit of traffic control along this main road. Elsewhere around the general area, traffic modelling has and will be undertaken to ensure that any further improvements required to accommodate the development are delivered. This will ensure that the scheme has no greater impact on existing issues, and in the longer term, is capable of supporting road improvements that will be of benefit to the wider area more generally.

Car Parking: Parking will be provided at Little Daux for all proposed uses, ensuring that there is no greater pressure on the village arising from visitors, occupiers or employees at the site. In addition, land is proposed for an extension to the station car park. This will help to reduce the existing pressures in this location.

Retail Experience and High Street Improvements: Development at Little Daux will support the growth, vitality and viability of the High Street. It will improve the permeability of the village, with new connections between the station and village centre, and increasing footfall to local services to help support them in the long term. This is intended to help increase footfall and encourage other businesses into the High Street, improving its retail offer and the overall experience for the local and wider community.

Improved Public Transport: The Development at Little Daux provides an opportunity to help enhance the local public transport facilities in the area. In particular, the availability of land for a station car park extension is a key aspect of this, as it may help to make the facility more attractive to those living in the wider area or far side of the village who cannot walk to the station. Equally, the greater population in the village resulting from the development will also increase pressure for improved and more regular services from the public transport service providers operating in this area.

Education and Medical Facilities: A new primary school is being provided at Little Daux. It will serve the existing community and proposed development. Where required, contributions would be made for improvements to the existing medical facilities in the village and there is an opportunity to provide an Ambulance Community Response Post within the site, enabling faster access to emergency care. However, whilst the need for access to high quality primary care is understood, it is acknowledged that the

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ratio of patients to doctors in Billingshurst is lower than the District and national average so advice would be taken from HDC on this matter.

Maintaining a ‘Village Feel’: The masterplan that has been prepared for Little Daux specifically seeks to ensure that the development integrates and contributes to the quality and character of Billingshurst. It will be a spacious, landscape led development, which aims to add positively to the existing village feel.

Workspace Provision: In addition to providing a community hub with local facilities such as a new community hall, café and meeting space, all of which could be used by local business persons working from home, the site will also deliver an area of commercial space adjacent to the main site entrance. This offers village residents an opportunity for access to further local employment space potentially for smaller businesses, start-ups and training. This will complement existing services and encourage new businesses to trade in the area. Equally, this provision will reduce the need for travel to places of work, helping to improve the long term sustainability of the village and helping to increase the footfall and patronage to local shops, services and public transport.

Housing Needs: In terms of providing a range of homes to address specific needs, Little Daux has the ability to provide a range of Starter Homes, Family Homes and Life-Cycle Homes to cater for various needs in Billingshurst.

Aim 1: Prepare for early review of the BNP

3.4 Object: As previously noted, the BNP is based on the HDPF which was adopted in 2015 and will become out of date in December 2020. As such, the BNP acts as an interim policy document to guide development in the Parish up until the adoption of the emerging Local Plan Review. Whilst the intent of this aim is supported, the commitment to an early review of the BNP should be elevated to the first strategic policy within the BNP. This would underline the importance of a review in the immediate future to account for changes in local and national policy.

3.5 As a result of Covid-19, HDC has also outlined that it has had to undertake a review of the Local Development Scheme, and the timetable for progress of the Local Plan Review. As a result, HDC currently anticipates that the Regulation 19 Consultation on the Local Plan Review will not take place until early 2021 (originally intended for September / October 2020).

Aim 2: Work with key stakeholders to deliver improved health and education facilities

3.6 Support: As noted in the response to objective 2 and paragraph 3.3, the development at Little Daux will help to achieve this aim through the provision of a new primary school and the potential for Ambulance Community Response Post on the site. Crest and Bellway are committed to delivering educational facilities as part of the development and have spoken with HDC and West Sussex County Council (WSCC) to achieve this.

Aim 4: Footpath and Cycle Route Infrastructure

3.7 Support: Bellway and Crest share BPC’s ambitions for attractive and usable footpaths and cycle route infrastructure in the Parish. As a sustainable urban extension, Little Daux will be able to provide clear and legible routes through the site, to provide sustainable transport options throughout Billingshurst to connect existing and proposed services and facilities in the village.

Spatial Strategy and policy BILL1: Billingshurst Built-Up Area Boundary

3.8 Object: This representation principally objects to the built up area boundary (BUAB) set out in BNP Policy BILL1. As the BNP has not allocated sites for development, the settlement boundary for the Parish should be left for HDC to determine. This is linked to the comments above in relation to Aim 1.

3.9 In this regard, Policy 15 of the HDPF identified that Neighbourhood Plans should bring forward 1,500 homes. BPC has made a decision not to allocate any sites (small or large) for housing development. Therefore it is not necessary for the BNP to definite a BUAB as this is already covered by the HDPF. Furthermore, as BPC is

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aware, the HDPF is presently being reviewed through the Local Plan Review Process, and this will make any further allocations for housing in the village and wider Parish, also outlining any proposed amendments to the settlement boundary to align with this.

Policy BILL2: Housing Design and Character

3.10 Comments: Earlier representations raised an objection to this policy, on the basis that part A was unclear with regards to requirements for good design. The policy now included a list of expectations for good quality design. Whilst this is clearer, there are some concepts that may be difficult to implement together. Before progressing to examination, it is necessary to ensure that the BNP includes sufficient flexibility to allow a development to have its own identity whilst also respecting the qualities of the area.

3.11 It remains the case that there is some overlap between Policy BILL2 and Policy 33 of the HDPF and arguably some conflict arises between competing interests of delivering a locally distinctive development (Policy 33) and delivering specific features in a scheme that may not reflect existing character. Overall it remains important for the policy to convey the importance of high quality design, ensured by evolution of proposals and supported by design strategies secured at the planning application stage. These requirements in BILL2 are capable of being secured in this manner as applicable to individual sites.

Policy BILL3: Energy Efficiency and Design

3.12 Support: The attached representations submitted to HDC’s Regulation 18 Local Plan Review in March 2020 (Appendix B) attest to Bellway and Crest’s commitment to the development of a high-quality and sustainable new development. The scheme is intended to meet and exceed the sustainable design interventions outlined in the emerging BNP.

3.13 Little Daux benefits from a genuine choice of transport modes, providing opportunities for electric vehicle charging points, car clubs, ready access to an established train station and the prioritisation of pedestrian and cycling routes across the site. In addition, the new dwellings will be constructed in accordance with the necessary energy efficiency requirements to mitigate against climate change.

3.14 To facilitate this, Bellway and Crest are open to positive engagement with BPC to promote sustainable development at Little Daux wherever it is viable to do so.

Policy BILL 4: Provision of Leisure and Recreation Facilities

3.15 Support: Little Daux covers circa 37 hectares; a large proportion of which will be dedicated to open space and infrastructure, including extensive amenity and open space, a potential trim trail, wildlife corridors, ecological enhancements, play areas and SUDs. In addition the proposals include dual use playing fields for the new primary school that would be available for community use. This commitment to green space and recreational facilities within the development demonstrates the site’s compliance with Policy BILL 4 and its compatibility with the wider objectives of the BNP.

Policy BILL 6: Integrated Infrastructure

3.16 Support: The text associated with this policy refers to education and health improvements. As set out above, Little Daux will be providing a new primary school and this provision will support the objectives of this policy. As applicable, S106 contributions or CIL will be provided that can also support improvements to primary care in the village where this is required by the CCG and local primary care providers.

Policy BILL 7: Retaining and Enhancing the Vitality and Viability of Billingshurst Village Centre

3.17 Comments: Whilst this emerging policy predominantly relates to development in the village centre, the sentiment is pertinent, specifically its ambitions to support the vitality and viability of town centres. The proposed development at Little Daux will promote the economic viability and vitality of Billingshurst village centre by providing new homes with direct links to the High Street. This will provide additional patronage and increase footfall along the High Street to encourage vitality in this area.

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Policy BILL 10: Flexible Workspaces

3.18 Comments: The general aims of this policy are supported, as Little Daux has the potential to deliver some flexible workspace. However, the policy limits development to existing buildings and areas within the BUAB. The limited space within the settlement for development is evident, and there is a potential conflict with the HDPF. This is particularly the case in the High Street where HDPF Policy 12 identifies that there is a balance to be made between maintaining a diverse range and choice of suitable uses which would include retail and other businesses, whilst ensuring that in these locations there remains a convenient, cohesive and concentrated primary area with a high proportion of retail (A1) uses and proposed Class E uses. Therefore whilst BILL 10 refers to Policy 9 of the HDPF, it should also refer to Policy 12, which is clearly applicable to central areas including the High Street. BILL 10, or its preamble should be re-worded to ensure that the HDPF is appropriately reflected, that is assuming that BNP is progressed now rather than waiting to align with the emerging Local Plan Review.

Policy BILL12: Protection and Enhancement of key movement routes

3.19 Support: Little Daux will enable the retention and enhancement of key public rights of way, ensuring additional north-south and east-west corridors, including to key locations such as the station and village centre. Future residents at Little Daux will benefit from a comprehensive and legible development that actively encourages increased footfall in Billingshurst.

3.20 Bellway and Crest have committed to providing direct access at the north of the development to Amblehurst Green to facilitate movement between the two developments and the village. In addition, the proposals at Little Daux will provide vehicular access to the A272, and cycling and pedestrian routes throughout the site, improving permeability and encouraging thoroughfare throughout.

Policy BILL13: Public Car parking

3.21 Support: This policy seeks to encourage new and retained parking areas in the village, including at the station. Although the policy wording need not be changed, it is highlighted that Little Daux will provide an opportunity for an additional station car park, with land being set aside specifically for this purpose in the illustrative masterplan. This proposal fulfils the non-policy action identified on page 73 of the BNP.

Policy BILL14: Residential Parking Provision

3.22 Objects: Policy BILL 14 should be informed by the latest evidence provided in the Horsham Local Plan Review

and the parking standards set out by the West Sussex County Council (WSCC).

3.23 HDC has adopted the WSCC parking standards and hence this should be explicitly stated that developments should accord with these countywide parking standards. It is essential to ensure that requirements for on-site parking provision does not conflict with that guidance.

Policy BILL15: Local Green Spaces

3.24 Comments: The BNP does not allocate Local Green Space on the site. This will be considered in the design evolution of Little Daux and will account for the emerging policies set out in BNP and Horsham’s Local Plan Review.

Policy BILL16: Multi-Value Sustainable Drainage Systems

3.25 Comments: Little Daux will incorporate SUDs which have been designed into the scheme from the outset and with input from both an Ecological and Drainage consultant. A significant proportion of the site is in flood zone 1 and so has the lowest risk of flooding. The current strategy limits peak flows from the development to existing greenfield rates and provides long term storage, ultimately resulting in no negative offsite impacts.

3.26 Whilst there are no objections to this policy, the wording of Part C should make an allowance for the fact that long term maintenance strategies are often not provided at the planning application stage but are secured either

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by way of a planning condition or through a S106 obligation. This is because the degree of detail stated in the BNP is not often known at the application stage and, in instances where it is, it can change before a development is occupied. This degree of flexibility is essential to ensuring that development is not unduly restricted and can come forward quickly and efficiently in any given location.

Policy BILL17: Views to St Mary’s Church

3.27 Comments: Bellway and Crest support the emphasis made in the BNP to uphold the integrity of St Mary’s Church in the village. A full heritage assessment will be undertaken to inform the design evolution of Little Daux. This will be provided as part of any future planning application and ensure that the requirements of this policy are met.

Supporting Documents

Density Topic Paper

3.28 Comments: It is assumed that the Density Topic Paper is relevant to development within the existing built environment and will not be applied to urban extensions. In accordance with local and national policy, the density of all new development in the District should be designed in response to the emerging policies of the Local Plan Review and guidance within the Planning White Paper (August 2020) and National Design Guidance.

Housing Need Paper

3.29 Comments: The Housing Need Paper was drafted in April 2018 to identify the types of housing required by the existing and future populations in Billingshurst. This paper is based on policies in the adopted HDPF and does not consider the latest evidence which is informing HDC’s Local Plan Review. This paper has recommended that BPC defer to the policies set out in the HDPF to inform housing mix and is, therefore, arguably not up to date.

3.30 In this regard, HDC is developing District Wide evidence base with Crawley Borough Council and Mid Sussex District Council which will account for the density, mix and tenure of housing to ensure needs are appropriately met. The primary driver for housing need will therefore be governed by the new Planning White Paper and revisions to the Standardised Methodology for Calculating Housing Need.

Summary

4.1 Little Daux is the most sustainable greenfield site in the District. This proposal represents the most logical extension for the village, enabling comprehensive plan-led development which can provide real and positive benefits for the village in the short and long term. The site is therefore being promoted to HDC as a strategic housing led development opportunity, which incorporates a range of other facilities including a primary school, community spaces, employment and a car park extension for the village train station.

4.2 Whilst the BNP could allocated sites for development, it is clear that the aspiration remains to support HDC in allocation through the Local Plan Review. It remains that there are no objections to this approach but it is felt that this should be appropriately reflected in the BNP with the removal of the settlement boundary policy (BILL 1). This would also avoid the need for later amendments to the BNP to ensure that it is capable of aligning with the emerging Local Plan Review.

4.3 This is pertinent to the other emerging policies within the BNP as the adopted Development Plan in Horsham will become out of date at the end of 2020. The adoption of the policies within the BNP is therefore only currently capable of serving as an interim measure to cover and address development in the Parish between the end of

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this year and adoption of the Local Plan Review. At this point, the BNP will require further updates and reviews if it is to form a functional part of the Development Plan.

4.4 It is hoped that this representation helps to further inform the final stages of the BNP process, prior to Examination commencing. If taken on board, these comments will help to ensure that the BNP can pass Examination and proceed to Referendum. We also want it acknowledged that we submitted duly made representations at the Regulation 14 stage (Appendix A), and for these to be referred to in the Evidence Base.

4.5 Should you have any queries in relation to the details of my letter, please do let me know.

Yours Faithfully,

Charles Collins

Director

Encl:

Appendix A - Regulation 14 Representation (September 2019)

Appendix B – Representations to HDC’s Local Plan Review (March 2020)

norman.kwan

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Representation Form

Billingshurst Neighbourhood Plan 2019-2031

The Neighbourhood Planning (General) Regulations 2012 (as

amended) - Regulation 16

Billingshurst Neighbourhood Development Plan In light of recent announcements regarding COVID-19, Horsham District Council to reviewed its protocols regarding the consultation process for neighbourhood plans, a number of which were published for public consultation shortly before the government imposed the nationwide lockdown. In order to continue to progress neighbourhood plans, we have made a decision to continue with the consultation process with measures we feel are in accordance to the government guidelines. Billingshurst Parish Council has prepared a Neighbourhood Development Plan (BNP). The Plan sets out a vision for the future of the parish and planning policies which will be used to determine planning applications locally. In accordance with Regulation 16 of the Neighbourhood Planning Regulations 2012 (as amended), the BNP and associated documents will go out to consultation: Wednesday 17 June to Wednesday 12 August 2020 for 8 weeks inviting representations on the draft submission plan, basic conditions statement, consultation statement and the Strategic Environmental Assessment (SEA) screening opinion. Supporting Background Papers are for information purposes only. Copies of the BNP Neighbourhood Plan and supporting documents are available to view on the Horsham District Council’s website: https://www.horsham.gov.uk/planningpolicy/planning-policy/currentconsultations Documents will not be made available in deposit locations due to the current COVID-19 pandemic. If local residents have difficulty in engaging online we have provided a telephone number and email address below. Members of the public are encouraged to leave their details for an officer to contact them back if they need further information. Email: [email protected] – [email protected] Telephone: 01403 215398

All comments must be received by Midnight on Wednesday 12 August 2020

There are a number of ways to make your comments:

1. Please use the above web address above to make your representation online ; or

2. Complete this form and email it to: [email protected] ; or

3. Print this form and post it to: Neighbourhood Planning Officer, Horsham Council, Parkside, Chart Way, North Street, Horsham, RH12 1RL

https://www.horsham.gov.uk/planningpolicy/planning-policy/currentconsultations

mailto:[email protected]



All comments will be publicly available, and identifiable by name and (where applicable) organisation. Please note that any other personal information provided will be processed by Horsham District Council in line the Data Protection Act 1998 and General Data Protection Regulations. Horsham District Council will process your details in relation to this preparation of this document only. For further information please see the Council’s privacy policy: https://www.horsham.gov.uk/privacy-policy How to use this form Please complete Part A in full, in order for your representation to be taken into account at the Neighbourhood Plan examination. Please complete Part B overleaf, identifying which paragraph your comment relates to by completing the appropriate box.

PART A Your Details

Full Name Charlie Collins (on behalf of Bellway Homes and Crest Strategic Projects)

Address Savills, 244 - 246 High Street , Guildford

Postcode GU1 3JF

Telephone +44 (0) 1483 796 837 / +44 (0) 7870 999 596

Email [email protected]

Organisation (if applicable) Savills

Position (if applicable) Director

Date 11/08/2020

PART B

To which part in the plan does your representation relate?

Paragraph Number: Policy Reference: AIM 1

Do you support, oppose, or wish to comment on this plan? (Please tick one answer) Support Support with Modifications Object Comment

Please give details of your reasons for support/opposition, or make other comments here:

Please refer to appended representation letter.

What improvements or modifications would you suggest?


x

https://www.horsham.gov.uk/privacy-policy

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Paragraph Number: Policy Reference: POLICY BILL1












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Paragraph Number: Policy Reference: Policy BILL6




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Do you support, oppose, or wish to comment on this plan? (Please tick one answer) Support Support with Modifications Object

x

Comment






Density Topic Paper






Please make sure any additional pages are clearly labelled/ addressed or attached.

Do you wish to be notified of the local planning authority’s decision under Regulation 19 of the Neighbourhood Plan (General) Regulations 2012 in relation to the Billingshurst Neighbourhood Development plan? Please tick here if you wish to be to be notified: x

x

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Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD

Charles Collins

E: [email protected]

DL: +44 (0) 1483 796 837

244 - 246

High Street

Guildford GU1 3JF

T: +44 (0) 1483 796 800

F: +44 (0) 1483 796 801

savills.com

25 September 2019 Billingshurst Parish Council Billingshurst Centre Roman Way Billingshurst West Sussex RH14 9QW Dear Sirs Billingshurst Neighbourhood Plan Regulation 14 Consultation – Consultation Representation in relation to Land East of Billingshurst, Little Daux. Introduction

1.1 This representation is submitted to the Billingshurst Neighbourhood Plan Regulation 14 Consultation, on behalf

of Crest Strategic Projects (“Crest”) and Bellway Homes Ltd. (“Bellway”). This representation specifically relates to the key aspects of the Neighbourhood Plan that are relevant to the Land East of Billingshurst, Little Daux (“the site”).

1.2 It is understood that prior to 31 May 2019, the Billingshurst Neighbourhood Plan Working Group (BNPWG)

resolved to advance their Neighbourhood Plan without allocating sites. In lieu of this, the Parish has committed to working with Horsham District Council (HDC) throughout their Local Plan Review to allocate sites within the Neighbourhood Plan Area.

1.3 The site is being actively promoted through Horsham’s Local Plan Review for the development of circa 700-

800 homes; 1.1Ha of employment space; provision of children’s play spaces; the protection and enhancement of Wilden’s Meadow SCNI; and, improved permeability across the site, with potential for improved wayfinding throughout Billingshurst.

1.4 This proposal provides an exciting opportunity to promote plan-led development in Billingshurst and secure

wider community benefits through open and proactive discussions with Billingshurst Parish Council and the local community. Billingshurst

2.1 Since the mid-1990s, the Village has witnessed substantial growth, including the expansion of the local road network and the provision of additional amenities. This is largely due to Billingshurst’s attractive location combining rural living with commutable links to Horsham and London.

2.2 As a result of the increasing pressure on Local Planning Authorities to deliver housing, growth in Billingshurst

is projected to increase as it establishes itself as one of the most sustainable settlements in the District. This emphasises the need for plan-led development, to maintain Billingshurst’s village character, feel and aesthetics.

2

The Site

3.1 The site lies to the east of Billingshurst and is outside of the existing settlement boundary. It has a collective area of 40.14 hectares and comprises a number of agricultural land parcels in addition to the Rosier Business Park which is an existing, unallocated employment site.

3.2 Elsewhere within the site there are also two listed buildings, comprising the Grade II Listed farmhouse at Little

Daux Farm (listing ID: 1354140) and the Grade II Listed Rosier Farmhouse (listing ID: 1027129). There is also a small area of woodland and some ponds.

3.3 The site’s western boundary abuts the existing settlement boundary and is demarcated by tree planting and

the rear gardens of properties fronting Broomfield Drive and Brookers Road. There is an existing access into the site from Brookers Road. The Principal access point into the site is off Coneyhurst Road (A272) to the east.

3.4 A site plan showing land ownership is attached in Appendix A.

Background 3.5 In the 2016 Strategic Housing and Economic Land Availability Assessment (SHELAA) the site was identified

as SA049 and SA569; albeit it was also assessed by HDC as part of a wider site – SA118. This area as a whole was considered as a potential strategic option for 1,750 dwellings (north and south of A272, including land south of the railway).

3.6 Following the grant of planning applications north of Billingshurst, within the SA118 site allocation, HDC sought

to expand the settlement boundary to include the new developments. The SHELAA 2016 recognised that up to 1,200 dwellings could be provided across the remaining potential allocation (all south of the A272 and hence north and south of the railway) and concluded that SA118 is a suitable, available and viable development option. It should be noted that SA118 did not simply apply to the Site (SA049 and SA569) but also included other land parcels, namely SA028, SA116, and SA637. This letter provides a representation related to the promotion of Little Daux.

Strategic Development Opportunity at Little Daux

3.7 The site has capacity for circa 700-800 homes. The main residential areas are to be formed in small parcels,

each defined by retained and enhanced landscape features. This strategy responds to Crest and Bellway’s aspiration to put sustainability and good place making at the heart of the proposals. Little Daux provides the opportunity for a cohesive and comprehensive development focused on high-quality housing in Billingshurst.

3.8 The site will deliver circa. 1.1Ha of employment space concentrated towards the proposed entrance north of

the railway to complement the mix of employment uses at Rosier Business Park. It is currently anticipated that this could be in the form of B1 or A1-A5 use classes, the final land use for this employment area will be confirmed as the scheme is progressed. The delivery of the site will also accelerate the delivery of the second primary school for the village. Further employment will be considered where appropriate.

3.9 Primary access to the site will be provided directly off of the A272, with further accesses from Broomfield Drive

and T-Junction at the north of the site. The development seeks to emphasise opportunities for sustainable travel. Aided by its proximity to the train station, the site will promote active transport through the provision of attractive cycle lanes and streets. The development will be designed to promote high levels of sustainable transport modes, reducing reliance on private cars wherever possible.

3.10 In addition, the masterplan utilises the existing landscape features to provide attractive formal and informal

open space, including: children’s play areas; trim trails; nature corridors and a sports pitch. Moreover, the proposed ecological enhancements at Wilden’s Meadow SCNI, demonstrates the site’s commitment to creating a sense of place, simpatico with the wider village environment.

3

Draft Neighbourhood Plan

4.1 The Draft Neighbourhood Plan for Billingshurst was published for Regulation 14 consultation on 1 August 2019. The consultation invites comments from interested parties until 29 September 2019.

4.2 The Parish covers 32.19km², comprising Billingshurst, Adversane, Coneyhurst and Five Oaks. The Parish

became designated as a Neighbourhood Plan Area in December 2015 and the BNPWG has been responsible for the production of the Plan since.

4.3 Through a series of public consultations, the BNPWG identified 11 issues presently facing the Parish, notably:

road congestion; insufficient levels of car parking; need to improve the high street; infrequent bus and train services; limited educational facilities; threats to natural and historic environment; demand for employment space; need for continued provision of small, affordable, starter homes; and the need for housing provisions for aging population.

4.4 Rapid expansion in the Village since the 1990s has substantially increased the population of Billingshurst.

Whilst the approved development at Amblehurst Green will deliver an additional 475 homes, extend the medical centre and provide land for a new primary school, there are concerns that there is still not the necessary quantum of development in Billingshurst to demonstrate the viability of a new primary school in this area; let alone provide the necessary infrastructural improvements or payments to address other concerns in the Village. Further development is therefore required to ensure that Billingshurst is adequately resourced to enable the delivery of the primary school and provide funding for other infrastructural projects in the area.

4.5 As previously mentioned, Billingshurst Neighbourhood Plan has not allocated sites for development. However,

we consider it prudent for the Parish to facilitate the development at Little Daux to safeguard the vitality of the Village. Albeit, through vocal or written support for the development and expanding the settlement boundary to include the site rather than specifically allocating the site in the emerging Neighbourhood Plan. Due to the size of the site, this should be left for HDC through the Local Plan process.

4.6 Notwithstanding this, the benefits of the site should be highlighted, particularly in relation to the 6 identified

objectives as set out on page 6 of the Draft Neighbourhood Plan.

Objective 1: The site is capable of delivering high quality new housing that reflects the existing village vernacular and respecting the character of the wider locality.

Objective 2: The development of the site would provide the additional demand to support the opening of a new primary school in the village. The development can also assist with the funding of this school as will be discussed and agreed with both HDC and WSCC as the site is progressed.

Objectives 3 and 4: New connections can be provided to the railway station and towards the centre of the village. Not only will this benefit future occupiers, but it may also provide improved connections for existing residents that will further support the growth and viability of the village centre. Furthermore additional complementary employment or community facilities will be provided on this site, serving the existing and future residents of the village and to improve its overall sustainability and attractiveness.

Objective 5: Appropriate flood mitigation will be provided at this site. Biodiversity enhancement and net gains will also be delivered, in addition to walking routes that connect Wilden’s Meadow SCNI, promoting wildlife and access to nature through this development.

Finally in respect of Objective 6, the development of this site will be sensitively designed to reflect the location of the site adjacent to the open countryside, and adjacent to heritage assets. The scheme will be landscape led in its overall layout and design, including extensive areas of public open space and new landscaping that creates a very high quality natural and built environment throughout.

4.7 Equally within the plan are a number of key aims for the village. The development proposal will certainly provide some added value in respect of a number of those aims, most notably:

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Aim 2: Work with key stakeholders to deliver improved health and education facilities

4.8 There are two key points to note here. firstly, the delivery of the site as a strategic development will result in

Section 106 contributions or CIL. Funding from either of these sources will be able to assist in delivery of the primary school on land to the north, which was consented as part of the earlier consortium strategic development.

4.9 With regards to health facilities, it is currently understood that the ratio of patients to doctors in Billingshurst is

lower than the district and national average. However, the need for high quality and accessible health care is fully understood. A financial contribution would therefore be considered towards health facilities in the village which can assist in providing greater levels of service to the community to meet aim 2.

Aim 4: Identify buildings suitable for co-working/start-up space

4.10 Whilst this aim specifically relates to the use and reuse of existing buildings within the village, the strategic

development at Little Daux does provide the opportunity for new business and start up space. The intention is to provide an area for new employment which correlates with the existing development at the Rosier Business Park, and this may offer space for small businesses, in addition to local training opportunities.

4.11 Whilst this may not directly result in an outcome that the aim is seeking to achieve, it will provide high quality

employment benefits to the village, which will complement existing services and encourage new business and trade into the area. This will assist in making the village more sustainable, more accessible, and ultimately reduce the need for long distance traveling to places of work. Furthermore, the strategic development of this site will assist in increasing the patronage of local services, public transport and increase consumer spend which will encourage and support the use of existing buildings in the village centre for start-up business space as new businesses become more viable in this location.

Aim 5: Footpath and cycle route infrastructure

4.12 New cycle and footway connections will be provided throughout the site. these routes will not only serve the

new community but also provide improved links and connectivity for the existing population. These connections will not only link to existing facilities and routes, but will provide new links to open space, play space and amenity walks that will assist in promoting the health and wellbeing of the wider community.

4.13 Paragraph 10.3 of the draft Neighbourhood Plan notes that with a ‘made’ Neighbourhood Plan, the Parish will

receive an uplift in the amount of funding received from Community Infrastructure Levy (CIL). At present, the Parish receive a capped share of 15% of the CIL received, this will increase to an uncapped share of 25% of CIL receipts from development in Billingshurst.

Community Infrastructure Levy (CIL)

4.14 From our initial calculations, we have estimated that the District would receive a total of circa. £6.14m - £7.02m

from development in Little Daux (arising from the residential provision). Pertinently, this income can be used to achieve some of the aims set out in the Neighbourhood Plan. This estimate is based on the April 2017 CIL Charging Schedule, and is un-indexed (in reality four years of indexation would be applied, assuming and estimated site delivery from April 2021). It is based on the application of 35% affordable housing and an average dwelling size of 100 sq m. On the making of the BNP, the Parish can claim 25% of the CIL receipts. In addition, the development will provide reasonable and necessary Section 106 Obligations and Contributions.

4.15 With regards to specific policies, we set out below our comments that may be of assistance in the progression

of the draft plan.

Policy BILL1: Billingshurst Built-Up Area Boundary

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4.16 Comment: At this time, given the intention of the Neighbourhood Plan not to allocate any new development sites, and leave this for HDC, it is considered that the proposed settlement boundary plan is sufficient to reflect the Plan’s aspirations. We would not therefore comment any further at this time. However, if this site is allocated through the Local Plan process, we would urge the BNPWG to update the site boundary plan to respond to this. In this regard it is acknowledged that the Neighbourhood Plan is clear that an early review will be undertaken once the Local Plan Review has been completed by HDC (page 15). Further comments may therefore be provided at the relevant future stage. Alternatively, the BNPWG might decide to link the NP production timeframes with the Local Plan Review.

Policy BILL2: Housing Design and Character

4.17 Object: Understandably, the Neighbourhood Plan demonstrates the need for well-designed, user-friendly and

resilient developments in Billingshurst. Whilst no specific design proposals have been progressed for Little Daux yet, Crest and Bellway have every intention of ensuring that this policy requirement is met as part of the development of the site. However, to ensure that there is no conflict with the HDPF or any subsequent policy on design, we would suggest some amendments to the wording of the policy as follows:

4.18 Policy BILL2, part A - The wording of this paragraph is not overly clear and currently implies that there is a list

of requirements that need to be complied with, whereas the actual policy only includes 1 requirement. It also appears that parts A and B are duplicated, although this may be as a result of the wording used rather than the intent of the policy itself.

4.19 In addition, there is significant overlap with Policy BILL2 and Policy 33 of the HDPF, the Parish should seek to

remove any onerous or repetitive policy wording. We would recommend that this is reviewed and clarified before the next stage of consultation.

4.20 It is important that the policy conveys the importance of quality design, ensured via appropriate analysis and

design evolution of development proposals, in character, as supported by relevant Design Frameworks or Codes, secured through the grant of planning permission.

Policy BILL4: Provision of Leisure and Recreation Facilities

4.21 Support: Little Daux covers 40.14Ha, of which approximately 20.26Ha will be dedicated to Strategic Open

Space and Infrastructure, including amenity space; wildlife corridors; sports pitch; ecological enhancements; open spaces; play areas and SuDs. The proposals are still evolving and may be able to accommodate the provision of a multi-use games area or alternative leisure facilities following discussions with the Parish Council.

4.22 The commitment for circa. 50% of the land use budget to open space and infrastructure demonstrates the site’s

compliance with Policy BILL4 and its compatibility with the wider objectives as set out in the Neighbourhood Plan. The proposal would therefore act to support the objectives of this policy.

Policy BILL10: Protection and enhancement of key movement routes

4.23 Support: As outlined, the delivery of the site will enable the retention and positive enhancement of key public

rights of way, ensuring additional north / south and east/ west movement, including to key village locations such as the station, The Weald and village centre. There is an opportunity to consider further deliverable enhancements to off-site linkages in selected locations in the village.

Policy BILL11: Public Car parking

4.24 Support: This policy seeks to encourage new and retained parking areas in the village, including at the station.

Whilst this would not require a change in the policy, it is highlighted that there are opportunities for the delivery of an additional station car park at this site. Crest and Bellway would be pleased to discuss the opportunity with the BNPWG should this be considered necessary.

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Policy BILL14: Multi-Value Sustainable Drainage Systems

4.25 Comment: As mentioned, the land-use budget for the site commits approximately 50% of the site to open space and infrastructure, including the use of SUDS. A significant proportion of the site is in Flood Risk Zone 1 (lowest risk of flooding); the current drainage strategy limits peak proposed flows to the existing greenfield rates and provides long term storage, ultimately resulting in no negative offsite impacts from development. The proposal will enable a site sufficient drainage system, which will be based on ensuring no adverse impacts off-site and ensuring a 40% allowance for climate change. In this regard, we have no objection to the proposed policy. Summary

5.1 The Land East of Billingshurst, Little Daux, is the most sustainable greenfield site in Horsham District. The proposal represents the most logical extension for the Village, enabling cohesive and comprehensive plan-led development which reinforces the nucleated settlement pattern in the District. It is therefore being promoted to HDC as a strategic development opportunity for circa 700-800 homes, with 1.1 Ha of much-needed employment space, the enabling of a second primary school for the village and extensive open space representing 48% of the whole site.

5.2 Whilst the Neighbourhood Plan could allocated sites for development, it is clear that the aspiration is to support

allocations in this area made by HDC through the emerging Local Plan Review. We do not object to this approach and have therefore made relevant comments on the draft policies to help inform the process and highlight where this development is able to help meet the needs and aims identified by the Neighbourhood Plan Working Group.

5.3 The Neighbourhood Plan has the potential to act to support and compliment the Local Plan Review,

and need not make unnecessary allocations over and above those being proposed by HDC. 5.4 We do hope that the comments provided are of some assistance to you and we would be pleased to meet

with you and discuss these matters in more detail. Otherwise do let me know if you have any queries on the comments provided. Yours Faithfully,

Charles Collins Director

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LANDSCAPE AND VISUAL REPRESENATION TO HORSHAM DISTRICT COUNCIL LOCAL PLAN REVIEW (A3 DOUBLESIDED)MARCH 2020

LITTLE DAUX, EAST BILLINGSHURST

3

ISSUE SHEET

JOB NAME: LAND EAST OF BILLINGSHURST, WEST SUSSEX

JOB NUMBER: D2720

CLIENT: BELLWAY AND CREST NICHOLSON

REVISION DATE REVISION DETAILS PREPARED BY CHECKED BY APPROVED BY

DRAFT 25.03.2020 FOR INTERNAL REVIEW LS LS AS

DRAFT 26.03.2020 FOR CLIENT TEAM REVIEW LS LS LS

FINAL 30.03.2020 CLIENT AND TEAM COMMENTS ADDRESSED LS LS LS

LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS

4 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS

5

CONTENTS

PROJECT NUMBER: D2720VERSION: 3VERSION DATE: 26 MARCH 2020COMMENT: FINAL REPORT

1.0 Introduction 71.1 Introduction 71.2 Desktopresearchandfieldwork 7

2.0 Landscape and Visual Critique of Proposed Local Plan 2019-2036 Allocations Around Billingshurst 82.1 Introductionandlandscapeplanningcontext 82.2 Sitesuitabilityandred/amber/green(RAG)rating 82.3 LandscapesettingtoBillingshurst 82.4 LandeastofBillingshurst(LittleDaux) 102.5 LandwestofBillingshurst(NewbridgePark) 14 2.6 LandscapesettingtoAdversane 182.7 LandatAdversane(Kingswood) 18

3.0 Landscape and Visual Critique of New Local Plan Evidence Base 223.1 LandscapeCapacityStudy,RevBFebruary2020 22

4.0 Review of Proposed Policies 244.1 Introduction 244.2 StrategicPolicySP27-NaturalEnvironmentandLandscape Character 244.3 StrategicPolicySP31-GreenInfrastructureandBiodiversity 25


**

L

LL

N

N

R2

R3

R5

R4R6

R7 R8

R9

C1

R1

* *

*P

MU1

U11-U12 (OA - 79mx56m)

RC

Description DateRev

0m 100m

1:2,500

50 North Thirteenth Street, Central Milton Keynes, MK9 3BP01908 666276 [email protected] www.davidlock.com

Scale@ : Drawn: Designed: Approved:

Drawing Number: Revision: Date:

©

A2

Little Daux, East Billingshurst

Framework Plan

DG SG SJP

HCSP003/008.01 30.03.20

Site Boundary 40.21ha

Primary Access

Secondary Access Points /Connections

Public Rights of Way & Connectionsinto the Village

Potential Leisure Routes(to Include Trim Trail )

Community Hub [Total - 0.19ha](Community, Local Retail, Business Space & Residential)

Residential Area [Total - 15.86ha]

Amenity Green Space (20.55ha)

Primary School (2.20ha)

Alternative Locations for PotentialLEAPs & NEAPs

Employment / CommercialOpportunity Site [Total - 0.74ha]

SNCI (3.20ha)

SNCI Buffer (min 15m)

Retained Hedgerows / Vegetation(TBC)

Retained Trees (TBC)

Root Protection Zones

Potential SuDS Locations (TBC)

Potential Structural Landscaping

Intermediate Pressure Gas Main(12.2m Easement TBC)

Potential Noise Impacts (TBC)

Potential for Railway Station Car Park(up to circa 90 spaces)

Existing Railway Crossing

Ambulance Community ResponsePost

LN

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Minor adjustments to parcel accesses 13.06.19ASuDS feature added, minor style changes 13.06.19BSite Boundary update 15.08.19C

P

Changes to Residential Parcels R1 & R5 06.01.20DChange to R2 & R5. MU1 added 12.02.20EChanges to residential parcels 20.03.20FChanges to residential parcels 26.03.20G

RC

Minor changes to Key 30.03.20H

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FIGURE 1.1 - FRAMEWORK PLAN (DAVID LOCK ASSOCIATES, 2020)

LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS

7

1.1 INTRODUCTION

fabrikCharteredLandscapeArchitectshavebeenappointedbyBellwayandCrestNicholsontopreparethislandscapeandvisualrepresentationtotheHorshamDistrictCouncilLocalPlan2019-36,PublicConsultation(Regulation18)February2020.ThisdocumentformsatechnicalappendixtothemainrepresentationpreparedbySavills.

AreviewofthelandscapesettingtoBillingshurstandAdversanehasbeencarriedout,togetherwithareviewoflandscapeandvisualconditionsspecificallyforthefollowinglargersiteswhicharepresentedintheemergingLocalPlan:

• LandEastofBillingshurst(LittleDaux)SHELAAReferenceSA118(ourclientssite);• LandWestofBillingshurst(NewbridgePark)SHELAAReferenceSA744,SA642

(includesSA225),SA688;and• LandatAdversane,WestChiltingtonParish(Kingswood),SHELAAReference

SA597.

1.2 DESKTOP RESEARCH AND FIELD WORK

Thefollowingdocumentshavebeenreviewedinpreparationofthisrepresentation:

• HorshamDistrictCouncilLocalPlan2019-36,PublicConsultation(Regulation18)February2020;

• HorshamDistrictCouncilRegulation18SiteAssessmentReport,February2020;• HorshamDistrictCouncilLandscapeCapacityStudy,RevBFebruary2020;and• HorshamDistrictCouncilLandscapeCharacterAssessment,FinalReport,October

2003.

Inaddition,thedesktopsurveyincludedareviewofOrdnanceSurveymaps,interactivemaps(includingmagic.gov.uk),aerialphotographyandtheemergingdevelopmentproposals(associatedwithourclientssiteonly).

ThedesktopandfieldworkassociatedwiththepreparationofthisrepresentationhasbeencarriedoutinaccordancewiththeGuidelinesforLandscapeandaVisualImpactAssessment,ThirdEdition(GLVIA3).

Thefieldsurveywascarriedouton20March2020whenleafcoverwasstilllimitedandreflectsawinterassessmentandthereforetheworst-casescenario.ThefieldworkfortheKingswoodandNewbridgeParksiteswerecarriedoutfromPublicRightsofWaythatcrossthesitesandthepublichighway.

INTRODUCTION1.0


SITE BOUNDARIES TO LAND WEST AND EAST OF BILLINGSHURST (NEWBRIDGE PARK AND LITTLE DAUX) AS REPRESENTED IN THE REG 18 LOCAL PLAN

LEGEND

8

2.1 INTRODUCTION AND LANDSCAPE PLANNING CONTEXT

Noneofthesitesconsideredinthisrepresentationliewithinoradjacenttoadesignatedlandscapeatthenationalorlocallevel(suchastheSouthDownsNationalPark,AreaofOutstandingNaturalBeautyorAreaofAttractiveLandscape).

Furthermore,noneofthesesitesarereadilyperceivedfromelevatedlocationswhicharepubliclyaccessiblewithintheSouthDownsNationalPark,dueprimarilytothelayersofinterveningvegetation.

2.2 SITE SUITABILITY AND RED / AMBER / GREEN (RAG) RATING

HorshamDistrictCouncilhaveappliedtheaboveinassessingthesuitabilityofsitesassetoutintheextractbelow(p57).

ThisRAGratinghasbeentakenfromtheHorshamDistrictCouncilRegulation18SiteAssessmentReport,February2020.AppendixAtothatdocumentsetsoutthecriteriausedinassessingthelandscape(asshownopposite).ThisdoesnotcrossrefertotheCouncil’sownLandscapeCharacterAssessment(2003)intheassessmentcriteriaorguidance,norhasitconsidereditsownPlanningandLandManagementGuidelinesaspartoftheassessment.

Landscapeanditscharacteristhecombinationofbothnatural/physical,cultural/socialandperceptual/aestheticinfluences,whichgiverisetoadistinct,recognisableandconsistentpatternofelementsinthelandscapethatmakesonelandscapedifferentfromanother,ratherthanbetterorworseandwhichdefinethe‘senseofplace’.Thelandscapeisnotthereforesimplyaphysicalmatter,butinfluencesperceptualqualities(includingtranquillityandremoteness)andtheexperienceofthelandscapeinvisualterms.

TheapplicationoftheRAGratingtothesiteshasbrieflydescribedlandscapematters,underenvironmentalconsiderations,however,ithasnotconsideredvisualmatterssuchasthevisualenvelopeassociatedwiththeproposedsite;thescaleofdevelopmentproposed;orpredictedtherangeofvisualreceptorsandthevalueofparticularviews.

TheRAGassessmentinlandscapeandvisualtermsrequiresfurtherrefinement.

Furthermore,thereisnomatrixsettingouthowtheRAGscoreshavebeenreached.

LANDSCAPE AND VISUAL CRITIQUE OF PROPOSED LOCAL PLAN 2019-2036 ALLOCATIONS AROUND BILLINGSHURST

2.0

55

Regulation18SiteAssessmentReport.Thekeyconsiderationsaspartofthisprocessaresummarisedinthefollowingparagraphs.

Site Suitability

6.21 Paragraph8oftheNationalPlanningPolicyFramework(NPPF)setsoutthedefinitionof sustainabledevelopment in relation to theplanningsystem. Itmakesclear thatdevelopmentshouldpursueeconomic,socialandenvironmentalobjectivesinmutuallysupportivewaysandthatopportunitiesshouldbetakentosecurenetgainsineacharea. SiteswerethereforeassessedagainstfourteencriteriaderivedfromtheseNPPFcriteriainordertoattainanoverallassessmentofsitesuitability.

6.22 TheNPPFstatesthatcertainassets,includingAreasofOutstandingNaturalBeauty,SitesofSpecialScientificInterestandirreplaceablehabitatssuchas ancientwoodlandshouldbeprotected. Siteslocatedfullywithinsuchareaswerethereforeconsiderednottobesuitableandwereexcludedfromfurtherassessment.

6.23 TheNPPFisalsoclearthatplanningpolicieswhichleadtoisolateddevelopmentsinthecountrysideshouldbeavoided. TheCouncilisoftheviewthatdevelopmentonlandwhichdoesnotadjoinexistingbuilt-up area boundaries and is not of a sufficient scaletobringforwardnewservicesandfacilitiesonsite,wouldleadtoisolatedruraldevelopmentwhichperpetuatesunsustainablelifestylepatterns.Thesesiteswerealsoexcludedfromfurtherassessment. ThesuitabilityofsiteswasassessedusingaRed/Amber/Greenratingasfollows:

VeryPositiveImpacts

FavourableImpacts

NeutralImpact

UnfavourableImpacts(wherethereispotentialformitigation)

VeryNegativeImpacts(impactsunlikely/unabletobemitigated)

Impactunknown/noinformation

Site Availability

6.24 ThevastmajorityofsitesthathavebeenproposedtotheCouncil can be considered ‘available’ fordevelopment duringtheplanperiod.Therearehoweverasmallnumberof sites that are held on the Council’s SHELAA database that have not been actively promotedforanumberofyearsandforwhich theCouncilhasnotbeenabletoobtain uptodateinformation.ThesesiteshavethereforebeenconsiderednottobeavailableoverthePlanperiodandwereexcludedfromfurtherassessment.

398

Appendix A) Site Suitability Criteria (in order to deliver Sustainable Development)

This guidance note should be read in conjunction with the Site Assessment Criteria Questionnaire. The tables below provide guidance is to help inform landowners / developers about issues on which the Council will be taking into account – where information is not available information about how this may be addressed will be beneficial. The full criteria are set out in the questionnaire which accompanies this document.

1) Environmental Considerations

Landscape NPPF Chapter 15 – Conserving and enhancing the Natural Environment Considers that authorities should allocate land with the least environmental or amenity value and plan for an enhancement of natural capital. Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks AONBs and the scale of development in these designated areas should be limited. Development on land in or impacting a SSSI / ancient woodland or veteran trees should not normally be permitted.

Assessment criteria Assessment guidance Is the site in or adjoining a

protected landscape (AONB / National Park)?

Are there any other landscape constraints (e.g. topography, prominent features) which may be sensitive to development?

What is the capacity of the landscape to accommodate the scale of development proposed (this should refer to the HDC Landscape Capacity Study where possible)?

Does the site offer opportunities for regeneration / landscape enhancement?

If known, what mitigation is proposed to minimise or reduce any potential landscape impacts? Will this be incorporated into any masterplanning?

Do the proposals contribute to the provision of new or improved green infrastructure?

In general terms sites which are in / adjoining protected landscapes are likely to perform poorly against the criteria, particularly taking account of footnote 6 of the NPPF. Sites which are proposed in locations with a low landscape capacity will also generally perform less well against the criteria. Conversely sites which can bring about landscape enhancements or regeneration are likely to perform better against the criteria. Many sites proposed for development are greenfield sites and would require some mitigation to enable them to be satisfactorily assimilated into the local landscape – some change will be permanent and any residual impacts will need to be acceptable after any mitigation. Sites which can contribute to new strategic green infrastructure provision and provide the mechanism to maintain this going forward


2.3 LANDSCAPE SETTING TO BILLINGSHURST

Broadly,theexistingandcurrentlyemergingsettlementedgesofBillingshurstarewelldefinedandconstrainedeastbythealignmentoftheA29tothewest;tothenorthbyNewRoad;thecombinationoftopography,therailwaylineandRosierWood(AncientWoodland)tothesouth;andtheA272totheeast.Thelandscapebeyondthesedefiningfeaturesandexistingandemergingsettlementedges(atAmblehurstGreen)isundulatingandpredominantlyruralandwelltreed.RosierBusinessParktotheeastofBillingshurstsitswithinthislandscape.

Inparticular,existingandproposedlanduses(relatingtotheconsentedpetrolfillingstation,thelocationofwhichisshownasa*ontheplanopposite)westoftheA29aretypicallyurbanfringe,withsportsusesandahouseholdrecyclingcentre(HHR)setwithinawelltreedlandscape,butprovidingatransitionallandscapebetweentownandtheruralcountrysidebeyondtothewest.ThecombinationofridgelinestothewestoftheA29providestherurallandscapesettingtothissideofthevillage.

Theeasttowestrailwaylinedissectsthevillageonitssouthernedge.

ThevisualenvelopeassociatedwithBillingshurstisheavilyinfluencedbythecombinationoftopographyandlayersofvegetationpresentbeyondthevillage.Assuch,thevisualenvelopeassociatedwithBillingshurstislimitedtotheimmediatelocallandscape(andconsideringthecompletionofAmblehurstGreen).

9LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS

FIGURE 2.1 – AERIAL PHOTO ILLUSTRATING LANDSCAPE SETTING (FABRIK, 2020)

A29

NEW ROADA29

A272

A272

A272

BILLINGSHURST

ROSIER WOOD (ANCIENT WOODLAND)

ROSIER BUSINESS PARK

SPORTS FIELDS

HHR

RAILWAY LINE

A29

RAILWAY LINE

*

AMBLEHURST GREEN AND LINK ROAD UNDER CONSTRUCTION

SITE BOUNDARY

LEGEND

FIGURE 2.2 – PLAN ILLUSTRATING PHOTOGRAPH LOCATION POINTS (FABRIK, 2020)

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5 6

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2.4 LAND EAST OF BILLINGSHURST (LITTLE DAUX)

IntermsoftheSiteDescriptionincludedintheLocalPlan,thefollowingaretobeacknowledgedinadditiontothatincludedintheLocalPlan,astheyinfluencetheperceptionofthesite:

• thatthereareopenviewsoftheexisting2and3storeysettlementedgeofBillingshurstoverandthroughtheboundaryvegetation;

• therearebuiltforminfluencesimmediatetothewestandnorth,withthelatterunderconstructionandhavingalreadyextendedthephysicalandperceptualedgeofBillingshursttotheeast;and

• thattherangeofbuiltformassociatedwithRosiersBusinessParkisevidentfromwithinthesouthernsectionofsiteandfromlandsouthoftherailwayline..

Theplanoppositeshowsareducedredlinearearelativetolandnorthoftherailwayonlyatthisstage.

IntermsoftheRAGRatingwenotethatlandscapeisscoredashavinganeutralimpact(yellow)consistentwiththeassessmentofLandatAdversane.However,itshouldbeacknowledgedthatunliketheAdversanesite,therearenoAncientWoodlandspresentwithinthesite.

WithregardtotheSiteSuitabilitySummary,thisistobeamendedtoreflectthatthereisnodesignationforinformalrecreationwithinthesite.Theinformalpathscreatedacrossthesitearenotpermissiveandarethereforehavenolegalstatus.These,inanyevent,wouldbeincludedintheopenspaceproposalsacrossthesite.

Intermsofthevisualenvelope,itispredictedthatvisualeffectsofdevelopingthissitewouldbelimitedtotheimmediatelocallandscapeduetothecombinationoftopographyandvegetationandwouldnotsignificantlyaltertheexistingperceptionorvisualenvelopeassociatedwithBillingshurst.

Furthermore,withregardtocompliancewithsub-section5ofStrategicPolicy3:SettlementExpansion,thesiteandtheemergingdevelopmentproposalsare: “... contained within an existing defensible boundary and the landscape and townscape character features are maintained and enhanced”.

In conclusion, out of the three sites considered around Billingshurst, the site at Little Daux has a strong relationship with the existing settlement edges of Billingshurst and where the A272 provides a defensible eastern boundary to the new settlement boundary, in a consistent way to the A29 to the west.


2.0

VIEWPOINT LOCATION21


PAGE LEFT DELIBERATELY BLANK


PHOTOGRAPH – VIEWPOINT 4 VIEW LOOKING SOUTH ACROSS THE WESTERN PART OF THE SITE FROM THE WESTERN FOOTPATH AND TRACK, ADJACENT TO THE VILLAGE EDGE WHICH IS APPARENT THROUGH AND BETWEEN THE BOUNDARY TREES. LITTLE DAUX FARMHOUSE IS EVIDENT ON THE RIDGELINE.

PHOTOGRAPH – VIEWPOINT 5 VIEW LOOKING SOUTHWEST ACROSS THE WESTERN PART OF THE SITE FROM THE WESTERN FOOTPATH TOWARDS THE VILLAGE EDGE, THE THREE STOREY APARTMENTS AND COMMERCIAL BUILDINGS AROUND THE STATION ARE READILY APPARENT OVER THE BOUNDARY VEGETATION.

LITTLE DAUX


2.0


PHOTOGRAPH – VIEWPOINT 6 VIEW LOOKING WEST ACROSS THE SOUTH-EASTERN PART OF THE SITE FROM THE ENTRANCE TO ROSIER BUSINESS PARK.

PHOTOGRAPH – VIEWPOINT 5 VIEW LOOKING WEST ACROSS THE EASTERN PART OF THE SITE FROM THE EASTERN FOOTPATH CLOSE TO THE A272.

ROSIER WOOD ROSIER HOUSE

ROSIER WOOD

7

8


2.0

SITE BOUNDARY (AS REPRESENTED IN THE REG 18 LOCAL PLAN)

LEGENDFIGURE 2.3 – PLAN ILLUSTRATING PHOTOGRAPH LOCATION POINTS (FABRIK, 2020)

2.5 LAND WEST OF BILLINGSHURST (NEWBRIDGE PARK)

IntermsoftheSiteDescriptionincludedintheLocalPlan,itshouldalsobeacknowledgedthatlandtotheeastofthesite,betweentheA29andthesite,isusedforarangeofoutdoorsportandforhouseholdrecycling.AfootbridgeovertheA29providesaccessfromBillingshurst.ThissectionshouldalsoacknowledgethatlandgenerallyslopeseasttowesttowardstheRiverArunandslopesnorthwardsandsouthwardsfromtheA272boundary.

WithregardtotheSiteSuitabilitySummary,inlandscapetermsthestatementsmadearecorrect,however,itstatesthat “Although geographically close to Billingshurst, its separated from the village by the A272 limits its relationship with the existing built form, and this relative isolation contributes to the very strong rural character.” Emphasisadded.ThecollectionofparcelsthatmakeupthesiteareallseparatedfromBillingshurstbytheA29,nottheA272.Furthermore,duetothetopographicprofileofthemainparcel,whichpredominantlyslopesawayfromBillingshurst,developmentonthissitehasthepotentialtotipthecurrentlywellcontainedandwelldefinedwesternedgeofBillingshurstintotherurallandscapebeyondandthussignificantlyextendingthevisualenvelopeassociatedwiththevillagetothewestbyapproximately1km.

WiththeexceptionoftheA29totheeast,robustanddefensibleboundariesarelimited.Thedevelopmentofthissitethereforewouldnotcomplywithsub-section5ofStrategicPolicy3:SettlementExpansion.

ThelandparceltothesouthoftheA272hasthepotentialtoresultinthesubsumingofthehamletaroundtheB2133andA272junction,alteringthesenseofseparationfromBillingshurst.

ThesiteincludesthelandparcelatPlattsRoundaboutwhichisalreadyconsentedforapetrolfillingstationandsomecommercialunits.Thistypicalurbanfringeconsent,whilstextendingbuiltformbeyondthedefinedsettlementboundary,doesnotjustifytheproposalforthedevelopmentofwiderlandparcels.

IntermsoftheRAGRatingforlandscape,developmentofthecollectionofparcelswouldactuallyresultinredRAGrating:‘VeryNegativeImpacts(impactsunlikely/unabletobemitigated)’ratherthanthe‘UnfavourableImpacts(wherethereispotentialformitigation)’.

In conclusion, the development of this parcel would result in urban sprawl beyond the existing defensible settlement edge into an area that has a very strong rural character; does not have any due to defensible boundaries; and would significantly extend the existing visual envelope associated with Billingshurst. The RAG rating should therefore be amended to red: Very Negative Impacts (impacts unlikely / unable to be mitigated).



15

PHOTOGRAPH – VIEWPOINT 7 VIEW LOOKING EAST ACROSS THE SITE TOWARDS BILLINGSHURST FROM THE WEY SOUTH PATH LONG DISTANCE ROUTE. THE CHURCH SPIRE IS APPARENT ABOVE THE INTERVENING TOPOGRAPHY OF THE SITE AND VEGETATION BEYOND.

PHOTOGRAPH – VIEWPOINT 8 VIEW LOOKING WEST ACROSS THE EASTERN SITE PARCEL FROM THE BUS STOP ON THE A29. THE EMERGING BUILT FORM TO THE EAST OF THE A29 IS EVIDENT, HOWEVER, VIEWS ACROSS THE SITE ARE PREDOMINANTLY RURAL.

A29


CHURCH SPIRE A272BARN

10

9

SITE BOUNDARY

LEGEND



PHOTOGRAPH – VIEWPOINT 9 PANORAMIC VIEW LOOKING SOUTH FROM THE FOOTPATH CROSSING THE SITE. THE WESTERN VILLAGE EDGE OF BILLINGSHURST IS APPARENT BEYOND AND OVER THE INTERVENING VEGETATION.


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2.0


DWELLINGS ON NEWBRIDGE ROADBILLINGSHURST

PHOTOGRAPH – VIEWPOINT 9 VIEW LOOKING NORTH-EAST FROM THE FOOTPATH CROSSING THE SITE. THE WESTERN VILLAGE EDGE IS PREDOMINANTLY OBSCURED BY THE INTERVENING LAYERS OF VEGETATION.


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ROWNER ROAD

DWELLINGS ON NEWBRIDGE ROADBARN


FIGURE 2.6 – AERIAL PHOTO ILLUSTRATING LANDSCAPE SETTING

2.6 LANDSCAPE SETTING TO ADVERSANE

ThehamletofAdversaneiscentredaroundacrossroadjunctionandsitswithinapredominantlyflatlandscapeassociatedwithminorwatercoursesnorthandsouth.

Thelandscapearoundthehamletrisesgentlytoseriesofminorridgelines,whicharenotreadilyperceivedinthelandscapeduetothecombinationofinterveningfieldboundaryvegetationandwoodlandblocks.Fieldboundaryvegetationandsmallwoodlandblocksaremoreprevalenttothenorthandwestofthehamlet.Thelandscapetothesouth-easternsideofthehamletismoreopen,allowinglongerviewsacrossthelandscapetotheridgelineatSteepwoodFarmandwheretreesformpartofthebackdroptotheviewandvisualhorizon.

ThelandscapesettingtothishamletispredominantlypastoralandprovidesthelandscapeseparationwiththecollectionofbuildingsaroundChichesterCollege(Brinsburycampus)tothesouth.Someofthesebuildingsarecommercial(suchastheHepworthandCoBrewery)andcompriseoflargesheds,asillustratedintheaerialphotobelow.

A29

ADVERSANE LANE

ADVERSANE

STEEPWOOD FARM

BEEDINGS COPSE

CHICHESTER COLLEGE

2.7 LAND AT ADVERSANE (KINGSWOOD)

IntermsoftheSiteDescriptionincludedintheLocalPlan,itstatesthatthissite“is open in nature on the west of the proposed site close to the A29”.However,whilstroadsidevegetationobscuresviewsofthegroundplaneofthesitefromthenorth,itsopennessisneverthelessperceivedfromAdversaneLaneandtheneighbouringpropertiestothenorth.Furthermore,itisexperiencedasanopensitefromtheresidentialvisualreceptorsbothwithinandimmediateadjacenttothesiteandforthosevisualreceptorsusingthePublicRightsofWay(PRoW)thatcrossorrunalongtheedgeoftheSite.Overall,thebuiltforminfluencesareintermittentandoftenrelatetoindividualisolateddwellings,farmsteadsorcommercialpremises.

Whilstparameterplansand/ormasterplansatthisstagearenotavailabletoreview,intermsoftheRAGRating,thelandscapeisscoredashavinganeutralimpact(yellow).UndertheSiteSuitabilitySummarysection,itstatesthat:“Although attractive, the landscape in the area has not been designate as being of importance. Nevertheless, it is recognised that a development of this scale will have significant changes on the settlement pattern and wider rural character in this area. The potential for coalescence of the development between Billingshurst and Pulborough has been identified as a particular concern.”Weconcurwiththisstatement,especiallyastherearenoreadilydefensibleboundariestothesouth,nortotheeast,butwouldalsoaddthatduetothelimitedinfluenceofbuiltformbeyondtheisolateddwellingsandfarmsteads,combinedwiththenumberofAncientWoodlandblocksandfieldboundaryvegetation,thereisasenseofremotenessexperiencedwithinthesite.However,thisstatementdoesnotcorrelatewiththeneutralscoringandconsideringtheabovestatement,shouldbeattributedanorangescorewhere:Unfavourableimpact(wherethereispotentialformitigation).

Furthermore,theseproposalsarelikelytoresultintheperceivedcoalescencewithChichesterCollegetothesouth,whichcurrentlyformsanisolatedclusterofbuildingsinthelandscape.

Notwithstandingtheabove,theRAGdoesnotidentifytheexistingAncientWoodlands,whichareakeycomponentofthesiteandarelikelytorelieduponforvisualmitigationpurposes.

WhilstnotcoveredintheRAGassessment,followingthefieldworkandintermsofthevisualenvelope,itispredictedthatvisualeffectsofdevelopingthissitewouldbelimitedtothesitelevelandlocallandscape,dueprimarilytothelayersofvegetationbothwithinandbeyondthesite.

Withregardtocompliancewithsub-section5ofStrategicPolicy3:SettlementExpansion,thesitedoesisnotfully: “... contained within an existing defensible boundary...”

In conclusion, due to the lack of defensible boundaries, the potential for coalescence and sense of remoteness, the RAG rating should be revised to orange: Unfavourable impact (where there is potential for mitigation).

SITE BOUNDARY (AS REPRESENTED IN THE REG 18 LOCAL PLAN)



LEGEND

1

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3

2.0



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PHOTOGRAPH – VIEWPOINT 1 PANORAMIC VIEW LOOKING EAST ACROSS THE WESTERN PART OF THE SITE FROM THE BRIDLEWAY THAT FOLLOWS THE EASTERN SITE BOUNDARY. VIEWS OF STEEPWOOD FARM AND ASSOCIATED BARNS AND DWELLINGS TO THE WEST AND FARM BARNS TO THE EAST ARE PERCEIVED FROM THIS ROUTEWAY.

PHOTOGRAPH – VIEWPOINT 2A VIEW LOOKING NORTH ACROSS THE CENTRE OF THE SITE FROM STEEPWOOD LANE BRIDLEWAY. THE INDIVIDUAL DWELLING OF STEEPWOOD AND STEEPWOOD FARM BUILDINGS (SEE PHOTOGRAPH 2B) ARE PERCEIVED FROM THIS LOCATION.

PHOTOGRAPH – VIEWPOINT 3 VIEW LOOKING EAST ACROSS THE WESTERN PART OF THE SITE FROM THE LAYBY ON THE A29 STANE STREET. TREES FORM THE VISUAL HORIZON.

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DWELLING AT STEEPWOOD


PHOTOGRAPH – VIEWPOINT 2B VIEW LOOKING EAST FROM STEEPWOOD LANE BRIDLEWAY. THE BARNS OF STEEPWOOD FARM ARE VISIBLE IN ITS RURAL CONTEXT.

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DWELLING AT STEEPWOOD FARM

STEEPWOOD FARM BARNS


LANDSCAPE AND VISUAL CRITIQUE OF NEW LOCAL PLAN EVIDENCE BASE

3.0

3.1 LANDSCAPE CAPACITY STUDY, REV B FEBRUARY 2020

ThissectionreviewstheabovedocumentfollowingasmallerscalereviewoftheindividualsitesatKingswood,LittleDauxandNewbridgePark.

ThepurposeoftheLandscapeCapacityStudy(LCS)istoprovideanoverarchingstrategiclevelassessmentofpotentialdevelopmentsiteswithoutthebenefitoftheparameterplansormasterplanproposals.Itisnoted,assetoutinpara1.8thatthisStudyis‘generalised’andprovides:“a pointer to detailed landscape and visual issues that would need to be addressed in a site allocation or development management context”.Itgoesontostatethat:“Landscape sensitivity and capacity levels are indicative, and it is expected that further analysis at a smaller scale and more detailed assessments of the area would be carried out in relation to specific applications to determine the actual capacity of the site.”Emphasisadded.

ThefollowingsectionssetsoutthefindingsoftheCapacityStudyandprovidesfurtherlevelofassessmentrelativetoeachofthesitesfollowingmoredetaileddesktopandfieldassessmentwork.

AlloftheabovesitesliewithinZone4:PulboroughtoBillingshurst.Allofthesesitesareproposedforlargescalehousingdevelopmentof500ormoredwellings.Thelandscapecapacityassessmentdoesnottakeintoaccounttheboundariesofthethreesites.ThefollowingparagraphssetoutthefindingsoftheLCSandthenfollowingonwithamoredetailedassessmentandcommentary.

Land East of Billingshurst (Little Daux)Themajorityofthesitelieswithinarea48whichisdefinedhashavingModerate capacity,withthenorthernandnorth-easternpartofthesiteformingthesouthernsectionofawiderarea49whichisdefinedashavingNo/Low capacity.

However,consideringthestrongrelationshipthatthissitehaswiththeexistingandemergingsettlementedgesandwherebydevelopmentcansitwithintheretainedframeworkoftreesandhedgerows,thecapacityofarea48shouldbeelevatedtoModerate - High capacity,whichisdefinedaswhere: “The area is likely to be able to accommodate a significant proportion of development without unacceptable adverse landscape and visual impacts or compromising the values attached to it, taking account of any appropriate mitigation.”

In conclusion, the current Moderate capacity judgement should be amended to be Moderate - High.

Land West of Billingshurst (Newbridge Park)ThelandscapetothewestofRownerRoadisexcludedfromtheassessmentwhichisquestionedandassumedthereforethatthereisNo/LowcapacityforthelandwestofRownerRoadaccordingly.

LandtothenorthoftheA272lieswithinarea51,definedashavingLow-Moderate capacity;withlandtothesouthoftheA272beingwithinarea52,whichalsoisdefinedashavingLow-Moderate capacity.Consideringthephysicallandscapeattributes,itsphysicalseparationfromthevillageedgeandthepredictedchanges

tothevisualenvelopeassociatedwithBillingshurst,overall,thesitehasaNo/Low capacityoverallandshouldthereforebeexcludedfromtheconsiderationoffuturedevelopmentsites.

The current Low-Moderate capacity judgement should be amended to No/Low capacity.

Land at Adversane, West Chiltington Parish (Kingswood)Themajorityofthissitelieswithinarea45whichisdefinedashavingmoderate capacity overall,whichisdefinedaswhere:“This area has an ability to accommodate development in some parts without unacceptable adverse landscape and visual impacts or compromising the values attached to it, taking account of any appropriate mitigation. There is a need for each proposal to be considered on its individual merits to ensure that there are no unacceptable adverse impacts”.

Thenorth-westernoutercornerbroadlyatthejunctionoftheA29,B2133AdversaneLaneandtherailwaylineformingpartofarea46;andthesouth-easternwoodlandedgerelativetoBeeding’sCopseandadjacentAncientWoodlandformingpartofarea44whicharebothdefinedhashavingNo/Low capacityforlargescalehousing,whichisdefinedaswhere:“The area is unable to only has very limited potential to be able to accommodate the specified type and scale of development without unacceptable adverse landscape and visual effect or compromising the values attached to it, taking account of any appropriate mitigation”.

Acoupleofcomparisonscanbemadebetweentheassessmentofarea46and44whicharenotincludedintheassessmentofarea45.Themajorityofthesite45sharessomeofthequalitiesoftheneighbouringareasinthatthistractoflandisalso‘enclosedbywoodedshawsandhedgerows’andis‘unspoiltincharacterandwherethelandscapeisgenerallyingoodcondition’(albeitthat,aswithanylargetractofland,somepartsareoflowerquality).Furthermore,theassessmentofarea45statesthatthereisalimitedfootpathnetwork,howeverthesiteactuallycontainstwobridlewaysintheeasternpartofthesiteandisthereforeaccessible.Furthermore,thedevelopmentofthislandmayresultintheperceivedcoalescenceofAdversanewiththeisolatedcollectionofbuildingsassociatedwithChichesterCollege.

Overall,consideringtheseadditionalpointswouldreduceitscapacitytoLow-Moderate,where:“The area only has potential to be able to accommodate development in limited locations without unacceptable adverse landscape and visual impacts or compromising the values attached to it, taking account of any appropriate mitigation.”

In conclusion, the current Moderate capacity judgement should be amended to be Low-Moderate.

FIGURE 3.1 – EXTRACT FROM HORSHAM DISTRICT COUNCIL LANDSCAPE CAPACITY ASSESSMENT MAP (HDC, 2020)

LEGEND 53

46

43

45

40

44

52

47

51

42

49

39

48

41

38WC1WC3

WC2

´

Horsham District CouncilParkside, Chart Way, Horsham

West Sussex RH12 1RLBarbara Childs : Director of Place

Reproduced by permission of Ordnance Survey map on behalfof HMSO. © Crown copyright and database rights (2020).Ordnance Survey Licence.100023865

No / Low capacityLow-Moderate capacity

Moderate capacityModerate-High capacity

High capacityLand committed for development

Med scale Lge scale

Drawing: LCA-Z4A

Zone 4a - Pulborough to BillingshurstLandscape capacity of local landscapecharacter areas for large and medium

housing development

Date: 01/08/2011 Scale: 1:25000 at A3Revisions: A: 26/02/2013, B: 15/01/2020

23

LAND AT ADVERSANE (KINGSWOOD)

LAND TO THE EAST OF BILLINGSHURST (LITTLE DAUX)

LAND TO THE WEST OF BILLINGSHURST (NEWBRIDGE PARK)

LOCAL PLAN SITE BOUNDARIES:


C

C

A

B

A

B

B

B

C

A

B

24

4.1 INTRODUCTION

ThissectionoftherepresentationprovidesacommentaryonthelandscaperelatedemergingStrategicPolicies27and31,withtheoverallcommentsprovidedintheRegulation18LocalPlan.ItalsosetsouthowtheproposeddevelopmentonlandtotheEastofBillingshurst(LittleDaux)respondsandaddresseslandscaperelatedpolicy.

4.2 STRATEGIC POLICY SP27 - NATURAL ENVIRONMENT AND LANDSCAPE CHARACTER

Thesiteisnotsubjecttoanylandscapedesignations.Therefore,inrelationtoPara’s170and171oftheNPPFthesiteistherefore‘offthebottom’ofthelandscapevaluehierarchy.ForthepurposesofPara170aoftheNPPFtheSiteisnotavaluedlandscape.

Theproposeddevelopmenthasbeenlandscapeled,keepingdevelopmentawayfromthemoresensitiveareasoftheSite.However,aswiththedevelopmentofanygreenfieldparcel,therewillbeanultimatechangeinthecharacterofthatlandscapefromgreenfieldtobuiltformandassociatedgreeninfrastructure,creatingahighqualityenvironmentwithasenseofplace.Therefore,inrelationtolandscaperelatedbulletpointsofPolicySP27,thesiteandproposeddevelopment:

1.Willprotect,conserveandenhancethekeycharacteristiclandscapefeaturesofthesite,namelythetopographicprofile,theexistinglandscapestructurerelativetotheexistingwoodedareas,treebelts,highqualitytreesandhedgerows(thelatterofwhichdefinestheexistingfieldparcels).Theexistingvegetationframeworkwillbesupplementedwithnewplantingaspartofthesitewideenhancementproposals.TheexpansionofthevillagetotheeastwillmaintainsettlementseparationbetweenBillingshurstandSouthwatertothenorth-east.

2and4.Willprovideanaccessibleandco-ordinatedhighqualityresponsetotheprovisionofGreenInfrastructureandSUDsacrossthesite.TheGreenInfrastructureisproposedtobeaccessibletotheexistingandnewcommunityalikeandwhichaddressesthepublicopenspacepolicyrequirements;whichprovidesamultifunctionallandscapedesignresponse;andprovidesalternativerecreationopportunitiesandopportunitiesforlearningthroughnature.

5.Doesnotsitwithin,orperformaroleinthesettingto,adesignatedlandscapeeithernationallyorlocally.

Intermsoflandscapecharacter,thesiteliesatthesouthernendofLandscapeCharacterAreaG3SlinfoldandFiveOaksWoodedFarmland,asdefinedintheHorshamDistrictCouncilLandscapeCharacterAssessment(2003).TherailwaylineformstheboundaryofthisLCAwithJ1tothesouth–BillingshurstandNorthHeathFarmlands.

AresponsetoeachofthePlanningandLandManagementGuidelinesforLCAG3issetoutinthefollowingtable.

LCA G3 Planning and Land Management Guidelines Land East of Billingshurst (Little Daux) Proposals and ResponseConserveruralundevelopedcharacter.Anylargescalehousingandcommercialdevelopmentislikelytodamagecharacter,e.g.throughlossofsmallscalefieldpatternsandlossofwoodlands.

Thedevelopmentofanygreenfieldsiteinthischaracterareawillalterthecharacterofthelandscape,however,theproposalswillretainthefieldpatternthroughtheretentionofexistingboundaryhedgerowsandtrees;andwillretainexistingwoodedareasaspartoftheSiteofNatureConservationImportance(SNCI).

Considerthecumulativeimpactofsmallscalechange,e.g.suburbanisationalongroads.

Intermsofcumulativeimpact,theproposeddevelopmentwouldseethecontinuationofbuiltformfurthersouthwardstothecharacterareaboundaryalongtherailwayline.ThereisalreadyaperceptionofbuiltformtothenorthofrailwaylineduetothepresenceofRosierBusinessPark,thenurseryandtheadjacentresidentialpark,alongwithindividualdwellings.Inessence,therewouldbeachangetothelandscapecharactermap,wherethelandtothenorth(currentlyunderconstructionandwhichstraddlestheA272)andthesiteitselfwouldformpartoftheareadefinedasBillingshurst.TheexistingplantingalongtheeasternboundaryoftheSitealongtheA272willberetainedandreplanted;thesenseofseparationtoandaroundexistingdwellingswouldberetained;andtheentranceintoRosierBusinessParkwillbereconfiguredtoaccommodateanewroundabout.ThecumulativeeffectonlandscapecharacterarisingthroughthelandcurrentlybeingbuiltoutandtheproposedsiteisthattheperceptionofBillingshurst,willextendsouth-eastwardstotherailwayline.However,theseeffectswillbemoderatedwiththeimplementationofthelandscapemeasuresdefinedabove.

Ensureanyappropriatenewdevelopmentrespondstohistoricsettlementpattern,localdesignandbuildingmaterialandiswellintegratedintotheexistinglandscapepatternofwoodland,hedgerowsandshaws.

Theproposeddevelopmentframeworkplanshowstheintendeddevelopmentzoneswhichareintegratedintotheexistinglandscapepattern,retainingexistingwoodedareas,hedgerowsandtrees.Thedesignintentisthattheproposeddevelopmentwillbehighqualityandreflectlocalvernacular.

Managecoppicewoodlandswhereappropriate. Ifappropriate,thiswillbeimplementedaspartoftheco-ordinatedlandscapeandecologicalmanagementplansubmittedaspartofafutureplanningapplicationandaspartofthesitewidebiodiversityproposals.

Restorenativespeciesinconiferplantations Allnewplantingacrossthesitewillbenative.Restorewherepossiblearablefieldstopasture WiththeexceptionoftheSNCIarea,whichwillberetained,theproposedGreen

Infrastructurenetworkwillaltertheuseofsomeofthegreenfieldparcels.Manageisolatedfieldtrees Isolatedfieldtreeswithinthesitearelimitedandwheretheyarepresent,theyare

proposedtoberetainedaspartoftheGreenInfrastructurenetwork.Themanagementoftreesacrossthesitewillbesubjecttomeasuressetoutinalandscapeandecologicalmanagementplansubmittedaspartofafutureplanningapplication.

Encouragelandownerstoadoptbettermanagementofhorsepaddocks Therearenohorsepaddockspresentwithinthesiteandthereforethisguidelineisnotapplicable.

REVIEW OF PROPOSED POLICIES4.0


25

4.3 STRATEGIC POLICY SP31 - GREEN INFRASTRUCTURE AND BIODIVERSITY

Theproposeddevelopmentwillprovideamulti-functionalandconnectednetworkofgreenspacesintheformoftrees,informalpark,roadverges,woodlandandwetland.TherangeofspaceswillprovideforfloodprotectionintheformofSUDs,formalandinformalrecreation,landscapeandnatureconservation.Assuch,theproposeddevelopmentwill,inrelationtothelandscapespecificbulletpointsofthepolicy:

1.Maintainsandenhancestheexistingnetworkofgreeninfrastructureacrossthesiteintheformofthegreencorridorsassociatedwiththeexistingvegetationpattern,predominantlyrelatingtofieldboundaries.

2.Assetoutabove,willretainexistingwaterfeatures,hedgerows,treesanddeciduouswoodlandandprovidesforadditionalplantingaspartofthelandscapeenhancementmeasuresproposedinrelationtoPolicySP27.

3.Replacementplantingfortreesproposedtoberemovedisembeddedwithinthelandscapeprinciplesandcompensationstrategy.Theoverarchingtreestrategyisthattherewillbenetgaintotreeplanting.


LENTEN HOUSE16 LENTEN STREETALTONHAMPSHIREGU34 1HG

FIRST FLOOR STUDIO4-8 EMERSON STREETLONDONSE1 9DU

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FABRIKUK.COM

1 Continues over page

COMMENTS FORM

Horsham District Local Plan 2019 - 2036

Draft Plan Regulation 18 Consultation (February 2020)

We are inviting comments on the emerging Local Plan.

Comments should ideally be submitted online by visiting https://www.horsham.gov.uk/planning/local-

plan/have-your-say. It is better for comments to be submitted in this way as it ensures a thorough

analysis of comments against particular parts of the Local Plan and ensures representations are

processed quickly and efficiently such that the Council can swiftly proceed onto the next stage of the

plan-making process.

If you are unable to comment online, this form should be used to make comments in response to this

consultation. Please use a separate form for each comment made on a different policy or part of the

Local Plan.

The consultation period begins on Monday 17 February 2020 and ends at 5pm on Monday 30

March 2020.

Please note:

1. Responses must include as a minimum your name and address. Please also provide your email address if you have one – without an email address, we will be unable to provide an acknowledgement of receiving your response.

2. Anonymous representations will not be accepted. Your comments cannot be treated as confidential. By completing this form you agree to your details being shared and your name and comment (but not your address or other personal details) being made available for public viewing. Please review the Council’s Privacy Statement at https://www.horsham.gov.uk/privacy-statement.

3. No inappropriate, derogatory or discriminatory comments should be made regarding an individual or a collective group of individuals. Any comments made of this nature will be disregarded.

4. It is recommended that groups that share a common view send a single response rather than multiple copies of the same response.

5. Completed comment forms can be returned to us via email to [email protected] or by post to Strategic Planning, Horsham District Council, Parkside, Chart Way, Horsham, West Sussex RH12 1RL.

6. Completed forms should be received by us no later than 5pm on 30 March 2020.

https://www.horsham.gov.uk/planning/local-plan/have-your-say


https://www.horsham.gov.uk/privacy-statement



Please leave this page blank and go to the next page.


Section 1 – Your details

Personal details

Title Mr

Name (required) Charles Collins

Organisation / group

(if you are an agent

representing a client,

please specify the client

you are acting on behalf

of)

Savills

(on behalf of Bellway Homes & Crest Nicholson)

Address 1 (required) 244-246 High Street

Address 2 Guildford

Address 3

Address 4

Postcode GU1 3JF

Telephone number 07870 999 596

Email address (required) [email protected]

Section 2 – Your comments

To which part of the draft Local Plan do your comments

relate? Please state the policy number, paragraph number or

figure number, or where applicable enter ‘SA’ (Sustainability

Appraisal’ or ‘HRA’ (Habitat Regulations Assessment)

Please see overleaf.

What is the nature of your comments? [tick as appropriate]

Observation

or General comment

X Support X Objection X

For official use only:

Date received:

Consultee & comment ID:


norman.kwan

Highlight

norman.kwan

Highlight

norman.kwan

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norman.kwan

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norman.kwan

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norman.kwan

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Provide your comments below:

Expand this box as necessary or attach additional sheets. If attaching additional sheets, please clearly mark

these with the consultation question that the representation relates to and your name.

Please see Main Representation Report prepared by Savills with appendices, notably:

Illustrative Master Plan – David Lock Associates (Appendix 2)

Framework Plan – David Lock Associates (Appendix 3)

Little Daux Vision Document – David Lock Associates (Appendix 4)

Technical Note – Ardent (Appendix 5)

Biodiversity Net Gains Report – Ecology Solutions (Appendix 6)

Mens SAC and Ebernoe Common SAC Note – Ecology Solutions (Appendix 7)

Landscape and Visual Report – fabrik (Appendix 8)

HDC Evidence base commentary:

Built up Area Boundary Review (February 2020)

Habitats Regulation Screening Report (30 January 2019)

Horsham District Local Plan Interim Sustainability Appraisal (February 2020) (including SA of strategic sites and growth options, SA of smaller sites and policies and SA Non-technical Summary of sites and growth options)

Infrastructure Delivery Plan (January 2020)

Landscape Capacity Study Rev B (February 2020)

Northern West Sussex Housing Market Assessment (November 2019)

Strategic Flood Risk Assessment (January 2020)

Representations (PTO):


Strategic Policy 1: Sustainable Development – Support

Strategic Policy 2: Development Hierarchy – Object

Strategic Policy 14: Housing Provision – Comment

Potential Housing Allocations – Comment

Smaller Scale Development – Comment

Strategic Policy 15: Strategic Site Development Principles – Object

Strategic Policy 16: Affordable Housing - Object

Strategic Policy 17: Housing Mix - Object

Strategic Policy 18: Housing Standards – Object

Strategic Policy 25: Environmental Protection – Comment

Strategic Policy 26: Air Quality – Comment

Strategic Policy 27: The Natural Environment and Landscape Character - Comment

Strategic Policy 31: Green Infrastructure and Biodiversity – Support

Strategic Policy 33: Development Quality – Object

Strategic Policy 34: Development Principles – Object

Strategic Policy 35: Heritage – Object

Strategic Policy 37: Climate Change – Object

Strategic Policy 38: Appropriate Energy Use – Object

Strategic Policy 40: Flooding – Comment

Strategic Policy 42: Sustainable Transport – Comment

Strategic Policy 43: Parking – Comment

Policy 46: Community Facilities and Uses – Object

6

Section 3 – Declaration

How we will use your personal information

All comments will be publicly available, and identifiable by name and (where applicable) organisation.

Please note that any other personal information provided will be processed by Horsham District

Council in line the Data Protection Act 1998 and General Data Protection Regulations. Horsham

District Council will process your details in relation to this preparation of this document only. For

further information please see the Council’s privacy policy: https://www.horsham.gov.uk/privacy-

policy.

Please sign and date this form. Forms signed electronically will be accepted.

Declaration:

By completing and signing this form, I agree to my name, organisation and representations

being made available for public inspection on the internet and in paper form. I further

understand that my personal contact details will be used to notify me further of later stages of

consultation relevant to the Horsham District Local Plan Review. I understand that personal

details will not be made publicly available.

A copy of our privacy notice is available on our website - https://www.horsham.gov.uk/privacy-

statement

Signature:

Date: 30th March 2020

We would also like to keep you informed of future Local Plan and planning policy consultations and

updates. If you would like to be kept informed, please register your details on our consultation portal

by going to https://www.horsham.gov.uk/planning/local-plan/have-your-say and clicking on the

‘Register to have your say’ button.






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