Rusper Neighbourhood Plan 2018 – 2031 Statement in Response to the Initial Comments of the Independent Examiner Contents Rusper Neighbourhood Plan 2018 – 2031
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Rusper Neighbourhood Plan 2018 – 2031 Image donated by Ian Mulcahy Statement in Response to the Initial Comments of the Independent Examiner Published by Rusper Parish Council 17 July 2020 Rusper Neighbourhood Plan - Statement in Response to the Initial Comments of the Independent Examiner Page 1 Rusper Neighbourhood Plan 2018 – 2031 Statement in Response to the Initial Comments of the Independent Examiner Contents Rusper Neighbourhood Plan 2018 – 2031...........................................................................................2 Statement in Response to the Initial Comments of the Independent Examiner....................................2 1.Foreword - Coalescence...................................................................................................................3 2.Planning Policy Context – Paragraph 3.8..........................................................................................3 3.Planning Policy Context – Paragraph 3.12........................................................................................4 4.Planning Policy Context – Paragraph 3.14........................................................................................4 5.Planning Policy Context – Plan C......................................................................................................5 6.Policy RUS1 – Landscape areas.......................................................................................................5 7.Policy RUS2 – Brownfield developments..........................................................................................5 8.Policy RUS1 & RUS8 – Distinction against NPPF and HDPF...........................................................6 9.Policy RUS3 – Design.......................................................................................................................6 10.Policy RUS5 – Green infrastructure................................................................................................6 11.Appendix D – Local Green Spaces Report......................................................................................7 12.Local Green Spaces Representations.............................................................................................7 13.Local Gaps......................................................................................................................................7 14.Policy RUS9 – Community Facilities...............................................................................................8 15.Policy RUS7 – Local Green Spaces................................................................................................8 16.Policy RUS9 – Community use viability...........................................................................................9 17.Policy RUS10 – School site.............................................................................................................9 18.Policy RUS12 – Promoting Sustainable Transport........................................................................10 19.Policy Maps...................................................................................................................................10 20.Implementation..............................................................................................................................11 Appendix 1 – Proposed Changes To The Submission Plan...............................................................12 1. In response to questions 4 and 20....................................................................................12 2. In response to questions 10.............................................................................................12 3. In response to questions 18.............................................................................................12 4. In response to questions 19.............................................................................................13 Appendix 2 – Copy of review confirmation letter to HDC....................................................................14 Appendix 3 – Copy of Millfields appeal decision.................................................................................15 Rusper Neighbourhood Plan - Statement in Response to the Initial Comments of the Independent Examiner Page 2 1. Foreword - Coalescence Independent Examiner Question In the Foreword (fifth paragraph) there is a reference to ‘even small scale development’ leading to ‘the two towns becoming one large urban sprawl’. There is also a statement that ‘further development, especially to the West of Ifield, will be harmful to both the communities and the environment’. Where is the evidence on which these statements are based? Parish Council Response The evidence for the small scale development leading to a coalescence of Horsham and Crawley is based on a study of the maps after the currently permitted developments are complete. This shows that once the final phase of Kilnwood Vale (DC/10/1612) and North Horsham (DC/16/1677) developments are complete and the development of the garage at Faygate (DC/19/0095) and a drive-through take-away along the A264 (DC/19/1913), all of which have initial planning consent, then the distance along the A264 separating the two towns is approximately 1 mile. This is split into two gaps: the one between North Horsham and the new take-away drive through at the Cherry Tree public house location; and the other between Park Road in Faygate and the Kilnwood Vale development. So a small scale development in either of these areas would effectively join the two towns as a ribbon development along the A264. A development to the West of Ifield, especially to the scale proposed by Homes England, would have a significant impact and we do not feel that this is disputed. The question is on how detrimental that impact would be. If the full scale of the 10,000 homes proposed, along with a new dual carriageway, went ahead then the majority of the rural area for the whole eastern half of Rusper Parish would be urbanised as effectively a part of Crawley in much the same way as the Kilnwood Vale development. It is clear from all of our responses from the parish residents that the rural nature of the environment is the most important thing to them, reference the initial questionnaire responses and subsequent consultations. This is a clear indication that it is harmful to the community. This is further supported by the responses of community groups in Ifield that represent the Crawley residents that are most affected. In terms of the environment, all of the areas along Ifield Brook and the River Mole are recognised flood plain and represent important wild-life habitat. Whilst proposals would seek to protect these specific flood plain areas, covering existing open fields and woods with housing, roads and commercial developments will inevitably lead to increased rain water run off, which will further jeopardise areas at risk of and already subject to flooding further downstream along the River Mole. No viable mitigation for wildlife habitat can overcome the overall loss of habitat that building on such a large area of open fields and woods would bring about. 2. Planning Policy Context – Paragraph 3.8 Independent Examiner Question Paragraph 3.8 refers to major allocations being proposed – by whom and in which document? Parish Council Response The major allocations referred to are in North Horsham and in the Ifield and Kilnwood Vale areas, identified as Sites 10, 11, 12 and 13 within our site assessments document. They have all been considered by HDC and already have planning permission Site 10 – North Horsham, relates to HDC SHELAA reference SA296. This has outline approval for 2,750 home approximately 500 of which will fall within the Rusper plan area and work has just commenced on the initial infrastructure for that site. This development is now managed by Legal and Rusper Neighbourhood Plan - Statement in Response to the Initial Comments of the Independent Examiner Page 3 General. Latest planning application reference: DC/16/1677 Site 11 – Kilnwood Vale, relates to HDC SHELAA reference SA289. This will be one of the final phases of the Kilnwood Vale development. This development is managed by Crest Nicholson. Latest planning application reference: DC/10/1612 Site 12 – Rusper Road A, relates to HDC SHELAA reference SA272. This development along the Rusper Road in Ifield is just being completed and people are already living on site. This development is managed by Martin Grant Homes. Latest planning application reference: DC/13/0368 Site 13 – Rusper Road B, relates to HDC SHELAA reference SA468. This development along the Rusper Road in Ifield is well underway and people are already living on site. This development is managed by Bovis Homes. Latest planning application reference: DC/14/2132 These sites are also covered in the latest Horsham District Council SHELAA report https://rusper- np.org.uk/wp-content/uploads/2019/08/SHELAA_RUSPER_DEC18.pdf and the earlier SHELAA https://www.horsham.gov.uk/__data/assets/pdf_file/0006/66309/Rusper.pdf . This information is already listed on our website as part of the evidence base. 3. Planning Policy Context – Paragraph 3.12 Independent Examiner Question Paragraph 3.12 refers to Local Plan consultation in April 2018 and in paragraph 6.8 there is another reference to evidence dated April 2018. Is the Parish Council satisfied that these paragraphs accurately reflect the most up-to-date position, particularly in terms of the availability