Development Control (North) Committee TUESDAY 15TH MARCH 2011 at 6.30P.M

Park North, North Street, Horsham, West Sussex, RH12 1RL Tel: (01403) 215100 Fax: (01403) 262985 (Calls may be recorded) DX 57609 HORSHAM - 6 www.horsham.gov.uk

Tom Crowley, Chief Executive

Personal callers and deliveries: please come to Park North

Development Control (North) Committee TUESDAY 15TH MARCH 2011 AT 6.30p.m. COUNCIL CHAMBER, PARK NORTH, NORTH STREET, HORSHAM

Councillors: Ian Howard (Chairman) Liz Kitchen (Vice-Chairman) John Bailey David Jenkins Andrew Baldwin Sheila Matthews Gordon Brown Christian Mitchell Clive Burgess Robert Nye Roy Cornell Linda Pettitt Christine Costin Peter Rowlinson Leonard Crosbie Pat Rutherford Sheila Dale David Sheldon Ross Dye David Skipp Duncan England Claire Vickers Sarah Gray Belinda Walters David Holmes Kyle Wickens Sally Horner

Co-opted Sally Blake Members of Ali Burke Crawley John Denman Borough Stephen Joyce Council:

You are summoned to the meeting to transact the following business

Tom Crowley Chief Executive

AGENDA 1. Apologies for absence

2. To receive any declarations of interest from Members of the Committee – any clarification on whether a Member has an interest should be sought before attending the meeting.

3. To receive any announcements from the Chairman of the Committee or the Chief Executive

Paper certified as sustainable by an independent global forest certification organisation

4. To consider the following report and to take such action thereon as may be necessary:

Application DC/10/1612 - Outline approval for the development of approximately 2500 dwellings, new access from A264 and a secondary access from A264, neighbourhood centre, comprising retail, community building with library facility, public house, primary care centre and care home, main pumping station, land for primary school and nursery, land for employment uses, new rail station, energy centre and associated amenity space; full planning permission for engineering operations associated with landfill remediation and associated infrastructure including pumping station; full permission for the construction of a 3 to 6 metre high (above ground level) noise attenuation landform for approximately 700 metres, associated landscaping, pedestrian/cycleway and service provision (land known as Kilnwood Vale); full permission for the development of Phase 1 of 291 dwellings, internal roads, garages, driveways 757 parking spaces, pathways, sub-station, floor attenuation ponds and associated amenity space.

NOTE:

The suggested conditions and reasons for refusal may alter from those set out in the agenda.

5. Items not on the agenda which the Chairman of the meeting is of the opinion should be considered as urgent because of the special circumstances.

AREA NORTH COMMITTEE – 15TH MARCH 2011

The Report by the Head of Planning and Environmental Services contains the following items:

Item Ward Reference Site No. Number

A1 Rusper & DC/10/1612 HOLMBUSH FARM LANDFILL SITE, CRAWLEY ROAD, FAYGATE Colgate

CONSULTATION SUMMARY – CREST DC/10/1612

Please find below summarised comments from the following consultees and interested parties:

Consultee Page number Summary of key comments/conclusions of full comments Natural England 18 No objection in accordance with the submitted information. Environment 18 - 24 Amended/additional information was submitted by the applicant. On this basis the Environment Agency has removed its Agency original objection. The Environment Agency therefore has no objection to the proposal subject to their recommended conditions and informatives. Thames Water 24 - 25 Waste Comments

Surface Water Drainage - With regard to surface water drainage it is the responsibility of a developer to make proper provision for drainage to ground, water courses or a suitable sewer.

A Trade Effluent Consent will be required for any Effluent discharge other than a 'Domestic Discharge'.

Water Comments With regard to water supply, this comes within the area covered by the Southern Water.

Supplementary Comments Thames Water propose to upgrade Crawley STW between 2010-2015 using growth forecasts outlined in the LDF Documentation for Crawley BC, Mid Sussex DC and Horsham DC. This upgrade should yield sufficient capacity until 2021. If the proposed development forms part of the already published figures in LDF documentation up to 2021, then flows from the development could potentially be accommodated by Crawley works upgrade. However, if the development is in addition to the figures already forecasted, it would need to be assessed separately. (Officers note that when the LDF was adopted this development was planned to finish by 2018 and Thames Water were part of the JAAP consultation process).

Network Rail 25 - 26 No objection subject to recommended conditions. Highways 26 - 32 The Highways Agency has imposed a number of holding objections on the application. The latest of which is to the 24th

1 Agency March “to allow additional time for the applicant to provide supplementary information requested to enable the secretary to come to a view.”

The HA consider that works are required to junction 11 of the M23 to mitigate against the impact of the development. Officers are aware that the HA and the applicant have been in discussions regarding how these works can be secured. In this regard the HA have provided some further comments which state: “a key element of the use of a Grampian condition is that there must be a reasonable prospect of the works being delivered. To this end we are currently reviewing the developer's proposals against our design standards and Safety Audit procedures. We are approaching the end of this process and I am hopeful that we will soon be able to remove our holding direction, and instead direct conditions to be imposed on any planning permission.”

Officers will update any further comments from the HA to committee. Sussex Police 32 - 33 Sussex Police state that “Secured By Design guidance discourages parking courts….If these parking courts are to be implemented, they must have natural surveillance from pedestrian footfall, surveillance from active rooms within dwellings and be well illuminated.”

As set out in the report Officers remain concerned about the use of parking courts along the western boundary where they remain isolated. Gating these courts only seeks to exacerbate their isolation and this is at odds with creating an inclusive community. Please see paragraph 8.57 of the Officers report.

The remainder of comments from Sussex Police are considered to be addressed by conditions relating to the phase 1 and for consideration at the detailed stages for later phases. Countryside 33 - 34 Concerns are raised that the multi-use circular strategic spine route originally proposed is no longer included. Access Forum Countryside Access Forum consider in view of the likely usage and recreational importance of this route, a grade for West Sussex separation at the A264 should have been sought, especially as the western bridge over the railway, for walkers, cyclists and the British and equestrians only, is not now included in these plans. It is considered essential that the new link paths proposed at Horse Society both the railway line and the A264 be dedicated as public rights of way, with bridleway status, and added to the definitive map.

It is noted that there does not appear to be any mention of linking routes on the southern side of the A264. A new route is needed going east, to link with the existing line of bridleway 1550/1, and again this should be dedicated as a bridleway. Equestrians along with all other users prefer circular routes. Consequently it is inevitable that they will use the estate roads and what is currently the western railway bridge to rejoin bridleway 1550. The access link to the bridleway in the north west corner needs to be multi-use as agreed by the Inspector. All links into the surrounding countryside on the eastern side of the development, at Ifield West, Bewbush and Sullivan Drive need to be multi-use.

The above comments are discussed in detail in Paragraphs 8.17 – 8.22 of the Officers report

Would Network Rail seek closure of the level crossing? Clarification should be sought regarding this, as if the information is correct, the bridleway will need to be legally diverted. (The use of this crossing would be reviewed when

2 the bridge is in operation.)

Gatwick Airport 34 - 35 Further information and amendments has been submitted regarding landscaping species for the phase 1 layout. On this basis Gatwick Airport are now satisfied with the phase 1 element of the application subject to conditions.

Gatwick are however requiring the following condition regarding heights. No buildings or structures associated with the development hereby permitted shall exceed the heights as shown on the plan accompanying our comments in metres Above Ordnance Datum AOD.

The developer has suggested that a condition could be imposed stating that no buildings within the safeguarding area are higher than 8.5m. However, Gatwick have stated that a height of 8.5m would still be in conflict with part of the infringement area. High Wealds 36 No objection in accordance with the submitted information. Area of Outstanding Natural Beauty

National Cycling 36 The National Cycling Organisation considers that the most important feature of the development is to ensure that the Organisation Pegasus crossing across the A264 is implemented together with speed limit reductions. The speed limit in the neighbourhood/all roads should be limited to a maximum of 20 mph on all roads.

A new Pegasus crossing would be provided prior to the completion of the 300th dwelling. The speed limit within the development is proposed to be 20mph and there would be a mechanism in the WSCC S106 to monitor this and seek improvements to the road network to facilitate this if needed. The remainder of comments from the National Cycling Organisation are considered to be relevant to the later detailed applications. Please see Paragraphs 8.17 – 8.22 of the Officers report Parish Councils Colgate Parish 36 - 38 Whilst the Parish Council are sceptical about the traffic model County Highways and the Highway Authority consider Council that the TA and the modelling are acceptable, subject to the recommended conditions and contents of a legal agreement as outlined in the Officer report.

The Parish Council would like some level of assurance that the development boundary will be strictly enforced. In this regard the development site is within the strategic site boundary which forms part of the Local Development Framework.

Comments from the Parish regarding the station car park are noted. Officers consider the principle of 200 spaces to serve the station and neighbouring uses within the development is acceptable providing its need can be demonstrated which can form part of the required design brief. However, its detailed design and management will be subject to future controls within detailed applications and conditions. The decision to deliver the station and the impact of any neighbouring stations is primarily with Network Rail. These decisions will help inform futures phases, management and

3 conditions on this site.

Can we have more detail about the supply of water? Has this development now tipped the balance for the requirement of a new reservoir in the area? Will these houses have the capability of waste water recycling? The provision of a reservoir is not a requirement of the JAAP. Comments received from Southern Water will be updated at committee.

Rusper Parish 38 Rusper Parish Council raise concerns to the road infrastructure and the potential for Rusper Parish to suffer with extra Council through traffic from the A24 and elsewhere.

Officers note the concerns of Rusper Parish Council. Rat-running was an issue which was discussed at the Examination in Public but was principally a concern for Ifield and Bewbush. WSCC are satisfied with the highway package submitted by the developer and the measures which can be put in place to mitigate the impacts of this specific development.

Horsham District Council Housing Officer 38 From the 5 phases 29.7% affordable housing (673 units) would be achieved and would rise to 30.7% (767 units) should the reserve land be delivered at 40% affordable housing. The base guaranteed starting point of 70% shared ownership and 30% rented. Housing Officers feel that this is a reasonable affordable housing offer in the current climate, and is a result of comprehensive and rigorous negotiations between Horsham District Council, Crawley Borough Council and the applicant. Arboricultural 38 - 40 No objection in accordance with the submitted information. Officer Landscape 40 - 67 Whilst some of the original concerns of the Landscape Architect have been addressed through additional and amended Architect information concerns are still raised to a number of points which are summarised below. As you can see from the comments below many of these can be controlled through conditions and a legal agreement. Officer comments are in italics.  CHP Plant/chimney – I remain very concerned about the height of the CHP chimney up to 60m in height- adverse impact on the skyline of the kilnwood ridge, wider impacts on the surrounding countryside and the Strategic gap. Quality of recent wire frame photomontages provided is poor and does not give any more confidence that this impact can be contained. Also the visual relationship to phase one housing could be adverse if the building is as high as 25m as shown on the DAS building heights plan. Could a condition be imposed to restrict heights?  We have not been given any illustrative information of similar facilities elsewhere- no principles in the DAS to govern design – may need to look at carefully worded condition. (Officers consider the concerns of the Landscape Architect and Environmental Health can be addressed by the submission of a technical and design brief for this building prior to the commencement of the northern section of Phase 1. Officers note the High Wealds AONB body do not raise objections to the chimney.)  Ancient woodland standoff- a number of areas around the woods are not compliant with the 15m setback from any development. Could a condition be imposed that states notwithstanding the DAS plans the development

4  Circus public art feature/needle- if it’s the height illustrated it will have a cumulative adverse visual impact with the chimney. Building heights plan does not have any height limitation where it is located. Could a condition be imposed to restrict its height to no more than that of surrounding buildings? (Officers note that an amended illustrative drawing forming part of the Design and Access Statement has been submitted omitting the needle feature. Details of public art can be secured as part of the/legal agreement).  Loss of tree group W15. I continue to object to loss- reasons set out in previous consultation responses. If they are removed a condition should be imposed to require large semi-mature replacement trees 50-60cm girth in nearest open spaces to area of loss. (Officers consider that semi-mature trees can be provided by condition).  Neighbourhood Centre, Station area and school- as previously recommended support a single design brief for the whole area to be secured by condition and a clause in the legal agreement setting out an agreed participatory process for its production. (Officers consider that a design brief can be secured by condition/legal agreement).  Bridges- the location and type of the 3 proposed bridges has not been shown on the DAS movement parameter plan. (Officers are content that the Design and Access Statement adequately portrays the principle of the proposed bridges)  Hard landscape palette in code that the applicant refuses to amend is not agreed. This can be secured by condition. (Officers consider this can be secured by condition).

Utilities Report  Previous inadequacies identified have not been dealt with. Condition provision of a services strategy. (Officers consider this can be secured by condition).

Phase 1  Parking courts cramped- poor environment with lack of space for landscaping. This should be a negotiating point after committee before grant of permission. (This remains a concern of officers – please see Paragraph 8.57 of the Officer report)  Quality of eastern and western green corridor boundaries. Comments regarding hedge and hedgerow tree planting in gaps are welcomed but fencing/railing issue still needs to be looked at in more detail. A condition is recommended that details are submitted for approval. (This remains a concern of officers – please see Paragraph 8.57 of the Officer report)  Provision of understorey shrub planting on noise bund, need for adequate structural planting around balancing lake and additional structural planting on access road bend. This can be insisted upon on when discharging landscape conditions. (Officers consider this can be addressed by conditions and detailed applications).

Conservation 67 - 76 Summary of final observations and Design Neighbourhood Centre Design Brief: There are areas that need to be strengthened to give a greater sense of clarity to

5 Officer this core and important area. In order to move forward, a constructive way of securing an appropriate set of principles would be to, by way of condition require the submission of a design brief. (Officers consider this is an acceptable approach).

Flats over garages (FOG) /parking courts: There has always been concern over some of the more isolated examples of these within the phase 1 layout. It is disappointing to see that some of specifics of these previously raised concerns over units 149, 191, 194 have not been addressed. Following on from this, some of the outlook and environment around the FOGs would appear to look like a car park, rather than an active and space of character. This is especially concerning with the courts to the western boundary where they will be visually open to the countryside beyond. Furthermore gated car parking courts increase the isolation to individual dwellings and do not enable such areas to be connected to the wider community and network. A set of design principles for these areas could help secure an appropriate approach for parking courts. (This remains a concern of officers – please see Paragraph 8.57 of the Officer report)

Western and eastern edges:The inward looking layout of phase I has always been a concern. A well designed and managed approach to the edges to help mitigate the issues of having rear fences onto the countryside and the tree/hedge line to the eastern boundary has always been welcomed. A compromise between a high close boarded fence (which would be inappropriate and unacceptable visually) and a secure boundary by having a 1.2metre close boarded fence and a trellis above, with landscaping to screen the fence is on balance, acceptable. (This remains a concern of officers – please see Paragraph 8.57 of the Officer report)

Eastern edge:The amended screening of the eastern edge is welcomed, and subject to the Landscape Officers comments, is acceptable.

Secured by design and other detail design amendments: It is appreciated that not everything for these matters can be” designed out”. However there are a few further points that could be resolved: Gates and alleyways to rear: 132-140 & 68-75 may need reorganising Car ports: 156-7 & 162-3 could be removed to help facilitate a better space Unit 21: Repositioning of door is welcomed – I note a similar unit is located at 67- this should also be repositioned. A small porch over door may add to detail on the elevation. Eastern edge of the neighbourhood park: the change in materials are noted and welcomed Apartment buildings 274-286: The increased fenestration is welcomed and noted.

Issues not addressed: Unfortunately there appears to still remain a number of issues that are yet to be resolved. Culmulatively, these and the issues identified above have a impact on the design of the development that together still is yet to meet the high standard set in the JAAP. Please refer to my comments in the previous design schedule 20. Other spaces- with the exception of Kilnwood Vale Park: Text not amended or clarified as requested

Points still to be addressed from phase 1 comments dated 10th November 2010 Units 55-66. This large block is highly visible. Its plain character of architectural style is obviously affordable, especially when read in context with 68-103 street elevation. (Please see Paragraph 8.57 of the Officer report Environmental 76 - 80 The Environmental Officer is satisfied that the additional information submitted addresses their original concerns. Officer (ES Statement) Drainage/ 80 No objection in accordance with the submitted information and the approval of further details. Engineering Public Health 80 - 82 Additional information has been submitted by the applicant to try and address the original concerns of the and Licencing Environmental Protection Officer. The outstanding issues are summarised as follows:  There appears to be no mention of the discussion concerning re-orientation of the internal layouts of the plots indentified. (The applicants have not reorientated the units in question).  I can’t see the objection to measuring the performance of the barrier at night. None of reasons quoted are insurmountable.  The comments in respect of the accuracy of the noise modelling are noted. However it was the accuracy of Soundplan in respect of PPG24 that was under discussion with a potential margin of error of up to 25m in the modelled contours.  I would argue that the suitability of this part of the site for development depends on the noise barrier. The plans showing noise levels on first and second floor levels demonstrate this. Therefore it is only prudent to ensure the barrier performs as predicted. Such a condition would be relevant, technically feasible and necessary. (Officers recognise this concern and consider this can be addressed through a condition – please see Paragraphs 8.48 – 8.49 and 8.59 of the Officer report)  As I have stated before much of this debate could be resolved if the internal layout of the affected plots were to be rearranged so that bedrooms were not overlooking the A264, particularly for those units that derive least protection from the noise barrier.  With respect to the CHP plant/Energy Centre the additional detail helps but it is clear that the selection of technology for the CHP plant/Energy Centre will be constrained by the proximity of residential development and the resultant noise targets. At this stage it is not clear how significant ancillary noise such as fuel deliveries etc will be. (Officers recognise this concern and consider this can be addressed through conditions – Please see paragraph 8.15 xii of the Officer report)

Building Control 82 - 83 No objection but raise a number of comments for the building regulation stage of the development.

7 Crawley Borough Council Urban Design 83 - 107 Whilst some of the original concerns of the Crawley Urban Design Manager have been addressed through additional Officer and amended information concerns are still raised to a number of points which are summarised below: HDC Officer comments are in italics  Concerns are raised to the fact that the development will not provide residential uses above the relatively large and prominent foodstore. Without this commitment and the consequent amount of activity and natural surveillance, the Borough Council does not support the design brief approach as a quality ‘fix’ would not have been achieved. There is also a concern regarding road safety in and around the small neighbourhood centre car park at the beginning and end of the school day. (Officers consider that an acceptable approach is to require a detailed design brief for the neighbourhood centre, Station Square and Brook Crossing)  Amended plans have been submitted showing proposals to enlarge 10 rear gardens. For houses generally 64% would now meet, exceed or be within 10% of the standard whereas for affordable houses this falls to only 40%. Some of the most deficient gardens would be for affordable homes that are likely to be fully occupied. Improving the size of these gardens could be easily achieved without affecting the mix, density and number of units. (Officers note that HDC as the determining authority do not have space standards but HDC Policy DC9 provides a benchmark for assessment)  Borough Council has suggested that some areas of incidental open space could be modified with fencing and direct access to provide semi-private amenity areas for flats. However, in some instances this has not been achieved. (Officers consider that fencing and other boundary treatments and landscaping can be controlled by condition).  There is a concern that flats adjacent to paths could be subject to crime and anti-social behaviour without fences fences. Juliet balconies comprise a rail in front of ‘French’ doors and should not be used as a substitute for private amenity space or walk on balconies. (Please see above)  The suggestion of gated parking courts adjacent to the FOGs is not supported by Horsham District Council. The amount of natural surveillance over the parking courts that can be achieved from one small flat would be limited. (This remains a concern of officers – please see Paragraph 8.57 of the Officer report)  The proposed boundary treatment adjacent the parking courts would be more robust, although the longevity of mesh is questionable, but the 1.2m height would be an insufficient deterrent. The Council has expressed concerns regarding the introverted layout of Phase 1. The scheme would present rear garden boundaries to accessible planted areas, providing opportunities for crime and dumping. (This remains a concern of officers – please see Paragraph 8.57 of the Officer report)  Parking dominance of affordable housing area (Plots 210-225) combined with a lower quality of architecture generally, in particular the prominent but bland A3 house type, and some very small gardens. (This remains a

8  Concerns remain regarding the lack of natural surveillance to the frontages, side gates and boundaries of Plot 1, 119, 143, 149, 155, 160, 272 and 273 and the extent to which residents would come into contact with neighbours. (Officers note it may be difficult to design out all issues and note that side gates are commonplace in developments - however concern is raised where the layout could easily be improved – please see Paragraph 8.7 of the Officer report).  Rear alleys to Plots 68-75 and 132-135,139 and 140 remain a concern with respect to crime, anti-social behaviour and dumping. (This is a concern of Officers particularly the large alley with a bend which would serve as rear access for bin storage to plots 132-135,139 and 140 – – please see Paragraph 8.7 of the Officer report).  Unit 67 - the reorientation of the main façade to the street, as proposed for Plot 2, could also address concerns regarding this prominent but bland elevation. (Officers note this would improve this plot)  A23/A2220 highway works – the existing trees would be lost to create the additional lane, without replacement, and pedestrian/cyclist desire lines between Gossops Green and Southgate made more difficult. The setting of the listed building would be negatively affected. (These trees are outside of the application site and Officers note the existing urban setting of the listed building. This building is within Crawley District and was not a recommendation for refusal in the CBC committee report).  The footpath and cycle links into Bewbush and Ifield West lack natural surveillance and the detailed design of these links should take account of this e.g. lighting and an open aspect. (Officers consider that conditions regarding lighting, landscaping and the phasing of these would mitigate this concern and that in the longer term their would be greater surveillance of these links).  The Woodcroft Road bus gate drawings should make provision for lost on-street parking as there is a shortage of parking in the area. How will these relocated spaces be paid for and delivered? (Officers consider this is a land matter for CBC)  The key spaces information in the DAS is lacking in sufficient clarity with respect of Brook Crossing and Station Square to establish a design quality fix for this prominent and important location. (Officers consider this concern could be addressed by a design brief) Contaminated 108 No objection subject to details being submitted at the reserved matters phase. Land Environmental 108 - 112 Additional information has been submitted by the applicant to try and address the original concerns of the Protection Environmental Protection Officer. The outstanding issues are summarised as follows: Officer  The noise bund is integral to the environmental design of the development. It’s performance will significantly affect the noise exposure of a large number of residences, not just those closest to the bund. It is reasonable for the LPA to have confidence in the performance of the barrier. As such the LPA needs to be able to ensure that the noise barrier is built in accordance with a verifiable design that matches or exceeds the insertion loss

9  It is accepted that post completion testing will not be required if confidence and verifiability can be achieved in other ways.  The figures supplied within the technical notes for the accuracy of the noise modelling are accepted as nominal. I would request confirmation of the grid resolution used and of any efficiency settings used during the modelling exercise and their effect (if any) on the accuracy of results. It was requested that the predicted noise contours for the site, at ground, first and second floor level be submitted and referenced to drawings showing the bund design used to achieve these levels.  In summary, the data so far supplied for the noise bund, and its position and height along the southern boundary, is neither complete nor detailed enough to allow for verification of the design and performance of the built barrier with that used in the noise modelling.  I continue to recommend therefore, that construction of the bund, to the satisfaction of the LPA, is completed prior to first occupation of dwellings. (Officers recognise this concern and consider this can be addressed through a condition – please see Paragraphs 8.48 – 8.49 and 8.59 of the Officer report)

The proposed energy centre  My comments of 4th November 2010 remain as advice to the LPA. Building up to the boundary of the proposed energy centre at this stage may place constraint on the design and technology that can be used at the energy centre site. This may not be satisfactory to the LPA; it depends on the type and mix of energy sources envisaged, as I understand it this has yet to be agreed. (Officers recognise this concern and consider this can be addressed through conditions – Please see paragraph 8.15 xii of the Officer report)  The technical notes outline three energy source options which could, with correct mitigation, meet the agreed BS4142 criteria of a rating level of 10dB or more below background.  At no stage has it been recommended that occupation of dwellings be conditional on certainty about the energy centre proposals. Orientation of dwellings  The developer had stated that only a small number of second floor bedrooms were affected by noise levels above 60dB LAeq, 16h. As such, I suggested that it may require very little effort at this stage to minimise this exposure, by considering simple reorientation of building footprint or internal layout. The applicant advises that their architects consider this not to be achievable, given the design of the affordable units proposed. (The applicants have not reoriented the dwellings. Officers therefore consider the concerns can be addressed through a condition relating to the noise bund).  The developer has already committed to noise insulate all dwellings to achieve the “good” standard of BS8233 for internal noise environment. Which in my previous memo is one of the matters that I recommend is secured

10 Environmental 112 - 113 Construction Phase Impacts Health Officer  The construction impacts can be minimised through the use of the recommended mitigation measures. This should include a Construction Environmental Management Plan (CEMP), which should be agreed with the Local Planning Authority prior to works commencing. (Officers consider this can be addressed by a condition).

Operational Phase Impacts  Energy Centre/CHP: The air quality dispersion modelling for the Energy Centre/CHP has relied on assumptions about fuel type, stack height and the exact size, design, location and layout of the plant.  As proposals for the development are progressed there may be changes in these parameters that will affect the results of the modelled air quality impacts on sensitive receptors and may also change the visual impact of the plant (eg stack height). Crawley Borough Council would therefore recommend that the Energy Centre/CHP element of this outline application is listed as a Reserved Matter requiring a further AQ impact assessment.  A number of traffic mitigation measures have been proposed in the Transport Assessment. It is recommended that even where the impact is considered small or medium, further mitigation in the form of a Low Emission Strategy (LES) should be incorporated into the design scheme to ensure that the development conforms to best practise standards and is “air quality neutral” as far as is reasonably practicable. (Officers recognise this concern and consider this can be addressed through a condition)

Sewage Storage Tanks  The AMP5 capital expenditure was determined in November 2009, following which a decision was to have been made on the provision of sewage storage tanks on the site (to hold sewage so that it could be sent up the pipeline at a controlled rate). However, there is no information in the application regarding this provision.  As there is a risk of septicity and possible odour emissions, the design and exact location in relation to sensitive receptors needs to be assessed. Therefore Crawley Borough Council would like to see this element of the outline application held as a Reserved Matter requiring a further AQ impact assessment when the design parameters are know at the Full Planning Application stage. (Officers consider this concern can be addressed by the Grampian condition recommended by Thames Water).

Development 113 - 115 A number of comments are raised regarding bus stop locations and design. Officers consider the broad location of bus Management stops is considered to be acceptable however their exact location and design, including shelters, will be controlled by condition. The separation between footpaths and cycleways is considered to be a matter for the detailed applications and/or through conditions.

Concerns are raised to the number of parking spaces proposed in the station car park and the possibility of this being used by a wider population base, and not just this proposed neighbourhood. Officers consider the principle of this size of car park is acceptable if the need can be demonstrated which can form part of the required station brief. The management of the car park will be a matter for discussion at the detailed stages. West Sussex 115 - 129 The main comments and outcome of original concerns from WSCC are summarised below:

11 County Council  The retention of existing hedgerows and trees should ideally be co-ordinated with the open space strategy so that the existing trees are designed into open spaces linked by green corridors. It is unfortunate that in the phase 1 of the development this has not been achieved.  The east/west road connections are not shown as green gateways. Further design input could be made to achieve this in a proactive way. (HDC Landscape Officer has provided detailed comments on the scheme – please see summary above)  WSCC has no strategic ecological objections to the planning application subject to conditions.  No objection is made to the proposals on archaeological grounds, subject to suitable archaeological safeguards.  There is no definitive public right of way that crosses the proposed site, but there is a public bridleway that runs along the northern and western boundaries.  The length of bridleway that continues southwards to the A264 and Buchan Park has not been improved and is difficult for cyclists and equestrians to negotiate.  The Countryside Access Forum for West Sussex has advised that more walkers, cyclists and equestrians would use this bridleway if safe crossings of the railway line and A264 can be achieved. In this respect, a new eastern bridge will be provided by the development over the railway lines to be fully design compliant for equestrian use.  A new Pegasus crossing will also be provided across the A264 as part of the secondary traffic signal access serving the development to allow bridleway users cross this busy road much more safely. This crossing, however, will be some distance west of the definitive route of the bridleway, so new links would have to be provided to allow users to deviate from and back to the definitive route to allow continuity.  It is not proposed to formally divert or downgrade the existing definitive route of the public bridleway as part of this development, but may be reviewed by WSCC in the future.  The trip rate data used in the TA has been based upon two scenarios (with or without a new railway station), as agreed at the TA scoping stage, and these trip rates are broadly similar to those used at the Examination in Public. Although the secondary access is not included in the TA, the presence of one or two points of access from the site onto the A264 would make no difference to the SATURN model assignment, provided that neither results in unacceptable delays on the A264 as both accesses are on the same link.  It is confirmed that the potential rat-running through Bewbush and Ifield was an issue at the Examination in Public and this is why journey times were conducted by the applicant in 2006…the TA demonstrates to WSCC’s satisfaction that the model does not predict any significant levels of rat-running of development generated trips through Bewbush and Ifield which subsequently rejoin the A23. However, as a result of development trip generation the model indicates that improvements to the M23 Junction 11, Cheals roundabout and the Sullivan Drive junction will eventually be required.  The provision of access to Phase 1 from the new A264 roundabout is acceptable in principle. However this phase of the development will be isolated from local facilities. It is therefore essential that public transport link and cycle/pedestrian links are introduced to serve phase 1 during this interim period.  The applicants are proposing to introduce a small shuttle bus service between the early phases of the

12  The proposed footpath/cycle route between phase 1 and Bewbush is shown as running within the boundary along the northern edge of the side of the A264 to Sullivan Drive and is acceptable in principle, although users will have to cross the main construction access at one point.  WSCC will require the applicants to deliver the new slip road at the A2220 approach to Cheals roundabout as this is required in capacity terms to mitigate the impact of Phase 1.

 To mitigate the impact of the A264 access works on the AONB to the south, WSCC will require a scheme of appropriate planting within the public highway together with a long-term management plan that requires the developer to maintain the planting until completion of the development in 2023 with commuted sum payments for a 13 year period post-completion – Section 106 requirement.  The applicant has now agreed to the inclusion of this requirement in the Section 106 agreement with WSCC. The requirement will be for the developer to carry out native species planting within the highway to be maintained by the developer for a period of 13 years until the completion of the development. There will also be a requirement for a commuted sum payment to maintain the planting for a further period of 12 years post-development completion until the trees have reached semi-maturity.  The secondary traffic signalised access and Pegasus crossing needs to be delivered much earlier in the development programme to provide a safe crossing point to the AONB for new and existing residents.  Discussions have taken place with the applicant and it has been agreed that the secondary access and crossing point will now be completed prior to the construction of the 300th dwelling on the development. This is much lower than the 800th dwelling previously proposed and will ensure that a crossing is in place much earlier in the development process to the benefit of existing public bridleway users and new residents. This will be a Section 106 requirement.  The area shown for the new A264 access roundabout will incur significant loss of tree cover as a result of the development. The amount of replacement planting shown on the proposals in this location does not provide sufficient buffering or containment of the development from the west and is not in accordance with the adopted WSCC Landscape Strategy.  WSCC and HDC landscape officers require that there be a requirement for a planning condition requiring the applicant to provide thick hedgerow planting on the access road embankment and 20m width woodland planting on the boundary of the reserved land. I understand that the HDC landscape officer will be recommending an appropriate planning condition.  Further investigation into the cumulative visual impact of the proposed (outline) vertical orientation feature in the Circus, and the proposed height of the Energy Centre Stack is required. Views from the AONB and land to the north of the development site, in particular, must be considered.  I understand that the HDC landscape officer has been considering this issue. (This issue is discussed in HDC and CBC Officer comments)  Further details are required for the provision of further structure and succession planting within the

13  I understand that the relationship of the neighbourhood park to the eastern greenway has been discussed at a recent meeting between the applicant and HDC. I further understand that they are not willing to compromise on this so any concerns will have to be included with any other design issues. I note that this is being considered by the HDC landscape officer.  The central bridge over the railway line would need to be designed to safely accommodate equestrian users.  Both railway bridges will be designed to safely accommodate equestrians, but only the eastern bridge will have a segregated equestrian route. This is considered acceptable to WSCC. (This issue is discussed in paragraphs 8.17 – 8.22 of the Officer report).  WSCC requires that the Sullivan Drive junction be subject to continuous monitoring during the development period and a financial contribution provided to mitigate the impact of the development if found necessary – Section 106 requirement.  The Sullivan Drive junction is not predicted to be close to capacity until much later in the development programme and will be monitored after the commencement of Phase 4 (1151st dwelling) and a financial contribution made towards future improvements if necessary. This is acceptable and will be secured in the Section 106 agreement with WSCC.  WSCC requires that the interim Stage 1 improvement of the Cheals junction be delivered by the developer upon completion of the 300th dwelling on their development – Section 106 requirement.  This has now been agreed with the applicant and will be secured in the Section 106 agreement with WSCC.  WSCC is concerned that there will be insufficient funding to deliver the full Stage 2 traffic signalled junction at Cheals roundabout upon completion of Phase 4 of the development (approx 2,100 dwellings).  The applicant is prepared to make a sizeable proportional contribution to a Stage 2 full traffic signalisation at the Cheals junction upon completion of Phase 4 of the development. However, there would still be a significant funding shortfall if this scheme is to be delivered and there is considerable uncertainty that the funding shortfall can be made up by contributions from other developments by the time required. The applicant has therefore been requested to provide an alternative modified roundabout option that was initially considered as part of the traffic modelling work in February 2008. Although not as effective as the traffic signalisation scheme for improving pedestrian/cycle links or bus priority, a modified roundabout scheme would improve traffic capacity whilst still retaining the existing pedestrian/cycle crossing points and would be much more deliverable in terms of funding. A modified roundabout scheme could also be designed to complement the Stage 1 interim improvement therefore being more cost effective. It would also have least impact on the access arrangements for the proposed new fire station site on land in the south west corner of the junction.  WSCC is concerned that the plans used in the Design Statement would not appear to accord with the landscaping plans which include additional features (such as walls) which will need to be subject to RRRA. Therefore, either the Design Statement or landscaping plans need to be amended to be consistent.  Both WSCC and HDC landscape officers have objected to the curved wall features. It is understood that the applicant’s are now proposing a ‘living wall’ which is more acceptable in landscaping terms.  WSCC has serious concerns about the impact of construction traffic accessing Phases 3, 4 and 5 through

14  The applicant has agreed to a planning condition requiring that a full construction traffic management plan is submitted to and approved by the LPA indicating the proposed routing of construction traffic from the A264 to each phase of the development.  Although the design of the internal access road layout is broadly in accordance with Manual for Streets, certain speed criteria has to be met if a 20mph Zone or 20mph speed limit is to be accepted. At this stage it is not clear what speed limits will be generated within the development and these will need to be measured and monitored to provide the evidence base for the introduction of such a limit. If speeds do not meet the requirements, then additional features may be required on certain routes as necessary – Section 106 requirement.  The applicant has agreed to carry out speed surveys once the roads have been constructed and ready for use. It is contended that traffic speeds will reduce with higher volumes of traffic using the roads as each phase is delivered. There will need to be a mechanism in the S106 planning agreement to reflect this.  WSCC requires that the shuttle bus service is of satisfactory quality and frequency and would want details of the service to be submitted for approval and reviewed as development progresses until such time as the Sullivan Drive bus gate is provided and Fastway services can access the site – Section 106 requirement.  The specification and frequency of the shuttle bus service along with the diversion of other services will be included in the S106 agreement. However, Metrobus has advised that they would like to see a more frequent 20 minute service during the day with services lasting longer into the evening. Although WSCC is content for any bus subsidy to be agreed between the applicant and the bus operator, there needs to be an adequate mechanism in the S106 planning agreement to enforce the provision of this bus service so as to embed bus services within the development at an early stage.  It is also not clear what level of bus service subsidy will be required to encourage bus operators to divert the services into the development until additional patronage results in the extended services becoming self-financing. This has been mentioned in Appendix 1 of the proposed Section 106 Heads of Terms but no detail is given.  There is likely to be a significant level of subsidy required to encourage bus operators to extend services into the site during the early years. Although WSCC is content for any bus subsidies to be agreed between the applicant and bus operators, there needs to be an adequate mechanism in the S106 planning agreement to enforce the provision of the specified bus services so as to embed bus services within the development from an early stage.  The red line of the planning application does not include the land required for the bus gates and their delivery is therefore uncertain. This would have significant implications for the applicant’s public transport strategy and WSCC would want confirmation that the bus gates can indeed be delivered. If not, then WSCC will be raising an objection to the planning application on the grounds that it is not satisfied that the public transport strategy can be delivered.  It is understood that the developer is in the process of acquiring the necessary land for the bus gates from Crawley BC and that separate planning application may be submitted for these features which are outside of the red line of this planning application. (Officers consider that the provision of the bus gates can be secured by a Grampian

15  The proposed Travel Plan in the TA has been reviewed and there are a number of points which need to be addressed. The previously recommended Green Travel Plan planning condition therefore needs to remain.

Conditions are recommended by WSCC relating to:  Tree protection  A scheme of perimeter planting and landscaping within and along the A264 site frontage (to the south and west of the site) adjacent to AONB  A scheme of suitable native structure planting shall be submitted to the LPA along the western side of the new A264 roundabout junction and main site access road  A landscaping management plan together with establishment and maintenance proposals for the planting within the public highway.  Green infrastructure strategy  Building heights along Bewbush Brook  Biodiversity Management plan  Methodology to support the detailed applications detailing how the ancient woodland component of Pondtail Shaw will be protected during the construction of the CHP plant.  How detailed application comply with ES.  Strategy has been submitted to support the detailed applications describing how the local community will aid the management of ecologically sensitive sites as nature reserves, i.e. LNR, Pocket Parks.  Phase 1 – an improved scheme of works, buffer zone and ecological enhancement scheme to be submitted.  Phase 1 – an improved native planting scheme  Heritage Asset Mitigation Strategy  Programme of archaeological work including a Written Scheme of Investigation has been submitted to and approved by the local planning authority in writing  A construction traffic management plan has been submitted to and approved by the LPA indicating the proposed routing of construction traffic from the A264 to each phase of the development.  Satisfactory provision made within the site for secure construction compounds, construction materials storage, the loading, unloading and turning of delivery vehicles and an area to be set aside for construction employees parking. In accordance with details to be approved by the LPA.  The existing Public Bridlepath 1550 shall be improved to cyclepath standards to the satisfaction of the LPA where it forms part of the new cyclepath connection between the development and the Bewbush neighbourhood.  No dwelling or buildings hereby permitted shall be occupied unless and until an access from the A264 has been designed, laid out and constructed in accordance with full plans and construction details (including safety audits) to be submitted and approved to the satisfaction of the LPA.  The development hereby permitted shall not be occupied unless and until a footpath/cyclepath route has been designed, laid out and constructed to base course level between Phase 1 and Bewbush. The footpath/cyclepath shall be completed to wearing course level and provided with street lighting prior to the occupation of the 50th

16  The development hereby permitted shall not be occupied unless and until it has been provided with a satisfactory means of access and car parking in accordance with a specification to be submitted and approved by the LPA.  The adoptable access roads serving the development hereby permitted shall not be constructed unless and until details of their design, layout and construction have been submitted to the LPA for approval.  No dwelling hereby permitted shall be occupied unless and until the access road to any occupied dwellings has been completed to base course level with the road construction to be completed within 12 months or to a later date to be agreed with the LPA.  Wheel washing equipment has been installed in a location to be approved by the LPA.  A comprehensive maintenance plan shall be submitted to the LPA clearly setting out future maintenance responsibilities for all areas of land within the development.  Full construction traffic management plan including routing for construction traffic from the A264 to each phase of the development.  Satisfactory parking arrangements in accordance with plans to be submitted and approved.  The proposed bus gate links from the development to Sullivan Drive and Woodcroft Road shall be designed, laid out and constructed in all respects to a specification (including safety audits) to be submitted to and agreed by the LPA.  Prior to the occupation of any dwelling, a Green Travel Plan shall be submitted for approval by the LPA setting out details of the proposed sustainable transport initiatives.

Summary of WSCC S106 requirements as set out in their consultation response:  Commuted sum for maintenance of highway planting/areas that do not form part of private plots  Continuous monitoring of Sullivan Drive junction after phase 4 and contribution for mitigation if needed.  Stage 1 improvements to Cheals roundabout prior to construction of 300th dwelling  Stage 2 improvements to Cheals roundabout or an alternative modified roundabout option.  Monitoring of internal road network and contribution for achievement of 20mph Zone or 20mph speed limit.  Subsidy and quality and frequency of shuttle bus service and reviewed as development progresses.  A264 roundabout access  A264 secondary access/Pegasus crossing prior to construction of 300th dwelling  Travel planning  Financial contributions towards pre-school, primary, secondary, sixth form education and youth (please see WSCC education p? for full comments)  Library facilities  Fire hydrants (Please note there may be other requirements in the WSCC S106)

Neighbours, 129 - 130 Comments received are summarised at the end of this document. residents of

17 neighbouring areas and other interested parties

CONSULTEE SUMMARY OF ALL FORMAL RESPONSES TO CONSULTATION OUTSIDE AGENCIES

Natural England 07/10/10  The application site is adjacent to House Copse Site of Special Scientific Interest (SSSI).  Natural England does not object to the proposed development subject to the proposals being carried out in strict accordance with the terms of the application and the submitted plans. Mitigation measures outlined in the application for the SSSI include the provision of formal and informal public space within the development proposals.  Natural England supports the proposed Woodland Management Plan and recommends that it be secured in a S106 Agreeement to provide long term security.  The proposal site is adjacent to High Weald AONB and has the potential to affect the natural beauty, setting, local character and distinctiveness of the AONB.  We welcome the inclusion of a visual and landscape character appraisal which has been based on good practice guidelines produced jointly by the Landscape Institute/ Institute of Environmental Assessment 2002. We are also please to see that views from the AONB have been considered and that additional planting has been proposed in certain locations to minimise impacts on the AONB. It is suggested that the AONB Unit is sent details of the proposal, if you have not done so already.  Woodland classified on the Ancient Woodland Inventory lies within the proposal boundaries. We are please to see that the proposals are in line with our standing advice on ancient woodland.  Natural England welcomes the inclusion of the Open Space Strategy for the proposals.  Subject to the proposal being carried out in strict accordance with the terms of the application and the submitted plans, Natural England has no objections to this proposal at present. Should there be any modification or amendment to the application, however, which may affect the SSSI, Natural England must be consulted further.

Environment Agency 17/09/10 We OBJECT to the proposal as submitted for the following two reasons and recommend that planning permission be refused:

18 1) The Flood Risk Assessment (FRA) submitted with this application does not provide a suitable basis for assessment to be made of the flood risks arising from the proposed development and therefore fails to comply with the requirements set out in Annex E, paragraph E3 of Planning Policy Statement 25 – “Development and Flood Risk” (PPS 25). This objection is necessary to ensure the development complies with the principles of PPS25 and Policy DC7 of the Horsham District Council Local Development Framework: General Development Control Policies (2007) 2) The development would have an adverse ecology impact on nature conservation such as: I. There are inadequate buffer zones to the Bewbush Brook and Hopper's Brook. II. The proposals involve the creation of an online pond to the Hopper’s Brook III. The loss of wetland habitats, ponds and ditches would have a detrimental impact on biodiversity and no mitigating factors or compensatory proposals have been included in the details.

22/11/10 We are in receipt of the Revitalised FSR/FEH rainfall runoff method Version 1.4 spreadsheet, drawing 16702/441/PA-12 Rev B ‘Phase 1 foul and surface water drainage’ and letter dated 8 November SLR reference 403-00404-00027. Our comments are based upon the information received.

The Environment Agency position: The Environment Agency is now in a position to remove our previous objection in relation to the proposal as submitted and would wish the following to be taken into consideration: The Environment Agency requests that the following twelve conditions be attached to any planning permission granted, and that details in relation to these conditions (and on which the Environment Agency would wish to comment) be submitted to and approved in writing by the Local Planning Authority (LPA). 1) The development permitted by this planning permission shall only be carried out in accordance with the approved Flood Risk Assessment (FRA) submitted with this application and the following mitigation measures detailed within the FRA: Finished floor levels should be set no lower than that identified within the approved FRA for phase one. 2) Development shall not begin until a surface water drainage scheme for the site, based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development, has been submitted to and approved in writing by the LPA. The scheme shall subsequently be implemented in accordance with the approved details before the development is completed. The scheme shall also include:  Full detailed design drawings and associated calculations.  A report demonstrating how the final drainage system is in accordance with the approved surface water drainage strategy/FRA for phase one.  Details of how the scheme (to include the operation of the structure for pond S2) shall be maintained and managed after completion.  Measures to mitigate any risk of pollution to the watercourses and groundwater.  Demonstration that there will be no discharge to ground that has been affected by contamination. 3) The development hereby permitted shall not be commenced until such time as a scheme for the surface water disposal from car parking areas, paths, roads, or any other impermeable surfaces and additional built footprint has been submitted to, and approved in writing by, the LPA. The scheme shall be implemented as approved. The scheme should include details of:  The installation of oil and petrol separators for parking areas of over 80 cars.  Demonstration that there will be no discharge to ground that has been affected by contamination.

19 4) Prior to each of the earthwork phases a surface water drainage scheme for the temporary drainage of the site shall be submitted to and approved in writing by the LPA. The scheme shall subsequently be implemented in accordance with the approved details before the development is completed. The scheme shall also include:  Demonstration that there will be no increase in the volume or rate of surface water runoff leaving the site for the duration of the earthworks and associated stabilisation period.  Measures to mitigate any increased risk of sediment entering the watercourses and groundwater.  Demonstration that there will be no discharge to ground that has been affected by contamination. 5) No development approved by this permission shall be commenced until a scheme to prevent pollution to the water environment for the disposal of foul water has been approved by and implemented to the reasonable satisfaction of the LPA. There shall be no discharge to land affected by contamination as this could mobilise contaminants to the aquifer. 6) Prior to the commencement of development, a working method statement to cover all channel / bank works (to include realignment or culverting) of any watercourses shall be submitted to and agreed in writing by the LPA. Thereafter the development shall be carried out in accordance with the approved scheme and any subsequent amendments shall be agreed in writing with the LPA. 7) The development hereby permitted shall not be commenced until such time as a scheme to ensure that there are no raising of ground levels within the one per cent annual probability (1 in 100 year) flood extent, taking into account a suitable allowance for the potential impacts of climate change has been submitted to, and approved in writing by, the Local Planning Authority. The scheme shall be fully implemented and subsequently maintained, in accordance with the timing / phasing arrangements embodied within the scheme, or within any other period as may subsequently be agreed, in writing, by the LPA. 8) Prior to the commencement of development a scheme for the provision and management of a buffer zone of at least 5 metres alongside the watercourses shall be submitted to and agreed in writing by the LPA. The buffer zone shall be clear of all buildings, structures, fences etc and hard standing, including formal footpaths and cycle paths. Thereafter the development shall be carried out in accordance with the approved scheme and any subsequent amendments shall be agreed in writing with the LPA. The scheme shall include:  Plans showing the extent and layout of the buffer zone.  Details of the planting scheme (for example, native species).  Details demonstrating how the buffer zone will be protected during development and managed/maintained over the longer term.  The exact locations and design, including widths and surface types, for all footpaths and cycle paths adjacent to watercourses. If any are within the 5 metre buffer zones we require details of what length and how close the paths are to the top of the watercourse bank.  The exact location of pinch points within the buffer zones and the justifications for these. 9) No development shall take place until a scheme for the provision and management of compensatory habitat creation has been submitted to and agreed in writing by the LPA and implemented as approved. Thereafter the development shall be implemented in accordance with the approved scheme. 10) Prior to the commencement of development, a detailed method statement for the removal or long-term management /eradication of Japanese Knotweed on the site shall be submitted to and approved in writing by the local planning authority. The method statement shall include proposed measures to prevent the spread of Japanese Knotweed during any operations such as mowing, strimming or soil movement. It shall also contain measures to ensure that any soils brought to the site are free of the seeds / root / stem of any invasive plant covered under the Wildlife and Countryside Act 1981. Development shall

20 11) Prior to the commencement of development approved by this planning permission (or such other date or stage in development as may be agreed in writing with the LPA), the following components of a scheme to deal with the risks associated with contamination of the site shall each be submitted to and approved, in writing, by the LPA . A preliminary risk assessment which has identified:  all previous uses  potential contaminants associated with those uses  a conceptual model of the site indicating sources, pathways and receptors  potentially unacceptable risks arising from contamination at the site.  A site investigation scheme, based on (1) to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site.  The site investigation results and the detailed risk assessment (2) and, based on these, an options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken.  A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in (3) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action.  Any changes to these components require the express consent of the LPA. 12) Piling or any other foundation designs using penetrative methods shall not be permitted other than with the express written consent of the LPA, which may be given for those parts of the site where it has been demonstrated that there is no resultant unacceptable risk to groundwater.

Planning Informatives The following consents/licences are separate to the requirement for planning permission and are required for both temporary and permanent works.

1) Under section 109 of the Water Resources Act 1991 and/or byelaws, any works or structures whatsoever, in, over, under or within 8 metres of a main river (including the erection of any flow control structures) require the prior written consent of the Environment Agency. 2) Under Section 23 of the Land Drainage Act 1991, if it is proposed to fill, divert, obstruct or culvert a watercourse (including the erection of any flow control structures or realignment), the applicant would require a Flood Defence Consent from the Environment Agency. 3) Under the Water Resources Act 1991, any impoundment of a watercourse to create ponds will require an impoundment licence from the Environment Agency. Any impoundment licence will be subject to a condition that ensures 'compensation flow' at all times. 4) We will require full design details and calculations for the proposed control structure (demonstrating no increase in either the volume or rate of surface water leaving the site and including any necessary provisions for a low flow bypass and/or fish bypass) to be submitted. The drawings for the design of the control structure for the attenuation feature (on-line pond), to clearly show how it will retain the ‘pond’ bed as close to a natural watercourse as possible will also be required.

Information/Advice for the LPA

21 1) We would wish to note that it is our expectation that an FRA will be provided with each core phase of the development in accordance with Local Policy WB16 of the Area Action Plan. 2) Surface water run-off should be controlled as near to its source as possible through a sustainable drainage approach to surface water management (SuDS). SuDS are an approach to managing surface water run-off which seeks to mimic natural drainage systems and retain water on or near the site as opposed to traditional drainage approaches which involve piping water off site as quickly as possible. SuDS involve a range of techniques including soakaways, infiltration trenches, permeable pavements, grassed swales, ponds and wetlands. SuDS offer significant advantages over conventional piped drainage systems in reducing flood risk by attenuating the rate and quantity of surface water run-off from a site, promoting groundwater recharge, and improving water quality and amenity. The variety of SuDS techniques available means that virtually any development should be able to include a scheme based around these principles. 3) Should the LPA decide to permit the proposed Pond S2 we will expect to see full design details and calculations for the final control structure (demonstrating no increase in either the volume or rate of surface water leaving the site and including any necessary provisions for a low flow bypass and/or fish bypass) within the details submitted for the discharge of the relevant surface water drainage condition. The adopting authority and / or freeholder of Pond S2 should ensure that they are satisfied as to whether the structure will be classified as a large reservoir under the upcoming amendment to the Reservoirs Act. 4) We note that table 15 identifies a minor increase in runoff rate for smaller storm events from ponds N2a and N2b. This should be revisited in due course at the detailed design stage. Sufficient information should be provided at that stage to demonstrate that there will be no increase, or that any increase will be negligible in the context of the flood risk of the whole final drainage scheme. We would advise that the outlet of the proposed culvert under the access road to the south of phase one should be realigned so that it is not at ninety degrees to the direction of flow within the culvert. The current alignment may reduce the hydraulic performance of this part of the watercourse and increase the likelihood of erosion of the bank. 5) Concerning the existing localised drainage issues to the north of the railway line, reference is made within the submitted details to potential groundwater / perched water / land drainage / overland flow issues to the north of the railway line. However, there is little specific information within the flood risk assessment on these matters. We would wish to advise that at an individual site level, such localised flood risk issues are outside of the remit and resource of the Environment Agency. As such the LPA may wish to request further details to demonstrate the development will adequately manage any such risks without detriment to others. Consideration should also be given as to whether the proposed re-contouring / ground raising of low points by the railway line would detrimentally impact on any of these issues. 6) To allow the free flow of floodwater within the floodplain, any new fencing or walls within the one per cent annual probability (1 in 100 year) flood extent, taking into account a suitable allowance for the potential impacts of climate change, should be of open construction to allow the movement of floodwater.

Additional Information Culverting - The Environment Agency resists culverting on nature conservation and other grounds and consent for such works will not normally be granted except for access crossings

Buffer zones - The buffer zone needs to be 5 metres wide measured from bank top for the whole extent of the site. Bank top is defined as the point at which the bank meets normal land levels. This zone should be without structures, hard standing, footpaths, fences or overhanging development such as balconies and should not include domestic gardens or formal landscaping. The buffer zone needs to be designed and managed to develop this natural character and planted with locally native shrubs and grasses, of UK genetic

22 provenance

Please note that Paragraph 6.2.4 of the Open Space Strategy states for the Bewbush Brook ‘…flanked on both sides by a formal footpath/cycleway…..’ ‘Formal’ suggests a hard surface and a minimum of 2m wide for bicycles. 3.5 metres is the recommended width for paths for combined walking, cycling, people pushing buggies and wheelchair users, which is not acceptable within 5 metres of the bank top, certainly not on both sides of the watercourse. Informal paths would be acceptable within the 5 metre buffer zones but not for the entire length of the watercourses. They must also be sufficient distance from the bank top to prevent undermining of the bank which could lead to the future need for hard bank protection.

Habitat Creation - We have reviewed the submitted table showing the areas of habitat creation for Phase one of the proposed development. Having compared these with areas of habitat loss in Table 10.12 of the Environmental Statement (ES), we are satisfied that the areas of wetland habitat creation will compensate for the wetland habitat loss and indeed will provide additional wetland habitat. Such enhancements are in line with Planning Policy Statement 9 – “Biodiversity and Geological Conservation.

Ponds - The Environment Agency is keen to encourage the construction of wildlife ponds, but only where the benefits of the pond creation outweighs any loss, so as to ensure a net gain in the ecological value of the site. On-line ponds are known to reduce the natural ecological diversity of the section of watercourse directly affected and indirectly affects downstream sections. Seasonal ponds dry out occasionally which means they are often overlooked, or assumed to be 'lost'. In fact the reverse is the case. They support a range of less common/rare species and it is important that they are retained, and not deepened. Seasonal drying out of the pond removes fish (which are a predator) and allows other species to thrive. Many temporary ponds support rare species such as Great Crested Newts, particularly where they occur in semi-natural landscapes

Water Stress - This development is located within an area of serious water stress due to limited water resources in the local area and high and growing demand for water. We therefore suggest the applicant investigates the use of water efficiency measures and aims to achieve 105 litres/head/day (l/h/d), equivalent to level 3/4 for water within the Code for Sustainable Homes.

Achieving a water efficiency standard of 105l/h/d within new homes can be accomplished at very little extra cost (under £125 extra per home) and typically only involves low/dual flush toilets, low flow/aerated taps and showerheads and efficient appliances (dishwasher and washing machines) and does not require more expensive rain or greywater technologies. Water savings made from hot water appliances can also contribute to reducing emissions by reducing the amount of energy required for heating water in the home. The Government’s ‘Water Calculator ‘provides information on how to achieve and assess water efficiency within new homes. BREEAM (BRE Environmental Assessment Method) is the leading and most widely used environmental assessment method for buildings. BREEAM credits are awarded for water where water efficient appliances (e.g. low flush toilets), water metering, leak detection systems and water butts are in place.

Pollution Prevention - When carrying out construction and demolition activities, potential sources of pollution from site activities will need to be identified so that appropriate pollution prevention measures are taken to avoid any contamination of controlled waters. Controlled waters include surface waters (bodies of water that are above ground, such as rivers, lakes, and streams) coastal waters and groundwater. It is necessary to prevent pollution of surface and/or groundwaters especially during site works. There should be no discharge of foul or contaminated drainage from the site into either groundwater or any surface waters whether direct or via

23 soakaways.during and after the proposed works. The risk of pollution at construction and demolition sites can be significantly reduced by providing secondary containment measures for storage tanks. Oil tanks must comply with the requirements of the Control of Pollution (England) (Oil Storage) Regulations 2001.

Landfill sites - Waste Management Paper No. 27 (2nd edition) discusses the difficulties associated with development within 250 metres of a landfill. Chapter 9 draws attention to the need for the developer to carry out an assessment to establish whether or not there is a risk from migrating landfill gas. If a risk is identified, then effective protection measures must be designed into the development. Former landfills are now more appropriately 'contaminated land' problems rather than waste problems, since they are no longer licensed, weren't licensed in the first place or any licence has been surrendered. They are therefore the responsibility of local authorities under Part 2A of EPA '90 or as local planning authority. There is therefore a potential risk of the presence of landfill gas.

Thames Water Waste Comments

Surface Water Drainage - With regard to surface water drainage it is the responsibility of a developer to make proper provision for drainage to ground, water courses or a suitable sewer. In respect of surface water it is recommended that the applicant should ensure that storm flows are attenuated or regulated into the receiving public network through on or off site storage. When it is proposed to connect to a combined public sewer, the site drainage should be separate and combined at the final manhole nearest the boundary. Connections are not permitted for the removal of Ground Water. Where the developer proposes to discharge to a public sewer, prior approval from Thames Water Developer Services will be required. They can be contacted on 0845 850 2777. Reason - to ensure that the surface water discharge from the site shall not be detrimental to the existing sewerage system.

A Trade Effluent Consent will be required for any Effluent discharge other than a 'Domestic Discharge'. Any discharge without this consent is illegal and may result in prosecution. (Domestic usage for example includes - toilets, showers, washbasins, baths and canteens). Typical Trade Effluent processes include: - Laundrette/Laundry, PCB manufacture, photographic/printing, food preparation, abattoir, farm wastes, vehicle washing, metal plating/finishing, cattle market wash down, chemical manufacture, treated cooling water and any other process which produces contaminated water. Pre-treatment, separate metering, sampling access etc, may be required before the Company can give its consent. Applications should be made to Waste Water Quality, Crossness STW, Belvedere Road, Abbeywood, London. SE2 9AQ. Telephone: 020 8507 4321.

Thames Water would recommend that petrol / oil interceptors be fitted in all car parking/washing/repair facilities. Failure to enforce the effective use of petrol / oil interceptors could result in oil-polluted discharges entering local watercourses.

Following initial investigation, Thames Water has identified an inability of the existing waste water infrastructure to accommodate the needs of this application. Should the Local Planning Authority look to approve the application, Thames Water would like the following 'Grampian Style' condition imposed. “Development shall not commence until a drainage strategy detailing any on and/or off site drainage works, has been submitted to and approved by, the local planning authority in consultation with the sewerage undertaker. No discharge of foul or surface water from the site shall be accepted into the public system until the drainage works referred to in the strategy have been completed”. Reason - The development may lead to sewage flooding; to ensure that sufficient capacity is made available to cope with the new development; and in order to avoid adverse environmental impact upon the community. Should the

24 Local Planning Authority consider the above recommendation is inappropriate or are unable to include it in the decision notice, it is important that the Local Planning Authority liaises with Thames Water Development Control Department (telephone 01923 898072) prior to the Planning Application approval.

Water Comments With regard to water supply, this comes within the area covered by the Southern Water PLC. For your information the address to write to is - Southern House, Yeoman Road, Worthing, West Sussex BN13 3NX Tel - (0845) 2780845

Supplementary Comments Thames Water propose to upgrade Crawley STW between 2010-2015 (AMP5) from the current population equivalent (PE) of 148 600 to circa 167 000 PE using growth forecasts outlined in the LDF Documentation for Crawley BC, Mid Sussex DC and Horsham DC. This upgrade should yield sufficient capacity until 2021.

If the proposed development forms part of the already published figures in LDF documentation up to 2021, then flows from the development could potentially be accommodated by Crawley works upgrade. However, if the development is in addition to the figures already forecasted, it would need to be assessed separately.

Available land at Crawley STW for wastewater treatment assets is restricted by the adjacent Gatwick Airport who is required to retain the land for any future airport expansion. Thames Water believes that following upgrades in AMP 5, further expansion on the site may not be possible with the available land. Alternative options will have to be considered such as, a change in treatment technology (to reduce the footprint) or a new/additional STW being constructed else where.

Thames Water propose to finalise the upgrade solution scope for growth up to 2021 (circa 167,000PE) and then initiate a study to determine what options are available and viable for post 2021 for wastewater treatment in the geographic area. If a new treatment works is required in the longer term, a period of 7 – 10 years would be required for planning, design and construction.

The network in Crawley is close to capacity. The inclusion of this site may offer the opportunity for a strategic solution to these network issues if a dedicated main for the development was laid other developments to the south of this site could potentially use this network reducing the amount of upgrades through the town centre. This would however require the development to crudely start in the NE of the site and radiate anti clock wise with development to the south of this site following on.

Thames Water does not reserve capacity, sewage treatment is not an exact science and factors such as weather, type of sewage and trade flows (inc. Gatwick Airport) can determine the performance of a STW therefore the above figure are provided as our best guide.

Network Rail 23/09/10 Network Rail is supportive of the application subject to DfT approval for the new station.

Development - Prior to the commencement of any works on site, developers must contact Network Rail to inform them of their

25 intention to commence works. This must be undertaken a minimum of 6 weeks prior to the proposed date of commencement.

Earthworks and Excavations - Prior to commencement of works, full details of excavations and earthworks to be carried out within 10 metres of the railway undertaker's boundary fence should be submitted for the approval of the Local Planning Authority acting in consultation with the railway undertaker and the works shall only be carried out in accordance with the approved details.

Drainage - No water or effluent should be discharged from the site or operations on the site into the railway undertaker's culverts or drains. Details of the proposed drainage must be submitted to, and approved by the local planning authority; acting in consultation with the railway undertaker and the works shall be carried out in accordance with the approved details.

Fencing - Children’s play areas, open spaces and amenity areas must be protected by a secure fence along the boundary of one of the following kinds, concrete post and panel, iron railings, steel palisade or such other fence approved by the Local Planning Authority acting in consultation with the railway undertaker to a minimum height of 2 metres and the fence shall not be able to be climbed.

Landscaping - Hedge planted adjacent to Network Rail’s boundary fencing for screening purposes should be so placed that when fully grown it does not damage the fencing or provide a means of scaling it. No hedge should prevent Network Rail from maintaining its boundary fencing. Network rail have provided a list of species which are permitted.

Noise and Vibration - The potential for any noise/ vibration impacts caused by the proximity between the proposed development and any existing railway must be assessed in the context of PPG24 and the local planning authority should use conditions as necessary.

29/09/2010 Network Rail confirmed that they would maintain their support if the railway station was not delivered.

Highways Agency 10/09/10 The HA’s interest is the potential impact of the proposed development on the operation of the M23 Junction 11.

Our transport consultants, Parsons Brinckerhoff (PB), have reviewed the Transport Assessment (TA) and Travel Plan (TP) submitted alongside the planning application and has made a number of comments regarding the assessment work undertaken. It is considered that further clarification and assessment work is required in certain areas before we can fully understand the impact that the development will have upon the SRN at M23 J11. Please find a technical note attached outlining our concerns and where we feel that additional information is required.

It is identified in the TA that the overall traffic demand in 2022 will exceed the capacity of M23 J11. A potential improvement scheme has been identified, although we have reservations about the TA’s assessment in that the scheme would not be required to be implemented until the end of Phase 3. In addition, we would require for the impact of the proposed development on the merge and diversion sections of the M23 J11 to be taken into consideration.

In order for discussions surrounding the full impact of the proposed development on the SRN and the timing of the proposed mitigation

26 measures to continue we are directing that planning permission not be to granted for a period of 8 weeks.

Comments on the TA  Chapter 1 paragraph 1.1.1. The number of homes in the full development has increased from 2,500 to 2,650.  Trip generation – The TA uses trip rates with 15% reductions for travel planning for the M23 J11 analyses in recognition of the HA’s previous concerns. The highway trip rates derived from assignments provided in the TA, figures 18 to 21, are consistent with previously accepted trip rates without travel planning which the HA consider acceptable.  Chapter 10 paragraph 10.1.4 multi modal assessments – It is stated that the 2022 WSCC model forecasts plus traffic generation from a list of developments have been used but there is no information on the growth assumptions used in the WSCC model, in particular those relating to longer distance and other traffic using M23 J11. Also tere is no mention of strategic housing sites currently being considered by Horsham DC; both the West of Ifield and North of Horsham sites could generate significant additional traffic on the A264 and at M23 J11. The Forecasting Report is referred to but is not included in the application.  Chapter 12 paragraph 12.6.7 junction 11 assessments 2006 baseline – The TRANSYT analysis (Appendix J of the TA) shows that some aopproaches to the junction are already at capacity.  Paragraph 12.6.9 – The TRANSYT analysis shows reductions in traffic compared with the 2006 baseline of 18% on the M23 north approach and 23% on the M23 south approach in the AM peak hour and 30% on the M23 north approach in the PM peak hour. These reductions are considered unrealistic and indicate inaccuracies in the traffic assignments used for the 2022 TRANSYT flows do not match the traffic assignments presented in Appendix M. Traffic on the Pease Pottage approach is shown to increase by 41% producing a RFC of 111% in the AM peak hour. These levels of overcapacity are unrealistic due to inadequate capacity modelling in J11 in the traffic assignment.  Paragraph 12.6.16 trip distribution – The TA estimates 27% of development departure traffic passes through M23 J11 in the 2022 AM peak hour. In the PM peak hour the ‘adjusted’ assignment shows 23% of development arrival traffic using junction compared with 16% before adjacent. The AM distribution and the adjusted PM distribution are acceptable to the HA.  Paragraph 12.6.16 M23 J11 assessment adjusted 2022 with development – The Traffic flows used for the TRANSYT analysis are the 2022 Baseline flows with development flows added so there is no reassignment to take account of capacity constraints with the additional traffic. The addition of the development flows compounds the problems discussed in the comments on paragraph 12.6.9 above. Overcapacity levels are higher and flows on the M23 north and south approaches in the AM peak hour and on the M23 north approach in the PM peak hour remain lower than in the 2006 baseline.  Paragraph 12.6.22 M23 J11 assessment criteria – It should be noted that the HA’s junction assessment criteria would apply as the roundabout is the responsibility of the HA.  M23 J11 onslips and offslips – It is noted that the impact of the development on he merge and diverge areas of the M23 J11 has not been considered.  Chapter 13 paragraph 13.4.1 timing of improvement of the M23 J11 – The conclusion that the improvement is not needed until the end of Phase 3 of the development (1,550 homes out of a total of 2,650 homes) is not accepted due to the concerns regarding the forecast traffic flows as discussed above. In addition, TRANSYT analysis is required to demonstrate that the existing junction would operate satisfactorily.  It is agreed that overall traffic demand will exceed the operating capacity of the M23 J11 roundabout in 2022 and under these circumstances the developer will be required to provide contributions to capacity improvements. This is recognised by the developer and the TA has assessed a potential improvement scheme. However, the HA is concerned about the accuracy of the 2022 traffic assignments at M23 J11 and consequently do not accept the scope and timing of the proposed improvements and

Comments on the travel plan  Chapter 1 paragraph 1.2.1 – The distance to the M23 J11 should be included within this site description.  Paragraph 1.3.2 – It is not clear from this paragraph at which point the travel plan will be implemented; this should be clarified.  Chapter 2 paragraph 2.2.5 – The section of PPG13 that is referred to in this paragraph should be identified.  Paragraph 2.3.13 – In terms of the degree of subsidy identified within this paragraph, has any consideration been given as to how much this might be? It should also be confirmed as to whether any discussions have taken place with operators regarding any service extensions into the development.  Chapter 7 table 12 – The HA feels that more detail is needed on the pedestrian and cyclist infrastructure to be provided including the number of cycle parking spaces and the highways safety and traffic calming measures. It addition to this does the footnote for this table indicate that bus service diversion has not been agreed with the bus service operators. If this is the case then consideration must be given to an alternative course of action.  Paagraph 7.28 – The HA wishes to know if any sanctions have been identified should the targets not be met.  Chapter 8 – No implementation plan has been included in this chapter; this should be addressed.  Chapter 9 paragraph 9.2.2 – The HA is concerned that the TP has only been identified as having a 10 year period as it believes that the TP should be permanent.  Paragraph 9.2.3 – This paragraph does not clarify when the baseline data collection will take place.  Paragraph 9.3.7 – The HA wishes to see a more detailed explanation of why the travel survey will take place over the period identified in table 14.  Paragraph 9.4.1 – The HA recommends that some monitoring should be undertaken every year in order to ensure the progress of the TP is appropriately monitored.  Chapter 10 paragraph 10.2 – The HA feels that the measures detailed in this section could be incorporated into table 12 rather than be listed as supplementary enforcement measures.

Summary As this technical note identifies there are a number of areas within both reports that require further work to address the issues we have raised.

04/11/10 I refer to the HA’s letter 10/09 setting out our comments on the TA and TO submitted in support of the Kinwood Vale planning application. Since then further discussions, clarifications and assessment work has taken place and the applicant’s transport consultants have provided further reports. We have reviewed these responses in relation to our earlier concerns as set in the technical note accompanying letter.

 Revised traffic forecasting has confirmed that overall traffic demand in 2022 will exceed the capacity of M23 J11 and a full signalised and improvements scheme will be required to accommodate all future traffic growth.  The potential improvement scheme of widening and signalisation of the A264 approach would be adequate to accommodate development traffic and would need to be in place by the end of Phase 2 of the development planned for 2017.

28  The merge/diverge analysis at M23 junction has shown that the existing layouts will be adequate for future traffic demand with the development. Other issues have been clarified and resolved.  The West of Bewbush Joint Area Action Plan envisages that an improvement to J11 of M23 will be carried out and that this will provide sufficient capacity to accommodate traffic from development in the surrounding area. The improvement would be funded by contributions from that development. The current planning application represents the first part of that development to come forward for approval.  From the HA’s point of view, in order to implement the improvement, it will be necessary to agree a design at outline stage to the satisfaction of the HA acting for the Secretary of State in respect of the M23/A23 and the junction roundabout and of WSCC in respect of Road Safety Audits and any departures from our design standards to be satisfactorily concluded.  As the majority of the improvement is on the Strategic Road Network we would expect to construct the works.  It will be necessary to identify a purseholder to enter into an agreement with the Secretary of State under Section 278 of the Highways Act for the construction of the improvement scheme. The purseholder will need to pay all costs in delivering the scheme, including a commuted sum for maintenance, and will need to forward fund any temporary or permanent shortfall between payments to us and receipt of contributions from developers.  Once there is a reasonable prospect of the proposed improvement to J11 being delivered, both in terms of an agreed outline design and an agreed delivery method, we would expect to direct a ‘Grampian’ condition requiring that the junction improvement or particular elements of it should be completed before stated quantums of development can be occupied. The details of this require further discussion with the applicant. In this respect we are unable to accept the proposal from the applicant of payment of a sum of money without any relationship between delivery of the development and delivery of the works. Until a reasonable prospect of delivery necessary mitigation is demonstrated, we would anticipate maintaining a ‘holding’ direction on the current application.

Comments on the TA 02/11/10  Chapter 1 Introduction - It was noted that the number of homes in the full development has increased from 2,500 to 2,650 (TA para. 1.1.1). The response report (para. 2.1.1) explains that the planning application is for 2,500 residential units. The Environmental Statement assesses 2,650 units to provide flexibility, if other uses are not delivered (e.g. the employment or third form entry of the school), and confirms that any increase in residential units from 2500 would be subject to a further planning application.  Chapter 10 Multi Modal Assessment - There was concern about the lack of information on the growth assumptions used for the 2022 WSCC model forecasts (TA para. 10.1.4). The response report (para. 3.1.1) refers to Technical Note 11 which details the way TEMPRO and trip generation from committed local development sites have been used in demand forecasting. It is accepted that this provides detail on growth forecasts but it seems a single TEMPRO growth factor is used for West Sussex and to the west of Crawley only the Kilnwood Vale development is modelled explicitly.  Consequently there is still concern that the strategic housing sites currently being considered by Horsham DC at West of Ifield and North of Horsham sites could generate significant additional traffic on the A264 and at M23 Junction 11 than that forecast in the TA.  Chapter 12 Detailed Junction Assessments - Because of reassignment in the WSCC model that resulted in reduced future traffic on the M23 it was agreed to use the existing count data with TEMPRO growth plus development traffic in assessing J11. The revised traffic forecasts are described in the response report (para. 4.1.1 to 4.1.4) and resulted in more realistic 2022 traffic flows. TRANSYT analysis shows the existing J11 to be overcapacity in 2022 both with and without the development

29  Developers are required to provide mitigation to ensure conditions on the strategic road network will be no worse with the development than if it had not taken place (DfT Circular 02/2007 applies).  It is agreed that the proposed widening and signalisation of the A264 approach to J11 will be adequate for 2022 traffic flows with full development. The response report provides an assessment of the impact of the development on the mainline merge and diverge areas at M23 J11 (section 4.3) and concludes that the existing layouts are adequate for 2022 traffic levels with the proposed development. This assessment is accepted.  The TA conclusion (section 13.4) that the improvement M23 Junction 11 would not be needed until the end of Phase 3 of the development (1,550 homes out of a total of 2,650 homes) was not accepted due to the concerns regarding the forecast traffic flows and the lack of junction assessment information.  The response report (section 5.1) now suggests that improvement would not be needed until the end of Phase 2 of the development (800 homes out of a total of 2,650 homes plus retail store).  Using the agreed revised traffic forecasting method TRANSYT analysis shows that without development the A264 and Pease Pottage approaches at the existing J11 would be overcapacity in the AM peak hour in 2017 and the A23 Brighton Road and Pease Pottage approaches would be overcapacity in the PM peak hour. The Phase 2 development would increase overcapacity on the A264 approach in the AM peak hour, increasing average queue lengths from 80 pcu to 128 pcu.  The widening and signalisation of the A264 approach would remove the overcapacity and excessive queuing on the A264. It is agreed the proposal to carry out the signalisation at the beginning of Phase 2 (350 houses) and the widening at the end of Phase 2 (800 houses) would provide sufficient mitigation.  The response report questions the agreed forecasting method (para. 5.1.5 to 5.1.9) pointing out the anomaly of 2022 baseline flows on the A264 approach being lower than the 2017 baseline flows due to the method of subtracting development traffic from forecasts with TEMPRO growth. The suggestion to reduce 2017 baseline flows to 2022 levels is not accepted because A264 flows in the AM peak hour would be 1468 pcu/hr which is less than the 1492 pcu/hr in the 2006 base. It is considered reasonable to assume some traffic growth in the 11 year period 2006 to 2017 and the 2017 baseline forecast of 1576 pcu/hr on the A264 represents modest growth and the minimum that would be expected.  The response report suggests (para. 5.1.10) that the A264 approach would not exceed capacity as traffic would divert to other routes. There is no supporting analysis, such as the identification of other routes and the impact on other key junctions such as M23 J10, and this approach would require the TA to be revised due to the different method of assignment of development traffic. Up to now the distributions of development traffic, which have been agreed, have been used to estimate traffic demand at J11 as it is the impact and mitigation of traffic demand that is required for the assessment of J11.  The response report states there has been a reduction in traffic on the A264 between 2005/6 and 2009 which will accommodate Phase 2 development traffic (para. 5.1.11). The traffic reduction was identified from ATC data but the location is not given and it is clearly not on the immediate approach to J11 as the summary provided to PB shows eastbound traffic flow of 1942 veh/hr in the AM peak hour in 2005/6 compared with 1492 pcu/hr on the A246 approach from the 2005 traffic count as J11. HA TRADS ATC data for J11 supplied to PBA shows more than 6% increase in traffic on the northbound onslip in the AM peak hour for comparable2005 and 2009 data which supports the view that the AM peak hour reduction on the A264 does not apply to the J11 approach. It is noted that PBA accepted that the J11 ATC data showed no overall growth between 2005 and 2009 and this assumption was used in the TRANSYT assessments.  The revised response report includes an additional section (5.2) that considers the phasing of the improvements to J11,

30  Full signalisation will be required in 2022 and the improvements on the A264 will only adequate the Kilnwood Vale development. The Transyts for the A264 signalisation and widening in 2017 (Appendix H) show acceptable operating conditions on the A264 and M23 northbound offslip approaches. Operating conditions on the other approaches are not significantly worsened by the development. However the Transyts for the A264 signalisation only in 2017 (Appendix I) show over capacity conditions on the A264 and M23 northbound offslip approaches. This demonstrates the need for both signalisation and widening on the A264 approach by the end of Phase 2 of the development.  Given the present high RFC on the A264 approach signalisation would be required at the beginning of Phase 2. On the basis of the above analysis it is considered that there has been no traffic growth at J11 between 2005 and 2009, there will be limited growth to 2017 producing overcapacity demand which would be worsened by the Phase 2 development traffic. The Phase 2 development will increase congestion and it is agreed that the proposal (para. 7.1.1) to carry out the signalisation at the beginning of Phase 2 (350 houses) and the widening at the end of Phase 2 (800 houses) would provide sufficient mitigation. Full signalisation of J11 will be sought by 2022 with funding from other developments.

TRAVEL PLAN  Chapter 1 Introduction - It is agreed that the distance to the M23 J11 will be included within this site description (response report para. 6.2.1). It is agreed that the travel plan will be implemented before the first residential occupation (response report para. 6.2.1).  Chapter 2 National and Local Policy - It is accepted that PPG13 is being summarised (response report para. 6.3.1). Service extensions into the development will be subsidised for 5 years (response report para.6.3.2).  Chapter 7 Measures. The information provided (response report para. 6.4.1 to 6.4.5) answers the comments on pedestrian and cyclist infrastructure, cycle parking spaces and the highways safety and traffic calming measures, bus service diversions and sanctions.  Chapter 8 Implementation Plan. It is accepted that the implementation plan is included in Table 13 (response report para.6.5.1).  Chapter 9 Management and Monitoring. It is noted that Crest will be responsible for the TP for ten years but it is intended that the TP will continue after (response report para. 6.6.1). The survey proposals have been clarified (response report para. 6.6.2 to 6.6.4).  Chapter 10 Supplementary Enforcement Measures - Clarification has been provided (response report para. 6.7.1).  SUMMARY - All previous comments have been answered or addressed by identified changes to the Transport Assessment and Travel Plan included in the response report.

The Highways Agency has imposed a number of holding objections on the application. The latest of which is to the 24th March “to allow additional time for the applicant to provide supplementary information requested to enable the secretary to come to a view.”

28/02/2011

31  Our view and experience is that it is perfectly proper and lawful to use a Grampian condition to require off-site works that can only be delivered by a third party. And this has been the HA's practice for a number of years.  In our view a S278 agreement is not an alternative to a condition, for example the condition applies to the land whereas the S278 applies to the developer. We do not see any need for a S278 agreement to be entered into before planning permission can be granted.  However a key element of the use of a Grampian condition is that there must be a reasonable prospect of the works being delivered. To this end we are currently reviewing the developer's proposals against our design standards and Safety Audit procedures. We are approaching the end of this process and I am hopeful that we will soon be able to remove our holding direction, and instead direct conditions to be imposed on any planning permission.  Please note that the Highways Agency has the legal personality of the Secretary of State. Therefore we are not permitted in law to be a party to a Section 106 agreement.

Sussex Police The location falls within an average crime risk area when compared with the rest of Sussex and I do not identify any major concerns with the proposal. I was particularly pleased to note the design and Access Statement submitted in support of the application gave mention of the seven attributes of safer places whose principles are to be incorporated into the design and layout of the development. Guidance on Information Requirements and Validation (CLG 2010), Section 6, Paragraph 132, states, “PPS1 makes clear that a key objective for new developments should be that they create safe and accessible environments where crime and disorder or fear of crime does not undermine quality of life or community cohesion. Design and access statements for outline and detailed applications should therefore demonstrate how crime prevention measures have been considered in the design of the proposal and how the design reflects the attributes of safe, sustainable places set out in Safer Places – The Planning System and Crime Prevention”.

The road layout in the main is direct, providing visually open and well used roads which in turn creates natural surveillance. However parking has been accommodated in small parking courts throughout the development to achieve this. It is important that if these parking courts are to be implemented, they must have natural surveillance from pedestrian footfall, surveillance from active rooms within dwellings and be well illuminated. Several of these have been gated which is commendable, however Secured By Design guidance discourages parking courts. See chapter 16.3 SBD New Homes 2010 document, SBD website.

It is important that the boundary between public space and private areas are clearly indicated. It is desirable for dwelling frontages to be open to view, so walls fences and hedges will need to be kept low or alternatively feature a combination (max height 1m) of wall, railings or timber picket fence. Vulnerable areas such as side and rear gardens need more and robust defensive barriers by using walls or fencing to a minimum height of 1.8metres. In the case of the houses at the centre of the development in particular, the alleyways to these rear gardens require a more open feature, 1.5m close board fencing topped by 300mm of trellis. This achieves both the requirements of security and observation. Gates that provide access to the side of the dwelling or rear access to the gardens must be robustly constructed of timber, be the same height as the fence and be lockable. Such gates must be located on or as near to the front of the building line as possible. Consideration to be given to wooden palisade constructed gates that give observation in both directions.

It is important to avoid the creation of windowless elevations and blank walls adjacent to space to which the public have access. These can have the effect of attracting graffiti and inappropriate loitering. An addition of a first floor window or a buffer zone can

32 assist in reducing these concerns. Buffer zones can take the form of railings or defensible planting or a combination of both, i.e. the railing to indicate the private space and the planting to prevent direct access, this is also very affective on vulnerable windows. The boundaries of the flats in this development would benefit greatly from 1m defensible railings and the vulnerable windows from defensible planting. Demarcation lines indicating the change from public to private space can take the form of coloured block paving, a change of material through to a physical barrier. The mandatory physical security requirements under the SBD Scheme are:-  All final exit doors should conform to PAS 024 and any glazing, including sidelights, to be laminated, any outward opening doors would benefit from hinge bolts. I will require to see a copy of the Manufacturers SBD licence and a copy of the product test certificate  Main communal entrance doors should conform to LPS 1175 SR2, be subject to access control with any trades buttons being coded and not timed. There should be an audio link with electronic release from the apartments. An audio/visual link is required if ten or more households share a communal entrance.  The individual apartment entry doors should also conform to PAS 024 and be fitted with viewers and chains and where appropriate have letter aperture deflectors fitted.  All ground floor and accessible windows must accord with BS7950 be laminated and if openers, have restrictors fitted. Again I will need to see a copy of the manufacturers SBD certificate and a copy of the product test certificate. Finally, lighting will be an important consideration, both in the car parking areas, around the buildings and communal areas. Advice on lighting levels and requirements can be found within the SBD New Homes 2010 Document.

Countryside Access  The Design and Access Statement submitted with this application contains a range of good proposals for “green infrastructure” Forum for West and “green corridors” which will enhance the quality of life of both existing and new residents in the area. Sussex and the  The Society regrets that the multi-use circular strategic spine route originally proposed is no longer included. British Horse Society  The West Sussex Countryside Access Forum through its Rights of Way Improvement Plan (RoWIP) seeks to secure an improved network of routes for all users, and new developments provide opportunities to achieve the goals set out in the RoWIP. This is an area where roads are busy and dangerous for vulnerable users with few safe off-road routes.  The National Equine Database of horses with passports by postcode proposed in 2009 shows 562 horses with passports in the surrounding area of the development (Rusper, Ifield, Bewbush, Langley Green and Colgate). Horses are exercised daily for health and fitness.  The Society welcomes the provision of safe crossing points at the railway line and the A264 (the 1550 bridleway).  This will provide a sustainable route to Buchan Country Park and the AONB to the south.  Given the recreational importance of this route a grade separation at the A264 should have been sought for walkers, cyclists and equestrians.  User groups must be consulted on the design of the eastern bridge.  The new links at the railway line and the A264 should be dedicated as public rights of way.  Clarification should be sought as to whether Network Rail would seek closure of the level crossing. If this is the case the bridleways will need to be legally diverted.  A new link is needed on the southern side of the A264 going east with links to the existing bridleway.  Equestrians along with all other users prefer circular routes. Consequently it is inevitable that they will use the estate roads and

33  The access link to the bridleway in the north west corner needs to be multi-use as agreed by the Inspector.

Gatwick Airport 01/10/10 Full - Phase One Amendments are required to the landscaping scheme for phase 1. Conditions are required regarding a bird management plan, cranes and lighting.

Outline - Phases 2 – 5  The proposed development has been examined from an aerodrome safeguarding perspective and could conflict with safeguarding criteria unless any planning permission granted is subject to the conditions detailed below:  Height Limitation on Buildings and Structures: No buildings or structures associated with the development hereby permitted shall exceed the heights as shown on the plan accompanying our comments in metres Above Ordnance Datum AOD. Reason: Development exceeding this height would penetrate the Obstacle Limitation Surface (OLS) surrounding Gatwick Airport and endanger aircraft movements and the safe operation of the aerodrome.  See Advice Note 1 ‘Safeguarding an Overview’. On Figure 2.13 the ‘Building Heights Parameter Plan’ as contained in Chapter Two of the Environmental Statement, it shows proposed heights Above Ordnance Datum (AOD), I believe that the only details to be considered at this stage are for the access to the site and therefore these heights are only indicative. The AOD levels in the Northern part of the site will infringe our Obstacle Limitation Surfaces for the Proposed Second Runway and would request that any buildings and structures proposed be kept beneath the AOD levels as shown on the attached plan.  No development shall take place until full details of soft and water landscaping works have been submitted to and approved in writing by the Local Planning Authority, details must comply with Advice Note 3, ‘Potential Bird Hazards from Amenity Landscaping & Building Design.  For Information: For a site in this location we would wish to see less than 25% berry/fruit bearing species and would want to see that 25% dispersed throughout the planting palette so that large pockets of exploitable habitat are not formed. With regard to Oak and Scots Pine species, we would wish to see those species kept to a minimum and dispersed throughout the site, as they provide extensive areas of tall woodland canopies which are attractive to arboreal species.  All landscaping works including details of SUDS shall be carried out in accordance with the approved scheme. No alterations to the approved landscaping scheme are to take place unless submitted to and approved in writing by the Local Planning Authority.  The development is close to the aerodrome and/or aircraft taking off from or landing at the aerodrome. Lighting schemes required during construction and for the completed development shall be of a flat glass, full cut off design, mounted horizontally, and shall ensure that there is no light spill above the horizontal.  Your attention is drawn to the Air Navigation Order 2005, Article 135, which states that, "A person shall not exhibit in the United Kingdom any light which: (a) by reason of its glare is liable to endanger aircraft taking off or landing at an aerodrome; or (b) by reason of its liability to be mistaken for an aeronautical ground light is liable to endanger aircraft." The Order also grants the Civil Aviation Authority power to serve notice to extinguish or screen any such light which may endanger aircraft. Further information can be found Advice Note 2 ‘Lighting Near Aerodromes’  Development shall not commence until details of the Sustainable Urban Drainage Schemes (SUDS) have been submitted to and approved in writing by the Local Planning Authority. Details must comply with Advice Note 6 ‘Potential Bird Hazards from

We would also make the following observation: Cranes - Given the nature of the proposed development it is possible that a crane may be required during its construction. We would, therefore, draw the applicant’s attention to the requirement within the British Standard Code of Practice for the safe use of Cranes, for crane operators to consult the aerodrome before erecting a crane in close proximity to an aerodrome. This is explained further in Advice Note 4, ‘Cranes and Other Construction Issues’ As this part of the application is for Outline approval, it is important that Gatwick Airport Limited is consulted on all Reserved Matters relating to siting and design, external appearance and landscaping. We, therefore, have no aerodrome safeguarding objection to this proposal, provided that a revised landscaping scheme is received in line with our comments above and is forwarded to us for our comments and that the above mentioned conditions are applied to any planning permission.

18/02/2011 In our letter dated 01 October 2009, we requested that some amendments be made to the proposed landscaping for Phase One before this part of the application is approved as follows: Berry/Fruit Bearing Percentages We requested that the amount of berry/fruit bearing species be reduced to around 20%. This has now been achieved by removing the hedgerow species from the equation as we have assurances in the letter from James Brewer of Messrs SLR Consulting dated 11 January 2010, that the hedgerow species will be clipped annually to reduce berry bearing. We would also ask that the annual clipping of the hedgerows be included in the landscape maintenance plan. Oak & Scots Pine Species We requested that the amount of Oak and Scots Pine that are proposed be reduced by 20%, this has now been confirmed in the letter dated 11 January 2010 from James Brewer. Now that the above amendments have been confirmed, the proposed Phase One development has been examined from an aerodrome safeguarding perspective and could conflict with safeguarding criteria unless any planning permission granted is subject to the conditions which require the following:  Bird Management Plan  Cranes - British Standard Code of Practice for the safe use of cranes  Lighting - carefully design lighting proposals

Please Note: This response only refers to Phase One the detailed part of the application, our response with regard to the height limitation for the remaining phases under the outline part of the application is still under discussion. It is important that the condition requested in this response is applied to a planning approval. Where a Local Planning Authority proposes to grant permission against the advice of Gatwick Airport Limited, or not to attach conditions which Gatwick Airport Limited has advised, it shall notify Gatwick Airport Limited, and the Civil Aviation Authority as specified in the Town & Country Planning (Safeguarded Aerodromes, Technical Sites and Military Explosive Storage Areas) Direction 2002.

23/02/2011 Gatwick have received an email from the developer suggesting a condition with regard to the height of the buildings on the area that we are concerned with. It has been suggested that the area be restricted to houses no higher than 8.5m across that part of the site. However this will still leave an area of infringement, so we are unable to agree to this.

High Wealds AONB The development is adjacent to the High Weald AONB boundary which runs from the A264. The development may therefore affect the Unit setting of the AONB. The Unit is pleased to see the work undertaken by SLR Consulting regarding the buffer and screening along the A264, and the details provided by them. These measures to mitigate potential impacts on the edge of the AONB are welcomed and will help to manage any impacts on the setting. Given the extensive mature woodland on this boundary edge and the hard edge represented by the A264, and the mitigation works detailed, the affects of the development on the setting of the AONB are unlikely to be significant at a landscape scale.

National Cycling  We are pleased to see that the submitted plans incorporate the majority of our suggestions/comments. Organisation  The most important feature of this development is to ensure that the Pegasus crossing across the A264 is implemented together with speed limit reductions.  The speed limit in the neighbourhood should be limited to a maximum of 20 mph on all roads. 1.  It is good to see that Cycle-ways have been incorporated in to the design. It is important that the cycle paths along the ‘main foot/cycle spine’ should be off carriageway along both sides of the routes and with continuous priority over intersections using raised beds. This should apply to the route from the bus entry point on the A264 and from the roundabout.  Cycle connections to the east of the site into Ifield West and Bewbush should include paths across the existing bridleway to the road network. At present they are missing in Bewbush and poor in Ifield West (although there is a current scheme to improve this). Full advantage should be taken of the Crawley/Horsham leisure route along the bridleway.  Proper signing should be provided for all cycle routes to include NCR228, Crawley town centre, Manor Royal, Horsham and NCN20 and 21. CTC are willing and able to assist with this work if requested. We have done this for other signing schemes across Crawley.  The default speed limit across Kilnwood Vale should be a maximum of 20 mph and this should be encouraged by ‘built-in’ street calming, particularly on the main car routes. There are several long ‘straights’ and these will encourage speeding by car drivers. These routes should have curves and blind corners to slow motorists ‘naturally’. 5. Clearly all cycle-ways, shared use paths etc should comply with the standards in DfT LTN2/08.

PARISH/ NEIGHBOURHOOD COUNCILS

Colgate Parish 17/09/10 Council  Roads - Single access point onto the A264. Even based on 1000 cars attempting to exit the development based on 1 car every 10 seconds would require a lapsed time of 3 hours to get cars out of the development. If time per car leaving was 15 seconds (which is not unrealistic) it would take 4 hours to get out.  Schools - Whilst provision has been made for younger children’s education within Kilnwood Vale, no provision has been made for any kind of senior school. This would mean children would need to be driven to school or school buses provided. Either way this will increase traffic and who will finance the school buses. Can the local senior schools absorb such an increase in headcount as they are over subscribed now? This may result in the children having to travel further afield to go to school. How does this fit with the carbon footprint policy of the Council?

36  Development boundary - How do we ensure the boundary between Kilnwood Vale and Faygate is maintained? Additional requirements to get planning permission such as hospitals, waste incineration plants would be forced to the west of the development, reducing the gap and getting us closer to the dreaded “Crawsham” that nobody wants.  Railway station - With the population of Faygate due to double because of Durrant Village, the demand on Faygate railway station will increase not only for travel to Horsham but also to London. Plans to close this station as part of a Parkway strategy within Kilnwood Vale would have a direct impact on the Faygate population. People in Faygate commute to London now. If there is no ability to commute you reduce the number of future potential buyers who would want to buy in the village. This could have a direct impact on local house prices and subsequently on the quality of life of the village.  Environmental issues - How is sewage, gas etc. going to come into and leave Kilnwood Vale, and can the local sewage works cope with the additional strain on the infrastructure?  Policing - How will Horsham Police cope with the additional burden of policing the development? With PCSO resources already stretched what impact would the development have on the services already received by Faygate and Colgate.  Low cost housing - How much low cost housing will be made available? What % of low cost housing will be allocated to Horsham to help meet its targets?  Gypsy site - If a new development is being incorporated and we have an obligation to provide traveller sites could one be incorporated within the development plan?

Notes of Parish/Officer meeting which Colgate Parish have asked to be included as part of their formal comments 20/10/2010  Roads - Plan shows main artery and secondary road. Highway Agency is guided by the Area Action Plan 2009 and the model trip generation. Peak times, morning 8am-9am) and evening (4pm to 5pm). Traffic lights are to be installed for the secondary exit. Projected 2600/2700 personal trips, numbers would consist not only of private cars, but would also include buses, cyclists and pedestrians. The Developers also use the model trip generation.  The Parish Council are Sceptical about the traffic model and would like more detail. Of the 2700 trips what is the split of cars within this? Looking at the traffic at maiden bower where a development of a similar size with 3 exits it takes 40 minutes to get out it is unclear how the road system for this development is going to work  Schools - It was stated that there is sufficient capacity in existing Senior Schools. Could children from Roffey and neighbouring parishes attend the new schools?  Development Boundary - Nothing proposed outside/beyond the boundary as now indicated. The Parish Council would like some level of assurance that the development boundary will be strictly enforced.  Railway Station - Car park proposed adjacent to station for over 200 cars. This development would mean a larger station with longer trains. Faygate Station closure could result in a possible mini-bus running between Faygate and Kilnwood Station. With this development, Network Rail would be able to use the Thames Link, considered this would be a great advantage. Park and Ride could also be used from Faygate and Ifield. Will the park and ride run later to support the trains stopping later into the night to provide the added benefit expected by improved rail links? If this scheme is to work how late will the park and ride run? Is a 200 capacity car park spaces enough to cope if you shut Faygate and Ifield? With the development of Durrants village have the plans re the station taking into account the potential increase in passengers in the Faygate area?  Environmental Issues - All covered. Sewage would be treated at the Gatwick Works. OFWAT says no problems with regard to water, sewage etc. Other utilities say no problem. Can we have more detail about the supply of water? Has this development now tipped the balance for the requirement of a new reservoir in the area? Will these houses have the capability of waste water recycling?

37  Policing - It is expected that a boundary change would take place and this development would come under Crawley / Bewbush.  Low Cost Housing - First phase = 20%. District Valuer is engaged re costs. Normal level of social housing is expected. These houses will not all be together but staggered throughout the development. Attractive site therefore no difficulty finding developers to take on the building of social housing (RSL`s) and already have the process in hand. Can the appointed RSL also build the eight social housing in Faygate? Answer: No, outside the remit - two separate planning applications. What % of the low cost housing will be allocated to Horsham to help meet its targets as we have now lost the social housing at Durrants Village? Answer: 50/50 Crawley / Horsham  Gypsy Site - South East reduction in number of sites needed. No provision by local authorities - in a state of flux at the moment.  S106 - Does Colgate Parish benefit? Answer: No. All monies generated will be used within the development itself. A264 - no pedestrian bridge? Answer: contact County to find out current position with regard to S106 monies ear-marked for transport.

Rusper Parish Rusper Parish Council are particularly concerned with the road infrastructure and the potential for Rusper Parish to suffer with extra Council through traffic from the A24 and elsewhere, not just from this development but also taking into consideration other developments that are currently being discussed. Although we appreciate that other villages suffer similar problems we feel Rusper is unique in being between Horsham and both Gatwick Airport and Crawley Town.

HORSHAM DISTRICT COUNCIL

Housing Officer Housing Officers have examined the options set out in developers letter of 17 February, and would support Option 2. In terms of number of units (not an average of the averages for each phase), from the 5 phases 29.7% affordable housing (673 units) would be achieved and would rise to 30.7% (767 units) should the reserve land be delivered at 40% affordable housing.

The base guaranteed starting point of 70% shared ownership and 30% rented across the site with provision to increase the percentage of rented to shared ownership should grant be available is acceptable – however, it is noted that the letter urges the LA to ‘use all reasonable endeavours to achieve HCA grant at the start of each phase’. The input of Registered Providers is essential to securing funding and the applicant is urged to finalise an agreement with a Registered Provider in advance of the submission of a detailed application for each phase.

With the above proviso, Housing Officers feel that this is a reasonable affordable housing offer in the current climate, and is a result of comprehensive and rigorous negotiations between Horsham District Council, Crawley Borough Council and the applicant.

Arboricultural Officer Thank you for consulting me on the above application. You will recall I have provided reports previously in regard to the site as a whole (29th September 2009) and the proposed positioning of the CHP energy plant within Pondtail Shaw (6th November 2009). I comment as follows:

Overall scheme  In overall terms, I am satisfied that the scheme has been drawn up providing the highest degree of protection for the trees/woodlands of the highest value.  Of prime importance are the areas of Pondtail Shaw and Capon Grove, both of which have been recently designated as Ancient Woodland (AW). I have commented previously on the proposal to erect the CHP energy plant within this area, but, as found, the area in question, though within the Shaw, is not within the AW area, and I find the principle of its location acceptable.  However, I should point out at this stage that the assessment of the trees either side of the plant reaching 25m in height, and thereby screening it effectively, I question; at my visit on 22nd October 2009 I found the trees either side to reach 22m to the east and only 20m to the west, a considerable difference.  A greater level of detail for the CHP plant will be required at the reserve matters stage. However, a number of points in regard to this should be ‘cast in stone’ at this stage: That no part of the plant shall use any space to the north, west and east, in excess of the 90m depth and breadth originally put forward for the plant, and absolutely not in to the AW area to the north in any circumstance; That the ingress and egress of all services attendant to the plant is provided for solely on its southern flank, and that no underground services are provided elsewhere.  In terms of the AW parts of the woodland, some interaction between the development scheme and these two areas is inevitable, and though this is regrettable, and contrary to best practice, the matter appears to have been sensitively handled and kept to a minimum. Full details of the method of construction of hard surfaces and other structures in these areas will be required at the reserve matters stage.  You will be aware that a recent Inspector decision, adopted by Natural England, requires a 15m wide buffer around the perimeters of AW sites, and I note that, where possible, there is an intention to achieve this. However, I suggest that this should be affirmed by condition to ensure compliance during the following later stages of the development of the site.  I have noted the details of the management plan for the woodlands, which appears satisfactory. However, I remain unclear as to the future ownership of these areas, a point of critical importance. Have we a firm commitment as to the disposal of this land? The management plan will be undermined if this point is not firmly established.  I also note the proposals for public access through the wooded areas, which I have no issue with at this stage. Again, full details of construction will be required once full plans for this area are submitted.  A most important decision in regard to the long-term development of the site is the provision for suitable clearance between the peripheral development and the off-site woodland, most specifically to the north along Kilnwood Lane. Plans were submitted at the pre-application stage showing indicative sections in these areas illustrating the concept of retaining a 10m strip, allowing use as a pedestrian/cycle greenway, between the residential property boundaries and the woodland edge. I am content to deal with the nuts and bolts of this at the reserve matters stage, but feel that this should be enshrined within the initial consent, and am not convinced that it is; the Design and Access Statement (DAS) does not appear to be fully convincing on this.  As stated, in general the important trees or areas of trees on the site are respected and targeted for retention. However, I have a concern with the proposed loss of the small woodland clump W15, to the north of the site. Although the trees within are not especial in individual terms, collectively the clump has landscape amenity value, and I raise an objection to its removal. I do not see why it cannot be included within the scheme, and its loss puts the proposal in conflict with the JAAP.

39 Phase 1 development proposal.  The scheme will involve the removal of a number of trees; however, I am pleased to see that this has been kept to a minimum in the case of the more important specimens. The retention of the four large oaks in the south-western corner of the site, within the rather complicated site entry, is welcomed.  In terms of interaction between trees and buildings, I note only a very small number of areas where RPA’s of trees are invaded; at plots 272, 212/217, 144 and at 165. While no RPA invasion is the ultimate goal, the degree proposed is acceptable within a scheme of this size, and affects no tree of outstanding or particular merit.  I do not assess that any proposed residential property is likely to be inappropriately shaded by retained trees, which is satisfactory.  Clearly the scheme requires the severance of the hedgerows in places for access through to other parts of the site. However, the sites chosen do no result in particularly extensive tree loss, and appear well selected.

Summary I find that notwithstanding the unavoidable deleterious effect the scheme will have on the countryside overall, good efforts have been made to minimise tree loss and preserve those areas on the site designated as of particular merit. The first phase also takes good account of the existing tree stock, and appears satisfactory. Taken together, I feel that the proposals meet with the requirements of the JAAP. Subject to my comments above, I thereby raise a cautious NO OBJECTION to the proposals.

Landscape Architect Comments received 18/11/10 and additional comments made 12/01/11 are in italics which are made further to additional information submitted. The numbering should be cross-referenced with the additional information submitted by the applicants 17/12/10.

 In general terms the landscape aspects of the proposed development, including the conservation and enhancement of landscape features, creating a strong landscape character and identity, provision of multifunctional open spaces and green corridors, and maximising opportunities from water have been well conceived.  I recognise much thought has gone into the comprehensive open space strategy and the illustration of a distinctive high quality landscape design approach to a number of the key open spaces is welcomed.  However there are a number of fundamental issues that need to be addressed including ones relating to: o the consistency of information on the parameter plans, the regulating plan (part of the strategic design code) and on design and access statement plans; o to the retention of trees and woodlands; o and to the adequacy of some aspects of the ES.  There are also a range of other important issues where additional information, clarifications, amendments are needed in respect of the design principles in the DAS and the SDC to give confidence in the quality of design and/or to demonstrate that some proposals are actually deliverable. Amended plans where appropriate and a comprehensive supplementary statement (cross referenced to previously submitted docs and plans) are therefore needed before I can record no objection to any planning permission being granted.  I have also highlighted where the use of informatives associated with any permission may be appropriate and will advise subsequently on appropriate conditions, should other matters be satisfactorily resolved. My consultation response has been made taking full account of the JAAP landscape and other LDF core strategy and development control landscape policies.

Key issues relate to:

Outline information  Inappropriate removal of a visually prominent mature tree clump  Other protection and mitigation issues relating to woodlands and wooded hedgerows  Land Use Parameter Plan- developable area issues, protection of trees and woodlands, including effect on amount of development  Energy Centre- adequacy of max area allocated, Chimney stack and building roof height visual impacts  Building Heights plans – accuracy and consistency, localised height restriction issue on vista/panorama  Green space parameter plan- a green corridor is modelled for ES but not shown in the DAS or in phase !  ES– Ecology and Landscape and Visual Impact Assessment – what has been assessed and mitigation issues  Utilities Report- Need for services strategy for whole site/principles established  Sustainability report- sustainable landscape issues  DS statement – various issues eg in relation to the Knoll, The Gateway, the Neighbourhood centre- clarifications and further info needed  Open Space Strategy- resident decisions on future uses, character of spaces, management  Strategic Design code- approach on some issues in respect of public realm and landscape

Phase 2 and 3 Full Earthworks (Engineering Operations)  Additional cross/long sections needed  Concerns about landform on Bewbush boundary  The knoll

Phase 1 Full details  Green corridor edges  Green corridor boundary with reserve land/countryside  Additional cross/long sections needed  Green corridor not provided in accordance with the parameter plan  implementation  Landscape treatment around balancing ponds  Surfacing  Tree provision and sizes

Access, Noise Attenuation and Footpath details  Various Signage and lighting issues  Objection to curved walls  Green wall

41 Outline Information

Arboricultural Survey  Wood 15 – It is noted that this clump/ring of large mature trees, classified as category C, has been shown to be removed on relevant parameter or design and access plans. I object to its removal. LDF development control policy is to minimise the loss of trees. (Will Jones the tree officer supports this objection)  Whilst the ash trees within the clump have been stated in the report as being of poor quality, the oak and other trees are assessed as of fair quality and the trees anyway have a collective value as a prominent landscape feature. It is therefore questioned what the justification for removal of this mature tree clump is?  Its removal is also not currently recorded in the landscape and visual assessment  I would therefore expect the relevant parameter and DAS plans to be amended accordingly to show it retained, including a stand off root protection area.

1. The applicants have stated elsewhere there is flexibility within the density ranges to take account of localised reductions in development land so it has not been explained why this would particularly have an adverse impact on the residential requirements of the JAAP. Although individually the trees are not high quality specimens they have group value and the tree clump is a prominent landscape feature- therefore my objection is maintained. No plan evidence in any case has been submitted to demonstrate how many dwellings might be potentially lost.

Off site trees- The arboricultural survey does not cover off site trees in Crawley which are located in the emergency vehicle/bus corridors

2. This is principally a matter for Crawley – however it remains the fact that these trees have not been included in the arboricultural assessment- field survey information referred to as far as I am aware has not been submitted. Retention of existing trees and landscape enhancement of the Bus Gate areas will need to be secured by a detailed scheme required as part of the relevant legal agreement

ES Parameter Plans:  It is understood these plans are for the purposes of modelling the maximum parameters of the development for the purposes of the EIA, but the applicant envisages that the plans that would be listed in any decision notice would be those in the DAS. Given this is the approach it should be more clearly explained in the submitted written information.  The approach does give rise to concerns about the implications for subsequent reserve matters applications and statements of conformity with the ES if these parameter plans are not amended, where necessary, to reflect any agreed mitigation measures in the ES.

3. It is understood from the applicant’s response the DAS plans will be those that should be used for determination of the application. However we also would be approving the Environmental Statement as one of the submitted application documents, including its parameter plans. If the ES parameter plans are left un-amended and there is not effective cross referencing between the DAS and the ES it could potentially give some license/encouragement to apply for a greater amount/scale of development than shown in the DAS in the future, as part of reserve matters applications ( all be it the DAS plans themselves would need permission to be amended in

42 future to achieve this). The applicants should provide some examples of how their approach has been dealt with elsewhere in decision notices

Land Use Plan (Parameter Plan)  Residential development area- The land use parameter plan should be amended as it shows ‘’potential extent of residential’’ areas within the 15M Ancient woodland standoff for Capon Grove and in that for the copse immediately to the northwest, as well as in root protection areas and open space margins to the woodlands/wooded hedgerows. The only previously agreed exceptions to this is for the road bridge embankment and the gap between the above two woodlands.  It then seems questionable to have an ES parameter plan that shows a greater and unacceptable adverse impact ( which could otherwise be considered a reason for refusal) when compared to other submitted documents.  Whilst it is noted that the ‘potential residential’ category in the key is noted as ‘includes non strategic green spaces’ this is confusing in relation to/nor is it appropriate to cover the stand off areas around woodlands and green corridors. Therefore they should be shaded as being in the landscape and buffering category shown in the key.

3. Whilst the parameter plans have been stated as the maximum areas considered for environmental assessment purposes and the ES written ecology chapter includes a mitigation measure of 15m standoff zone, I remain very uneasy about the use of the term ‘’potential residential area’’ in the standoff area on the land use parameter plan.

If it is not envisaged that the 15m area is needed for development purposes in the future why is it necessary to carry out an environmental assessment on it in the first place? It is a constraint that should be treated the same as other constraints on the site which have excluded development from the start

There is a clear inconsistency between on the one hand a CHP max area being shown outside of a 15m stand off zone in one part of the site and other areas shaded as potential development area extending within the 15M zone. We have not had any response to make it clear the 15m standoff zone for development excludes not only built development but garden development as well. I would further note the potential residential development area also fully extends into the identified outline application root protection for the kilnwood Lane woodland boundary

 Energy Centre Area in Pondtail Shaw – Certainty is needed at this stage of the adequacy of this ‘ maximum’ area before it can be approved as part of the outline aspects of the development.  Whilst it is understood the developer is currently in negotiation with a provider for a CHP plant that would take up a much smaller area of land, we only have the submitted info to assess.  It is estimated the proposed area is approx 130m long by 75-90m deep. Given its max depth extends to approx 90m confirmation should be provided now, with an accompanying plan, that the ancient woodland 15m stand off has been respected in full.

4. I agree from checking the A! DAS plans the 15M stand off area in this location has been respected

 Evidence should be provided now that the max size of similar facilities elsewhere has been taken into account, allowing for the extent of building/s, car park/lorry turning areas, storage and landscape areas (bunding and planting), and any statutory

43  Also confirmation is needed that any power lines will be undergrounded and together with any underground heating pipes will follow the line of access roads throughout the site, not in woodland or green spaces (not covered in the utilities report). Will Jones the tree officer is in agreement with this.  A written statement and illustrative plan (diagram) is required as evidence so we can be sure there will be no risk of subsequent development pressure (when a reserve matters application comes forward) to extend the area further northwards into the ancient woodland stand off area or the ancient woodland itself .This is all the more important given the position of residential properties, spine road and balancing ponds nearest to the energy centre will be fixed in phase 1 now, so there would be no option to extend southwards.

No illustrative plan and written evidence has been submitted as requested. The applicant has stated that the area applied for is the worst case scenario and any additional area, if it became necessary, would require further ES assessment. However in the absence of the requested supporting evidence being provided now we could be faced with an application for unacceptable encroachment into the ancient woodland standoff area or the ancient woodland itself in the future, especially as built development for phase 1 will be fixed now. No information has been provided on any required safety distances from residential development. Decisions taken now could affect the deliverability of the CHP plant, unless reassurance can be provided on this. Confirmation however that all services will be underground is however welcomed.

 Possible bridge locations –.The key on the land use plan should identify that 2 road bridges and a footbridge (pedestrian and cycle link between the neighbourhood centre and development to the north), irrespective of whether a station is built, will be provided.  At present the plan could be interpreted as only showing 2 bridge locations. This needs to be consistent on all parameter and design and access plans and in the written documentation.

5. Reference is made to central, eastern and western bridges in the DAS supporting statement. However the location and type of bridges to be provided has not been labelled on DAS Movement plans. The ES parameter plans have also not been amended to show 3 possible bridge locations for assessment purposes. Suitable amendments should be provided.

 Developable Areas- Given the comments above about ancient woodland stand-off areas and other RPA woodland buffers we need reassurance that developable area modelling/calculations to determine the amount of houses applied for/ delivered (set out in the DAS) have taken account of this, and are based upon the land use plan in the DAS, rather than this parameter plan?  It is also questioned whether there has there been some factoring in of the effect on the total amount of housing numbers when potentially greater set back distances than 8m are necessary (to avoid future resident pressure for works to mature woodland trees), particularly in locations where woodlands, wooded hedgerows may shade gardens/reduce light to properties ? I note para 2.99 of the planning statement regarding the orientation of urban blocks and buildings to avoid day long shade which is welcomed.  Will Jones is satisfied this principle has been respected in terms of the submitted phase 1 development but this should be clearly stated in the ES and DAS so that future reserve matters applications, including potentially, those made by other developers follow this.

6. Noted the applicant has stated there is flexibility to deal with this within the DAS density ranges. An addition to ES tables 17.1 and 17.2 should be made to take account of this mitigation requirement

 When reserve matter submissions come forward we will seek road and built development configurations that avoid this wherever possible (informative needed) but nevertheless this could still be an influencing factor on the number of houses that can be delivered. In summary we do not want to find at a later date that there is undue pressure to allow development inappropriately close to woodlands and wooded hedgerows, because the agreed housing numbers cannot otherwise be achieved.

Building Heights and Building Heights AOD (Parameter Plans)  Energy Centre Chimney Stack- A major concern is that this could be up to 60m height.  This could have a significant adverse visual impact on views looking towards the AONB, and from other representative viewpoints in the area, as well as on views looking from/towards the strategic gap.  Any part of the chimney over approx 20 m in height may not be screened by the surrounding Pondtail woodland * and over approx 50m in height I would estimate has the potential to visually break the wooded skyline on the Kilnwood Lane ridge in some views.  Furthermore it may also appear visually to break the wooded skyline of the AONB when looking towards it.  At present this issue has not been adequately considered in the LVIA in the ES. It advises that the most prominent element of the energy centre will be the chimney but the visual impact will be minimised by the surrounding woodland. However I would question whether this assessment has assumed an up to 60M high chimney and to state the impact will be minimised cannot be justified.  I consider this is a fundamental issue of concern and I suggest two alternative courses of action: o Confirmation to be provided now of the exact height of the chimney required (hopefully much lower) and if it exceeds the height of the surrounding Pondtail woodland * a photomontage illustration be prepared from a viewpoint to be agreed with the LPA. This should demonstrate the visual impact of the chimney set against the massing of development (can be diagrammatically shown) on the Kilnwood hillside, with an assessment of the magnitude and significance of the change from the assessment viewpoints affected. o Assess the worst case scenario of 60m height with a photomontage illustration and assessment as above.  The Photomontage illustration for either of the above should also be supplemented by a north –south long section including the chimney and extending if necessary beyond the ridgelines. Furthermore an amended Zone of Theoretical Visibility (ZTV) may be needed depending on what height assumption was made.  In summary it should be recognised there is a risk that the adverse visual impact from the chimney could be such that it would warrant a landscape reason for refusal.

7. The EIA written assessment is inadequate in its explanation of the visual and landscape impact assessment of the chimney. I suspect a 60M high chimney will have a significant residual adverse landscape and visual impact, but we need additional information to fully assess this.

The applicants have simply stated in their response that no significant impact has been identified and no further explanation as to why

45 has been given. We have had no confirmation as promised by James Brewer of SLR that the ZTV of the proposed development is based upon a max 60m chimney, although there is reference elsewhere in the response to the ZTV being prepared on the basis of parameter plans. I suspect the ZTV may extend further beyond the kilnwood ridgeline than currently shown Photomontages, a cross section and amended ZTV is recommended. Consider seeking information under Regulation 19 EIA (detail of requirements to be provided)

The applicants own EIA Scoping Report stated that photomontages of the proposed development would be provided, so the lack of provision is not satisfactory

 I note in DAS 15.15 a number of sources of renewable energy are under consideration (other than CHP which I assume is the use with the chimney stack). What uses are these? and can they all be accommodated within the area allocated and what are there heights ?. Has the ES considered uses other than CHP?

No response has been provided to the above

 Energy Centre roof height- On the building heights plan this is up to 25M height but on the building heights AOD plan by my calculation this could be up to 31m height.  This is inconsistent and if the max height were to be built it would significantly exceed the height of the surrounding woodland.

8. No explanation has been provided in the response as to why the max height of the energy centre CHP plant assessed needs to be higher than what is proposed in the DAS

 Note the arboricultural survey has given a max height for the Pondtail woodland of 24m and a mean canopy height of 17.3m, and the HDC arboriculturalist considers the max height to be 20-22m, so this issue also needs to be ironed out for assessment purposes.

9. The response to this issue is poorly worded and unclear

 Development North of the railway and west of Capon Grove- In the area either side of the main axis- I cannot see how the up to 98M AOD areas on the AOD building heights plan ( purple shaded) are consistent with the up to 18m height ( 4.5 storey buildings) in the same area on the building heights plan. Eg if you have an up to 18m building on the 85m contour it gives you a height of up to 103M AOD.

No response to this issue has been given. Concern remains over accuracy of this plan

Linkages Plan  It is noted the plan indicates flexibility in the exact locations of links between Kilnwood Lane and the northern part of the development which is acceptable.  It should however be noted that in any reserve matters submissions applicants should take account of both the need to minimise the impact on root protection areas and to select a route that makes visual sense -where the density of trees and

46  It is important that any legal agreements entered into by the developer to provide connections across adjoining landowners land do not preclude this.

10. Pleased to note the applicants have stated the legal agreements will need to have regard to this.

Green Space Parameter Plan  The stand off/buffer areas to woodlands and wooded hedgerows as noted above should be shown on this plan. An approximate location for a minimum 20m proposed east-west green corridor has been shown in the south west area of the site. As this corridor has not then been taken forward in the DAS, nor delivered in phase 1, how does this affect the ES ecology and landscape assessments?

11. If there is not to be a proper green corridor running through phase 1 and it is claimed to not be necessary to address environmental impact why has one been proposed in the first place for assessment purposes?

Landform and Drainage Parameter Plan  This plan should be noted to clearly state that (I presume) there will be detailed manipulation of contours on the Kilnwood hillside to construct access roads, house platforms and possible open space terraces etc in future reserve matters applications.

12.Applicants response is noted- I accept this detail will not substantially alter the landform parameters and can be dealt with in each phase application

Phasing Parameter Plan  I note the energy centre is not shown allocated in any particular phase. Does this mean it may not be delivered?  Surely it ought to be part of at least the second phase if community sustainable energy benefits are to be realised. (note I appreciate this is not a specific landscape comment but I believe the issue needs considering)

This comment has not been addressed and therefore remains a concern

Environmental Statement  Chapter 10 Ecology and Nature Conservation - In general appropriate mitigation measures have been identified in respect of woodlands and hedgerows.  Para 10.5.12 – We need confirmation and more certainty that the proposed mitigation measure to provide pinch points (to allow canopy connections) with footpaths re-directed away from the road and a ‘floating’ construction to minimise compaction and root damage will be achievable where access roads cross woodland and hedgerows, and especially in the case of the route through the ancient woodland linking Capon Grove to the smaller ancient woodland copse to the north west. (Note pinch points have not been shown on phase 1).  An illustrative section and statement from the applicant’s highway engineer and landscape architect/ecologist is needed at this stage. We do not want to find at a reserve matters stage that it actually cannot be delivered for highway reasons.

13. This cannot just be left to reserve matters stage- we need confidence that this ES mitigation measure is practically deliverable within highway design constraints. The very fact that it appears to have not been addressed in the detailed phase 1 proposals does not give confidence in this regard

 Management of Ancient Woodland- The management of the woodlands as community/local nature reserves is supported.

14. This issue of who will manage the woodland is still under consideration.

 Consideration will need to be made for ‘ formal’ access arrangements using existing rides to try to limit any damage to ground flora. Also the15m stand off zones will be ecologically enhanced by new woodland, scrub, and wildflower grassland.

Pleased to see a commitment by the applicant to include the above measures as part of a detailed management plan to be secured by legal agreement. However they are key mitigation measures needed to reduce adverse impacts on ancient woodland from trampling pressure etc which should also be clearly included in the ES list of mitigation measures- add to ES tables 17.1 and 17.2 accordingly

 Corridors for mammals, reptiles etc- whilst we can condition detailed mitigation strategies as part of each phase there should be a commitment now to provision of suitably designed culverts and pipes to allow species movement where roads cross ancient woodland, hedgerows or new green corridors.

15. The applicants have stated that there may be a range of solutions to maintain wildlife corridor species movement which may include culverts and pipes but not necessarily restricted to these and these will be considered as part of each phase recommended by a professional ecologist. The proposed types of mitigation measures that will be considered in the phase applications should however be listed in the ES tables 17.1 and 17.2 It is hard to have confidence in this regard because no such measures have been included in the detailed phase 1 proposals in relation to green corridors

Chapter 9 Landscape and Visual Impact  Why has there been no assessment of the impacts of construction in terms of landscape and visual effects of earth moving, machinery, cranes etc? This does not conform with the EIA regulations.

16.The applicants response is unclear/does not properly address this. The assessment of the full range of construction impacts on landscape and visual receptors should have been part of the assessment as a clear section within the LVIA chapter, as done for other ES chapters. No mitigation measures in terms of location and fencing of construction compounds, controlling extent of earthmoving area at any one time etc have been identified.

 Residential receptors- please explain why no representative residential views have not been considered?

17. The applicant has advised these have been assessed by implication from nearby public footpaths. Whilst this may be true in quite a few cases there are some eg Roffey Park where this is not the case. Impacts on residential receptors should have been more

48 systematically assessed even if impacts are not considered significant.

 Once houses are built on the new landform which is similar in height in the south east area of the site to the existing landform, would those on the highest ground, at least in the short term be visible from the adjoining cottage/ Bewbush estate?  There is a need for a cross section/s extending across the boundary to demonstrate what the impact might be or showing there is none.

The applicant has not agreed to cross sections at this stage. The ZTV plans do suggest a potential high impact in this area. I would question, although there are localised effects from the hedgerow being quite thick in places, whether the assessment has properly taken account of the worst case scenario of visual impacts in winter as photos were taken in summer. There are 3 storey flats with potential views anyway. Beaubush Cottage is not screened by a hedgerow. Also the assessment does not distinguish impacts on completion of development from those 15 years after additional planting has begun to be properly established. The above concerns re winter assessment and length of time for planting establishment are generally an issue for assessment of the visual impacts of the proposals

 Views from the AONB- I am in agreement with the assessment about the very limited impact from public rights of way. However there seems to be an important omission of any view from Holmbush Farm Park a tourist facility that is highlighted on the OS map. Similarly why has no view from Buchan Hill golf course been assessed?

18. Holmbush Farm – there are views from a recreational/play area. Buchan Park – can agree impact of surrounding woodlands may well provide screening to any views of built development but confirmation that no part of a 60m chimney stack will be visible should be provided

 Circus feature column in the design and access statement- I understand this feature shown illustratively is most unlikely to be built.  I would also be concerned about cumulative visual impact with the chimney stack. I therefore recommend it is taken off the illustrative drawing altogether, or stated in the supplementary document it is no longer a possibility.

19. The applicants have maintained that the principle of a landmark vertical feature will be agreed as part of the DAS and that the precise nature of the feature will be determined at the detailed design stage in accordance with the parameters in the ES. However the height parameter plans only relate to building heights and the CHP stack height, the area in the centre of the circus is not colour shaded, and there is no evidence that a maximum height for the circus feature or cumulative impact with the chimney stack has been considered in the landscape assessment text. The illustration in the DAS suggests a feature that appears to be as much as 7-8 times the height of surrounding 4 storey development.

A feature that is no more than 4 storeys height could be accepted if the parameter and DAS building height plans are suitably amended to allow for this but I would object to the landscape and visual impact of anything higher. With the knoll proposed as well it should not be necessary to have an additional orientation/legibility feature proposed as well

20. It is noted table 17.1 of the ES proposes a 20m structure planting belt on the western boundary of the site to conserve the integrity

49 of the strategic gap. The county landscape architect has emphasized the importance of such planting. ES table 17.2 needs to be amended as its not acceptable for its provision to be subject to determination of a relief road that may not happen and there is no certainty when it will go ahead. Condition/obligation in the legal agreement needed to cover this

Remediation strategy Appendix 8.4  I note a comprehensive remediation strategy has been prepared for the landfill on the site. These matters will need to be conditioned.  We will be looking to ensure for each phase of the works there is a robust landscape specification for ground preparation and cultivation but at this stage we need some further information re the approach to subsoil and topsoil use for landscaping purposes on the site.

21. Commitment to use of the code of practice for sustainable soils, together with an application of a materials strategy is welcomed. Needs to be secured by condition

Utilities Report  Whole site strategy- The report essentially only covers phase 1, not the whole site as suggested.  We need a services strategy for the whole site at this stage setting out the key principles for the location of underground services and in particular the need for services corridors to be kept within the east-west, north-south access roads and excluded from green corridors, planted road verges ( except through driveways) and green spaces.  This is essential to avoid damage to existing trees and hedgerows/woodlands and avoid conflict with new planting.  At the very least, as an alternative, we need a written commitment now regarding these issues, with a services strategy provided by condition prior to the commencement of any development  At the moment the BW public utilities corridors drawing for phase 1 shows the corridors include road verges and the neighbourhood park, so this does not give confidence in this regard.

22. Comments from the applicant re their intentions in respect of services are noted – to be provided in roads or in localised cases in footpaths. However the comments miss the point that the utilities report includes a plan showing services corridors incorporating verges and open space giving utilities companies the license to work within these areas as well. Either an amended utilties report/plans should be provided incorporating all the above points, including the undergrounding of services to and from the CHP plant ( see earlier comment) or we will condition the provision of a services strategy.

Sustainability Assessment

Landscape Proposals  Sourcing of materials-There should a commitment, not only to meeting the ecology requirements of CSH, but also sustainable sourcing of hard and soft landscape proposals under BREEAM.

23. The commitment to sourcing sustainable materials wherever possible in the supplementary DAS is noted it should be more precise than this and follow a recognised scheme of assessment ie CSH code 4 or BREEAM.good/verygood.

50  Topsoil- commitment to minimise importation of topsoil.

24. Commitment in draft supplementary DAS is noted.

 Green Roofs- more definite commitment needed for provision of these for community facilities, including the school and possibly the CHP plant.

25. The applicant has referred to various statements, recommendations in the Sustainability and Suds/FRA report although wording is still not definite- eg ‘ opportunities may exist for… ’ , ‘’potential for ….etc. Provision needs to be written into the legal agreement with appropriate allowance for costs

Design and Access Statement and Open Space Strategy  I consider it is important that the main development plans in respect of use/amount, scale, access/movement, linkages and landscape and open space are cross referenced to in any decision notice and I would recommend they are submitted as stand alone A1 plans to a standardised scale, rather than just included in the DAS where they are not to scale.

26. A1 plans have been submitted

Illustrative Masterplan-  Would the configuration of residential development and access roads shown allow it to development to positively face the Kilnwood Lane woodland and an open space buffer edge rather than turn its back on it?  The concept plan in the DAS appears to suggest development would back onto the woodland so not giving confidence in this regard.  This is a key issue and the illustrative cross section information to show the relationship of the development to the woodland, previously provided pre-application, should be submitted as part of the DAS

27. I accept Figure 19.8 does show development facing woodland and open space on the plan. However it is not explicitly stated in the written principles. This should be written into the supplementary DAS statement or we will deal with it by means of an informative on any decision notice, including reference to cross section drawings provided pre-application.

Scale  Panorama -The building heights plan in the design and access statement indicates a ‘possible localised height restriction’ to allow a panorama to be maintained southwards’ from the viewpoint on the ridge near Kilnwood Lane.  The main design principles statement on page 88 puts considerable emphasis on this panorama, but on the basis of the plans submitted I cannot see how a panorama in the normal sense of the word will be provided.  We need to be clear at this stage that a panorama view is achievable by appropriate limitation of building heights, and demonstrated by an illustrative long section and a photomontage illustration (massing and height diagram on photos). It would not be appropriate to leave this matter, as stated in the DAS plan, solely to the reserve matters stage.

28. Either the building heights are appropriately fixed now to facilitate a proper panorama and this is demonstrated by evidence or the

51 wording referring to panorama in the DAS should be changed by a supplementary statement cross referenced to the DAS. The applicants accept views at ground level are likely to be restricted to view corridors. The use of a viewing structure on the upper terrace has been mentioned – however this is not likely to be appropriate as it could well affect the garden privacy of the nearest houses.

Access and Movement  Pedestrian and Cycle Movement Plan and Bus Gate Linkages- There needs to be a clear mechanism by legal agreement/Grampian condition for the delivery of all those linkages outside the application boundary, taking into account the need for minimising the impact on existing trees and vegetation, appropriate management of boundary vegetation, and new planting associated with these links.

29. Applicants response is noted

Landscape and Open Space Plan-  We need clarification that a minimum of an 8M open space buffer to the Kilnwood wooded edge and to one side of the green corridors has been shown.

To clarify my previous comment above- the 8M I was referring to was the root protection standoff from the edge of the woodland/hedgerow canopy which is shown in the submitted arboricultural survey for the outline application, which I understand was based on the largest trees assessed. From measurement of the the DAS A1 landscape and open space plan the open space buffer width measured from edge of canopy to development is generally a lot less than this 8m width –in fact mostly about 4m width, in a few places a bit less or more.

I recommend an informative on the decision notice that highlights the need for root protection areas to be fully taken account of in this phase of the development to ensure access roads, built development etc are still set back the appropriate distance for root protection which may extend beyond the open space buffer width shown on the DAS plan.

I would add from my measurement of the plan the 15m ancient woodland standoff has not been properly respected around Capon Grove, such that there are widths of 8, 10 and 12m around the wood which extend beyond the areas where some localised intrusion for roads, bridge embankments was considered reasonable. It is clearly not acceptable to have this greater intrusion in the 15m zone and the DAS plans should be amended accordingly to achieve compliance with the ES mitigation measure.

 One of the large parkland trees in the northwest corner of the site is shown largely in a development area shaded grey, when its long term protection would be much better secured within the open space.

This is a very important tree which is very unlikely to be successfully retained in back gardens- If the developer is not prepared to show it at this stage in the DAS landscape and open space area I recommend an informative on the application to cover this

 To accompany each subsequent reserve matter submission for each phase we will require the provision of a green infrastructure analysis plan that demonstrates how all relevant green infrastructure issues have been consider in an integrated

Landscape and Open Space Strategy in the DAS- The key objectives as stated are supported but there are additional principles that should be added to guide future reserve matters applications  Provision of themed street planting, appropriate to different character/sub-character areas within the development  Street trees spaced so that canopies can join up, where feasible in terms of necessary access routes, to maximise green infrastructure provision  Use of medium –large growing tree species on primary routes  Use of hedge planting to define frontages  Maximise the use of large parkland scale trees of mainly native species in green spaces  Provision of native tree and structure succession structure planting in green corridors  Follow WSCC Low Weald planting guidelines for native tree and shrub structure planting  Maximise opportunities for native wildflower seeding in green corridors and key green spaces  Provision of areas of naturalistic perennial planting and swathes of bulb planting in green spaces  Ensure planting is adapted to climate change- to include drought resistant species

I welcome the inclusion of the principles I proposed in the supplementary DAS

Key Spaces  The Gateway- I am pleased that consideration that has given to provision of a distinctive landscape design for this area, whilst dealing with highway visibility/safety constraints. However there are some concerns that need to be dealt with.  The formal ring of fastigiate trees around the edge of the roundabout and the formal lines of planting (native species proposed) contrasted with an informal tree clump in the centre island to provide a soft gateway/clear waymarkers to the new neighbourhood and to Crawley on balance are considered to be acceptable.  However the proposed urban style curved walls either side of the main access are considered to have unacceptable landscape impact close to the AONB boundary. The curved walls should either be replaced by a countryside hedge or a living wall structure, or another alternative would be for the wall facades to be entirely screened by native shrubs and climbers. Whatever is done it needs to be easily maintained. A sign of modest scale for the neighbourhood, other than any highway signage, could if necessary be set into the planting.  The Illustration therefore needs amendment or at least agreement is needed to change the approach as set out above.

34. The proposed green wall treatment is likely to be acceptable. The county landscape architect would prefer the walls were taken out of the proposed highway boundary

 Key Space South and North square- I am satisfied with the design principles illustrated for these spaces and support the design strategies.

 Neighbourhood Park- It might have been preferable for this to have incorporated or to be located adjacent to the nearby green

53  However the principle of getting a high degree of natural surveillance from houses facing onto it is supported. I would like to see at least some of the central green as wildflower seeded areas which would provide an interesting contrast to some of the more formal aspects of the design as well as enhancing biodiversity.

 Axis Spine- I am satisfied for the most part with this and the variety of spaces that will be created along it. However I am concerned about the offsetting of the station or other landmark building on the south side of the railway and wonder whether the axis breaks down too much adjoining the railway on the northern side?  The design strategy should include text committing to maximising the use of large growing avenue trees in single or double avenues.

37. Recommend these issues are dealt with as part of a design brief for the area, in the absence of it being addressed in DAS design principles at this stage

 The Knoll space- Despite its artificiality, the proposed landform- in terms of scale/ height and its slopes will not be incongruous when seen against the backdrop of the AONB wooded ridgeline and it does take positively take advantage of a pre-existing rise in the landform of the landfill site.  As a viewpoint to look along the axis I can see merit in this, but have reservations about it in terms of providing views to the south towards the AONB, because at least in the short term, it will be looking down onto the dual carriageway.

38. Accept planting will in time mitigate views down onto the dual carriageway

 However we definitely need more reassurance/commitment now from the applicant that the area can be successfully managed and maintained before we can accept the principle of the proposal. Some photographic evidence of similar features elsewhere should be provided and a commitment given to exclude the use of intrusive fencing, lighting columns etc in a long term management plan to be prepared subsequently.

I am disappointed that the applicant has not been forthcoming with photographic evidence to show successful design and use of a similar feature elsewhere. Why not? This should be provided. Accept detailed landscape maintenance issues can be dealt with in a management plan. In the absence of a commitment in the DAS re lighting, fencing etc deal with by an informative

 Sledging and other activities are envisaged. I would suggest the future detailed construction and landscaping will need to be robust enough to withstand this sort of wear and tear. It would be sensible to design it so that an activity like sledging is only encouraged on the northerly more shallow slopes. (Informative needed).  The sculpting of the knoll landform is mentioned as a possibility in the design strategy text. I am strongly of the view that to enhance its attractiveness as a landmark feature to be of benefit to the new neighbourhood and the wider area, it is essential a more strongly sculptural landform to the slopes. This would give it greater distinctiveness as a special feature of the development (as well as making it a selling point) and give additional purpose to the Knoll (landscape design as art). I would therefore seek a strong commitment to this in the design strategy text rather than it just being mentioned as a possibility.A single feature tree on the summit might be an alternative to any public art feature.

No strong commitment has been forthcoming to the above issues to include in DAS design principles. There is no guarantee that such proposals would be brought forward in a reserve matters application, unless secured through legal obligation now, or that it would be proposed as a public art feature in the relevant phase. I believe a landscape design approach along the lines I have suggested is essential to ensuring the Knoll is an acceptable locally distinctive feature of long term benefit not only to the residents of the development but also users of the wider landscape. If it is not to be strongly committed to in the DAS then it should be secured through legal obligation.

 The formal sports provision illustrated is tightly squeezed into the illustrated space, very close to the bottom of the knoll landform.  I am concerned proper allowance should be made for a buffer hedgerow/structure planting between the footpath and the suggested ball courts or other formal provision. This should be covered in the design strategy text and when detailed plans come forward we will expect this issue to be taken account of (informative needed)

This concern has not been responded to. Recommend informative

 The perspectives illustrate residential development will appropriately face onto the Knoll space, but this is not shown on the plan nor clearly stated in the design strategy text- at the very least the text should be amended to say ‘’ typically 2 storey building height will enclose and face onto this space..’’

No satisfactory response has been given. Recommend an informative

 There is potentially also a conflict between the location of the play areas and sports provision in relation to the residential development.  Will appropriate width buffer areas be provided to avoid noise issues, adverse impact of fencing etc - again this at least needs to be dealt with by appropriate text in the design strategy.

I accept a recreational green and play area are unlikely to require intrusive fencing. However appropriate buffer distances to play areas need to be ensured and a MUGA would have fencing. Recommend an informative

 The Knoll Approach- Generally I am happy with the design approach but share some of Peter Martin’s concerns about the legibility of the space. I am not sure that a vista between the Knoll and the Circus can be confidently stated as ‘’will be uninterrupted’’, when the illustrative material showing the configuration of built form – illustrative axis spine plan and the knoll approach perspective appears to conflict with this. Whilst a variation of size and scale of spaces within the spine is supported, the width of the vista illustrated in parts of the area may be so narrow as to be almost imperceptible

39. Applicant has clarified the axis will be clear from an elevated position at the Knoll which is accepted, but advise at ground level the legibility will be a matter for detailed design. Recommend an informative to cover this issue

 The Circus – Whilst the principle of some kind of a public art centrepiece in the circus is supported, it is considered the height

40. See comments above re the needle

 The Neighbourhood Centre and the Market Square- Activity is welcomed, but a key part of the design strategy must be to minimise the visual dominance of any parking in the space.  I recommend the diagram is clearly labelled to indicate that possible parking areas occupy a low proportion of the total space (especially as there will be an alternative larger car park nearby) and minimising the visual impact of the car should be part of the design strategy text.  Recent neighbourhood centres at Southwater and Bolnore show the problems that arise when their squares are dominated by parking.

41. Pleased to see applicants have committed to production of a design brief for this area which can address the above and other issues. This needs to be conditioned and a specification set out in a legal agreement for the process of its production. Note comments below however

 As the success of the Neighbourhood centre is particularly key to the development a masterplan for this area and more detailed design guidelines set out in a design brief, as has been suggested by the applicant, may possibly be a way forward.  Brook Crossing and Station Square- An alternative design strategy is needed if station is not built.  There needs to be some principles in the design strategy text in respect of parking or otherwise in the square- location/extent- a workable vehicle movement plan to prevent traffic chaos will be critical in the detailed design

42. The applicant has committed to a design brief if the station is not provided. However I would recommend that a single design brief is produced for the whole area of the neighbourhood centre, station area ( with and without station alternative scenarios) and the primary school so the relationships between these areas are properly considered in one go.

 A high quality bridge design for this main crossing of the brook will be vital and we need a statement to this effect in the design strategy, cross referenced to a general bridge design strategy in the DAS, as proposed below.  We do not want to end up with standard concrete bridge designs.

Bridges-Recommended general good design principles for Kilnwood bridges should be added to the DAS and are as follows:  Bridges will be simple and elegant and their associated embankments will be sympathetically graded and planted to integrate them into the landscape, minimising visual impacts.  Bridges will be of harmonious design both in terms of the proportions of the structure, and in terms of ensuring symmetry, a rational order and rhythm in the design of the bridge elements to avoid a discordant appearance  The design of lighting, railings/parapet design will be integrated effectively  Cladding will also be used to improve the appearance of bridges and consideration will be given to the use of local materials. Footbridges across streams and ponds to be of timber construction.

56  A rider note can be added, if necessary, to the effect that very specific network rail safety design constraints will be applied to the railway crossings and these may severely restrict design options. However as a minimum the possibilities of the use of cladding to improve the appearance of railway bridges will be sought.

43. I welcome inclusion of the principles I provided in a set of design principles in the supplementary DAS although concerned that the reference to consideration of use of local materials has been taken out.

 Terraces square- The Concept is supported  The Viewpoint- I am satisfied with the illustrative material but I consider design strategy should note the possibility that an alternative high quality formal landscape design approach could be adopted rather than necessarily following the italianate styles/gardenesque styles illustrated.

45. As the applicant has stated this issue will be considered in the appropriate phase I recommend an informative to cover this

 Kilnwood Vale Park- I am broadly happy with the layout illustrated. The design strategy text should note potential to provide some significant wildflower seeding beyond any buffer edges to formal pitches and the need for sensitively designed floodlighting.

46. Recommend an informative as not being included in the supplementary DAS text

 I note in addition to the main leisure route shown other pedestrian links are intended to be provided connecting to the adjoining Bewbush Open Spaces but this would need to be covered by legal agreement now.

 Informal square- Space configuration illustrated is fine. Design strategy should have a commitment to include provision of naturalistic perennial planting in the central green to provide a contrast to other more formal landscape spaces.

47. Covered by the supplementary DAS now

 Formal Square- I am happy with the illustrative material  Greenway Square – I am happy with the illustrative material  Green Corridors ( west, central, east)– am broadly happy with the illustrative plans. Need to add text in design strategy committing to native succession planting. Whist in principle I can accept some formal, active recreational uses in the green corridors I am concerned what has been illustrated on the central greenway would run contrary to providing connected ecological corridors. When detailed proposals come forward for the green corridors we will expect connections to be maintained and enhanced by retention of existing hedgerows and new structure planting.( need for informative) Also design strategy text needs to cover appropriate surfacing materials for footpaths and cycleways and minimising the impact of lighting. With re to the eastern green corridor along the Bewbush boundary- selective opening up /management of vegetation on the boundary is supported to strengthen visual links with Bewbush but would not necessarily subscribe at this stage to the layout illustrated.

57 50. Recommend an informative to cover the above issues

 Bewbush Brook- The illustrative material and design strategy is fully supported. Care will be needed when the detailed design is subsequently developed to ensure a variety of bank slopes are provided along the course of the brook to create visual interest and provide for habitat diversity, rather than having a standard cross section profile along its length ( informative needed)

51. It is useful to have the clarification that the landform works in phase 2 and 3 are purely for remediation purposes. Informative is recommended re the above detailed issues so that they are properly dealt with when the development proposals come forward for these phases

 Attentuation Ponds- I am broadly happy with the illustrations and design strategy. The use of some permanent water bodies as a design feature is supported.  An appropriate management and maintenance strategy for all the attenuation features will be vital to their success and will need to be tied up by condition and legal agreement.  It is noted many of the more formal, intensive maintenance green spaces/squares are intended to be managed by a private management company. This is supported but it is recommended that the legal agreement for the provision of a management plan also covers the need for demonstration that sufficient funds will be invested in the management company to provide some of the more intensive maintenance operations.

53. I recommend the legal agreement includes an obligation for the provision of a bond in the event the private management company goes bust

 Play Strategy in OSS – The text should specifically refer to providing imaginative natural play opportunities.

54. The applicant is asked to clarify exactly where in the DAS and Open Space the term natural play is already used – otherwise informative is recommended

 Open Space Strategy Budgets in OSS- Whilst is useful to identify up front appropriate formal open space budgets for each phase for the legal agreement we will need more evidence of how these budgets have been calculated and budget flexibility will need to be built in both in terms of what specific types of facilities are actually agreed to be provided in each phase and allow for inflation.

55. There is no specific response from the applicant on this issue. I would recommend on further consideration we are not tied into any particular capital budget allocations for different types of space, even if an allowance for inflation is made.

 Flexibility of open space provision in OSS -eg allotments, kickabout areas, garden areas in neighbourhood parks, exact type of formal sports provision .  The principal is supported of allowing some flexibility with residents able to make some choices about what they want in the open spaces. However I have thought the LPA would want to maintain some control to avoid in balanced provision across the

56. The applicant has just responded that these issues will be considered at each detailed phase application, so unclear how the approach set out in para 7.2 of emerging community involvement in the design of spaces and the flexibility set out in para 1.7 will work out in practice . There is a danger of this being too ‘wishy washy’. There still needs to be a mechanism in the legal agreement and/or through appropriate conditions for any departure from the precise location, size and type of formal and informal facilties shown on the open space strategy figures 1,1 and 4.1 and key area plans to be agreed with the local planning authority and to ensure compliance with the amounts of provision set out in table 1.2.

Also whilst formal play provision locations and amounts for children aged four to eight are shown on figure 4.1 within 240m/480m distance we still need to ensure through the legal agreement and individual phase applications that other small play areas for very young children are provided within 60m radius in smaller green areas etc see para 5.6 of the open space strategy. It is queried why on Figure 4.1 there is a substantial area outside of the 480m walking distance for formal play? This needs to be addressed

 Landscape Maintenance and Management Proposals and woodland management in OSS. These form a good starting basis for a full management plan to be provided by condition and legal agreement. I will give some response to the initial framework in due course.  Urban Form and Structure Plan in DAS – with re to earlier comments is it view corridors or a panorama being provided. Plan appears to indicate a broad open space in front of the viewpoint.

58. There has been no response to this comment. See earlier comment about establishing more definitely whether a panorama or just view corridors are being provided for. Need to ensure consistency between different DAS plans

 Illustrative Layouts in DAS- I am mostly satisfied with the landscape design approach to the various types of block layouts illustrated but a key concern would be, in the absence of scale plans, whether there would be sufficient space between access roads and residential development for at least medium eventual size street tree planting. This needs to be addressed.

59 I would still be concerned the secondary access road layout illustrasted may restrict us to only small size tree species. However we will deal with this in individual phase applications

 Space Typology- Primary streets landscape text should specify at least medium size tree planting with provision of larger trees at focal points/junctions or locations where there are greater set back distances from development.

Accept applicants comments

 Appearance- use of public realm materials with a high green rating is noted. Does this apply to building materials? General approach to street furniture, lighting and public art is supported

Strategic Design Code

59 The Regulating Plan  Inconsistency with other plans in respect of the viewpoint panorama ( see comments above)

Not addressed; no response from the applicant

General comments re code for public realm and landscape  Clipped hedges are fine but I would be concerned about over-use of walls and railings on the axis spine, creating a cluttered appearance. If hard urban appearance is more important here why not just allow for some built development to be at the back edge of the footpath without these boundary treatments?

60. Applicants response accepted

 Are the primary streets wide enough to accommodate London Plane?

61. I still have some doubts about this but we will check through the detail phase applications

 Contemporary lighting and street furniture is supported  Road and footpath finishes- more consideration needs to be given to the use of appropriate colour surface dressings, rather than extensive areas of flags and blocks on footpaths.  County council indicated support for this at a recent meeting re appraisal of the development that I attended- also will not accept blocks on bus routes. Blocks are fine for the more minor access roads and courtyards.

62. WSCC has recently confirmed to me that WSCC would not object to the use of surface dressings or a similar surface eg embedded chippings on bus routes and secondary access roads, subject to detailed design and specification being satisfactory when details are submitted for their approval. Therefore I would seek an amendment to the code now to provide for this. I do know that they will not accept concrete blocks on bus routes

 Suggested tree species are okay and themed planting is desired- however when individual phases come forward we would not want to be too heavily bound by the code where as part of the detailed design approvals local circumstances may suggest other tree species may be appropriate- best for the tree species to be stated as examples of species that may be appropriate

63. I appreciate the review mechanism for the code can be agreed and that this can be tied to a planning condition. Nonetheless I do not want us to be too bound by certain tree species now and therefore an amendment to the code should be provided that tree species listed are examples of species that might be used in different situations rather than having them as the ones to be used unless otherwise agreed in writing.

 Recreational routes- bound gravel or gravel surface dressing on tarmac paths for more intensively used routes

64. Applicants response is accepted

60 Phase 2 and 3-Full details of Engineering Operations  At a broad scale I am generally happy with the proposed landform.

Accept, if as in applicants letter there is a subsequent 10cm reduction in height of landform across the site this will not make a significant difference to the landform and drainage parameter plan.

 For the attenuation ponds and banks of the brook we need significantly more detail- suggest 0.5 m contours, and more cross- sections ( approx 30- 50m intervals) and long sections- to demonstrate how a visually interesting landform and habitat benefits eg through use of marginal shelves can be secured through landform design. At present I am concerned/cannot judge from the present information how this will be achieved. This should be provided now or it will need to be conditioned to be provided prior to the start of the earthworks.

68. Accept applicants response that this detail will be forthcoming as part of the built development applications for these phases- but we need to word reserve matter conditions to cover this

 A steep bank will remain on the interface of the school land, green corridor and residential development.  A cross section should be provided across here, and buildings, planting and fencing shown illustratively on it to demonstrate that these future development elements can work with the proposed landform.

69. Accept applicants response. Note- Contour changes for the attenuation ponds in phase 4 and 5 are shown on the submitted contour plans- however we will not be approving these.

 Knoll- If only earthworks are done at this stage with no seeding the slopes will be vulnerable to erosion.  We will need to agree a temporary hydro-seeding for the area, and by condition require full details of final landform sculpting, seeding/planting, paths etc, or otherwise agree the full details now for implementation

70. This concern is not addressed-will need to cover in the legal agreement and by condition to allow for temporary seeding. What happens if there is a considerable delay in the development In this area being applied for?

 Also re the stream works, or any other areas with steep banks there could be a similar issue re erosion.

Phase 1 Full details  Given the issues/concerns above re CHP plant consideration and its relationship to phase 1 there may be a need for phase 1 to extend only as far as southern boundary of the proposed balancing ponds ie exclude development to the north for the time being.

Earthworks  We need a long sections/ cross sections across the site showing not just the landform but the interrelationship between landform, development, and green corridors

61 72. The applicants consider the level of info provided is sufficient. I accept given the land is only gently sloping this may not be critical, although I would still be of the view it would have assisted in understanding the relationships between built development and open spaces

I have reviewed the balancing pond details these and am satisfied with the proposals.

Green Corridors  What does the double red line on the boundary with the reserve land denote? Also a sub- station and parking have inappropriately encroached into it in some places

73. Noted the substation position has been moved out of the existing western boundary green corridor to area near CHP plant to the north, adjacent to unallocated parking spaces. However the substation will need screening planting and there is a general question why there are no landscape proposals for this area of informal open space within phase 1 of the development ie structure planting and wildflower seeding etc ? Needs a written commitment from the applicant re this and we will deal with as part of the landscape conditions. Clarity however is needed on the east-west road in this area- has the layout been designed to be sufficient to serve the CHP plant or could it be subsequently modified/upgraded with implications for the flats in this area?

 There is a need for succession native structure/hedgerow and tree planting in both east and west corridors, where space allows.

I think there is a misunderstanding in the applicant’s response. I was only referring to additional strengthening planting detail for the two green corridors within the phase 1 boundary not other green corridors outside it at this stage. No additional planting has been provided in these areas which there should be in accordance with the agreed supplementary DAS landscape principles. A written commitment is sought on this area from the applicants and I recommend we then deal with it as part of discharge of landscape conditions.

 Further consideration needs to be given to fence/ railing issues/ planting/ links through to the countryside and management issues. Need for cross sections to show planting and fencing

I agree a security fence is not appropriate. I recommend the details of planting and fencing at back of car parks and gardens would be best dealt with by a more detailed discussion as part of discharging landscape, boundary and hard landscape conditions. Management agreement will need to address issues of potential dumping on the boundary of rear gardens. The idea of providing some low key pedestrian links onto the reserve land has been discussed. The area may remain un-developed for some time. Written commitment to a couple of links is sort now and needs to be dealt with by legal agreement and condition.

 The east- west green corridor, min 20m width, shown on the ES parameter green space plan has not been delivered. How is this proposed to be dealt with?

See earlier comments. No proper additional 20m green corridor has been delivered in the phase 1 area.

62 Spine Road at northern end of the Neighbourhood Park  With regard to the above missing green corridor this would be a substandard very green corridor could strengthen road planting- setting back built form at the western end adjacent to the western green corridor .

74 There has been no agreement to setting back development at the western end to allow tree planting

 Where it crosses the eastern green corridor where is the pinch point required as mitigation in the ES.

Yes I accept there is a pinch point. However why have no other measures for species movement been proposed- underground culverts etc? More generally have any protected species mitigation requirements in respect of phase 1 been complied with.

Neighbourhood Park  Are the small garden areas critical to the scheme- given the maintenance implications, even under private management, would just 2 rather than 4 areas be more sensible/realistic?

75 Accept applicants response but will review planting detail to ensure satisfactory

 Buffer mound- a cross section is needed

Explanation of the landform is helpful but a detailed cross section will be required by condition

 I appreciate it is intended to allow for some flexibility of use for central green but the formality of the green could be contrasted with wildflower seeding in buffer areas

Understand this area has to meet formal recreation requirements. However the central green is not proposed for formal sports pitches. If a 30m x 15m kickabout area is allowed for in this area together with some areas of mown amenity grassland areas for a range of other activities eg sitting out on the grass,picknicking, play etc other this would still leave space for buffer areas seeded with wildflowers. I consider this would not undermine the JAAP provision. The shape of the area designed in any case only allows for one kickabout area. Recommend if not redesigned a written commitment is provided and we deal with this by condition. Detail of play areas provision will need to be dealt with by legal agreement and condition

Central Footpath/Cycleway  What is the reason for no tree planting at the northern end?

Attenuation ponds  Feature wall- design and appearance? We need more detail now as critical to appearance of this area.

77. If gabion wall treatment is proposed then planting will be needed in pockets to soften

 Road crossing- a cross section is needed to assess impact.

Cross section referred to is accepted

 Need for native shrub structure planting to enclose adjoining accesses/driveways, managed at 1m height to the south otherwise appearance of ponds will be marred by visual impact of car parking

Understand the need for secure by design but some shrub planting in road verges adjoining the ponds will be sought. Could include some lower growing cultivars of native species. Deal with through the landscape conditions.

 Need for groups of wetland trees.

Appreciate EA requirements- however will want to look at some additional trees as part of landscape conditions

 Views through blocks of flats are a concern depending on size and scale of the CHP plant

Provision of Structure planting on the land to the north of the flats will help in this regard. See above comments

General comments  Avoid very small triangular grass areas;pave instead

Review as part of landscape conditions

 Need for climber planting on blank elevations, fences in courtyards

Does not need to involve trellises etc. Self climbers could be considered. To be reviewed as part of the landscape conditions

 Commitment however needed now for provision of semi-mature size trees –min of 25-30cm girth on main access, spine road, in the neighbourhood park.

Am satisfied with the response

 Lighting report/plans can be conditioned. Contemporary lighting design looks appropriate but will need County approval

The Accesses and Roundabout  I am very concerned about the size of 2 of the advanced direction signs -6.9 by 4.3m which will undermine the landscape design of the gateway. I will have a conversation with WSCC about the need for signs of this size, although I appreciate there are others of a similar size on the dual carriageway.

79. Applicants response is accepted but the large signs should be recognised as a detrimental landscape and visual impact on the edge of the AONB.

 The layout/structure of the planting shown is acceptable. We will condition a detailed planting plan.

80. The County Landscape architect will require some changes to planting- shrub mixes not stripes of individual species and substitution of cytissus and ulex by cornus sp due to the clay soil. I will subsequently advise on any other planting detail changes and this will be dealt with by landscape condition.

 Is a new footpath delivered on the north side of the Toucan and Pegasus crossing back to the existing bridleway which goes into the AONB ?

83. Confirmed I agree this is provided

Compensation woodland planting  20m woodland planting proposed for visual mitigation and for compensation of loss of poplar plantation on the western boundary of the reserve land is not included. Needs to be appropriate condition/clause in the legal agreement.( Advance planting – prior to commencement of phase 1)

85. Correction this is 20m structure planting – see earlier comment under the ES section. To be dealt with by appropriate condition/legal agreement

Back garden tree planting  I concur with Crawley that back gardens generally should provide adequate private amenity/quality of environment for residents.  Need to ensure however there is not a significant reduction in the number of larger garden areas to achieve this- space is needed for larger back garden trees- important to the landscape/visual mitigation of the development

86. Am satisfied the minor changes to back gardens made so far do not adversely impact on ability to provide for back garden tree planting

Access road embankment  Need for hedge/ native structure planting on the embankment, not just trees on the top

87. Can see hedge and avenue trees on embankment sections. However additional dense structure planting should be provided The County Landscape architect has emphasized the importance of this planting for strategic landscape character reasons and compensation for loss of poplar plantation close to where loss will occur Written commitment sought now and deal with by condition

Noise Attenuation Wall  I will need to be satisfied about the detail and effectiveness of the green wall solution so that it does not have adverse visual impact

Green wall treatment specification has not been provided – will deal with by condition

 General landform, illustrated by cross sections seems acceptable  Planting- my understanding is this will be primarily a woodland mix but this is not necessarily illustrated on the cross sections? Trees shown but no understorey shrubs?

We will deal with through the landscape conditions- need for more areas of woodland understorey shrubs than proposed

 Connection of footpath/cyclepath into Bewbush- need to agree sensitive vegetation management on bridleway, to make it feel safer.

Revised connection plan to Bewbush – general location to connect directly to footpath to Chetwood road is acceptable. However position in relation to very large hedgerow oak needs detailed consideration. Exact position shown is likely to affect the tree adversally. Tree survey detail needs to be provided – adjust position of bridge/footpath as necessary to ensure no damage.

Important Additional Issue re play Where are all the areas for toddlers play within 60m walking distance of homes to conform with the open space strategy

22/02/2011 DAS/ES  CHP Plant/chimney - I remain very concerned about the height of the CHP chimney up to 60m in height- adverse impact on the skyline of the kilnwood ridge, wider impacts on the surrounding countryside and the Strategic gap. Quality of recent wire frame photomontages provided is poor and does not give any more confidence that this impact can be contained. Also the visual relationship to phase one housing could be adverse if the building is as high as 25m as shown on the DAS building heights plan. Could a condition be imposed to restrict heights?  We have not been given any illustrative information of similar facilities elsewhere- no principles in the DAS to govern design - may need to look at carefully worded condition.  Ancient woodland standoff- a number of areas around the woods are not compliant with the 15m setback from any development. Could a condition be imposed that states notwithstanding the DAS plans the development must comply with a 15m setback distance?  Circus public art feature/needle- if it’s the height illustrated it will have a cumulative adverse visual impact with the chimney. Building heights plan does not have any height limitation where it is located. Could a condition be imposed to restrict its height to no more than that of surrounding buildings?  Loss of tree group W15. I continue to object to loss- reasons set out in previous consultation responses. If they are removed a condition should be imposed to require large semi-mature replacement trees 50-60cm girth in nearest open spaces to area of loss.  Knoll – I am happier that they have included images in the supplementary DAS but to secure a quality design need this needs to be controlled by condition and by clause in the legal agreement. ( Engineering works - condition will be needed re

66  Neighbourhood Centre, Station area and school- as previously recommended support a single design brief for the whole area to be secured by condition and a clause in the legal agreement setting out an agreed participatory process for its production.  Bridges- the location and type of the 3 proposed bridges has not been shown on the DAS movement parameter plan.  Hard landscape palette in code that the applicant refuses to amend is not agreed. This can be secured by condition.

Utilities Report  Previous inadequacies identified have not been dealt with. Condition provision of a services strategy.

Phase 1  Neighbourhood park- incorporation of a kickabout area and wildflower seeded areas. This can be conditioned.  Parking courts cramped- poor environment with lack of space for landscaping. This should be a negotiating point after committee before grant of permission.  Quality of eastern and western green corridor boundaries. Comments regarding hedge and hedgerow tree planting in gaps are welcomed but fencing/railing issue still needs to be looked at in more detail. A condition is recommended that details are submitted for approval.  Provision of understorey shrub planting on noise bund, need for adequate structural planting around balancing lake and additional structural planting on access road bend. This can be insisted upon on when discharging landscape conditions.  I am happy with the supplementary DAS document recently submitted which includes design principles for bridges, additional landscape principles, alternative circus area design and also with various additional notes added to the drawings referred to in Savills letter of the 7/2/1.  I will advise on conditions and informatives subsequently. As made clear previously- notwithstanding the submitted details all hard and soft landscape and boundary treatments will be conditioned

Conservation and West of Bewbush; Kilnwood Vale interim design comments, 29th September 2010 Design Officer Design and Access statement – interim comments

Use & Amount: Residential and other floorspace calculations are proposed in this section, including the residential mix and affordable housing amounts. The proposals are for 2250 -2500 residential units, with 80 around the neighbourhood centre. Phase one includes 291 dwellings, plus infrastructure and the junction from the A264. Although the total amount of dwellings for the site has been reduced owing to constraints identified in the course of the pre-application consultation time period, this is largely compliant with the JAAP. Strategic Planning officers for both Crawley and Horsham are best placed however to comment on the exact figures and identify any issues arising from these. The plan at 15.2 shows a range of densities over the site; it is logical to propose high densities around the neighbourhood centre and

67 towards Bewbush, rather than on sloping ground to the north or adjacent to the SSSI & countryside edge.

Scale The scale section (DAS 16) identifies how the scale of the neighbourhood, both as a total and locally will appear, including building height and building foot prints. Again, there is a logical reason for locating taller buildings towards the neighbourhood centre and the enclosure of spaces, including the Circus & Market Square may benefit from taller buildings (2-4 storey) in these locations. It is interesting to note that localised areas of height in the northern region of the site have been identified. It would be helpful to have a cross section of how this may appear within the landscape and how the view south and north along the axis would be framed by this. There is a useful table showing the size and form of buildings in relation to their use.

Access & Movement The JAAP requires the development to have links with Crawley and links to the surrounding countryside. The outline proposal contains links via Bewbush, Ifield and two in the southern section to the A264. Land has been allocated and designed to also facilitate the development of a station adjacent to the neighbourhood centre. There are cycle and pedestrian links, plus equestrian links to the countryside and through the development.

The movement strategy takes vehicular traffic into the centre of the development from the main A264 junction. The Fastway bus services, plus other local bus services can access the development by bus gates connecting with the edge of Crawley, although it is noted that the bus gate entrances are outside the development proposal area. This poses questions about integrated design of these entrances, not just from a strategic point of view, but localised design issues also.

The figurative plan at 17.1 is useful but poses some questions about vehicular access in the foot/cycle areas, especially the main spine and linking roads. Are these routes just foot/cycle areas? Figure 17.1 shows three routes across the railway; but the text at 17.4 refers to two bridges, This needs further clarification.

Figure 17.2 demonstrates bus movement. The amount of buses servicing the proposed development is encouraging, however the structure and specific routes & points are best commented on by WSCC and those with knowledge of this particular aspect of the development. The principle of connecting the neighbourhood centre with other areas in the development and the wider community of Crawley and Horsham however is broadly supported in design terms.

Figure 17.3 shows movement hierarchy in terms of private vehicles and parking. The primary street and secondary street concept is supported. It is useful to see where loops of development from these streets will be located. The general layout shows a good level of permeability.

Landscape Although the Landscape Architects, parks managers and outdoor play experts are best places to comment on the specifics of the landscaping & open space details the general principles of retaining green tree and hedge belts, proposing play areas, and high quality schemes is generally supported. Localised design for phase one and at reserved matters for the later phases should follow good urban design principles of natural surveillance, accessibility for all etc.

68 Key spaces The DAS outlines the design principle for the key spaces within the development and this general approach to securing good design for both the phase one and outline.

The gateway- this provides a good opportunity for transition from the dual carriageway of the A264 into the development. The road curve at this point could be a positive feature, slowing down traffic to bring it into the residential area. The openness of the site at this point, especially to the east where the “green” with the pond is provides an attractive gateway, with buildings over looking the space. The landscaping around the roundabout is distinctive. It is important to remember that with this new junction, this is not only the gateway to “Kilnwood Vale” but to the west of Crawley as approached from Horsham and the arrival point at this roundabout will be observed by just more than those living in the development, so therefore in principle, high quality attractive environment, led by quality design and not solution engineering is supported for this junction & roundabout. The gateway buildings into the site also represent the beginning of the development. At this point, the general approach to the building layout is supported.

South and north squares – general principles in these spaces are supported; they are points on a journey through the development as well as being spaces in their own right. High quality landscaping is supported, however the maintenance of these spaces should be discussed with the relevant officers from the authorities.

Neighbourhood Park – The location of the park surrounded by buildings and overlooked is supported. The evolution of the positioning of the park has enabled it to become a central part of phase 1, as well as easily located for later phases.

Axis spine – A strong legible route through the site is supported. The sequence of spaces, from north to south has an easily identifiable character. The axis is also accessed at points intersecting, making the central area of the development permeable and clearly defined. However, there are concerns over how the area around the station will function as the axis does not physically extend over the railway to the north. It is unclear from the DAS whether the view and access here will be truncated.

The Knoll – although this represents a simple way to redistribute some of the land that requires remodelling, the purpose of the Knoll is unclear apart from being part of the buffer between the A264 and the development. It does provide a focused end to the axis, but the area may end up being underused and could attract antisocial behaviour if not managed properly both through natural surveillance, policing and landscaping. I am unconvinced that the space will be enclosed sufficiently by buildings. Although studies of other spaces have been undertaken (for example market square size in relation to the existing squares, there are no examples of how this sort of space functions elsewhere. Unfortunately the large expanses of grassed areas with little purpose elsewhere on estates can unfortunately attract unpleasant behaviour, especially ones accessible by car and close to the regional road network. There is also concern over the football pitches, or rather more specifically the fencing paraphernalia immediately adjacent to houses. The open and overlooked character of this area is possibly not as strong as it could be.

The Knoll approach- the pedestrian and cycle only design for this section of the development could be successful. Careful local design at intersections needs to be controlled so that bollard type street clutter is limited. The enclosed nature of the street is aided by the positioning of the buildings around it.

The Circus – this provides a strong entrance and space between the north and south of the site, as well as an event that creates a

69 specific character. Landscaping here is expected to be of high quality. The circular nature of the space creates an enclosed character as well as an arrival point for movement. The relationship with the Market Square could appear a little contrived; historically the two type of spaces are not found closely together in organic settlements; their juxtaposition might be confusing.

The Market Square and neighbourhood centre – The general concept of a square being the centre of the neighbourhood is supported. There is concern that the scale of the buildings and size of the square has been shown in the DAS to be successful elsewhere may not be successful in his location. Using Petworth & Horsham as examples is useful, but these are town centres rather than neighbourhood centres. The example of Southwater and Bolnore are useful and their strengths and weaknesses are noted. Southwater clearly is dominated by the car and some of the space is too large to give a coherent sense of place. At Bolnore again the space is dominated by the car. We obviously do not want to repeat the mistakes of Ifield & Bewbush et al and the general principles of providing a vertical & horizontal mix of uses, residential above ground floor, central location, active frontages, accommodation of the that does not dominate the space, well defined and enclosed space and positive relationship between uses are all obvious elements that help create a successful place. Perhaps adding to these principles would enable the LPAs to have further confidence over the design of the neighbourhood centre. For example, there is concern over the western passageway leading to the car park/ side entrance of the supermarket use; of the amount of activity and overlooking from residential properties above the shops is not clear then this particular area could become problematic at night. How would the secondary vehicular access in the western side function? There is also concern over the parking/drop off arrangements for the school; at busy times the square could become chaotic. Perhaps an alternative drop off point could be provided to the rear of the site also.

Brook crossing and station square- The design strategy for the brook crossing and station square are sensible. However there should be a key space design strategy for the station square if the station is not delivered. Now would also be an ideal opportunity to set out what the design strategy for the buildings and spaces facing the brook would be. It is not only the brook crossing that is an important space, but the buildings intersecting this area facing or backing onto the brook. This space could be equally attractive. It is noted that the green spaces of bewbush Brook has been dealt with at section 18.78. Are there buildings around this space and how will the brook and the buildings interact with each other?

Other spaces- with the exception of Kilnwood Vale Park – The general design strategy for the smaller, secondary spaces is sensible and their locations supported. Much of the success of these spaces will rest with the quality of landscaping and materials used in the area. It seems logical to have formal squares with a formal arrangement of buildings around them and more organically designed spaces with looser building lines around them. The DAS also outlines the general block principles for courtyard, mews, back to backs, communal open space, sloping block etc at section 19. General the design strategy is clear, with the exception of the communal open space – the rear garden boundary treatment would need to be of such a design that the communal central space would be over looked. It would not be good design practise to have tall fences/walls etc presenting blank elevations onto this space. The space typology at 19.26 19.96 is acceptable.

Appearance (section 20) Table 20.1 sets out the building form, materials and details for the whole site. The table is clear to use and it is anticipated it will not be too difficult to use for developers of future phases. The demonstration of transition between traditional arts and crafts to contemporary style architecture is useful and it is hoped that a more forward and modern approach is taken to the architectural style of the later phases.

Phase 1 The JAAP requires a detailed masterplan and design code for each phase (4.8). In terms of phase 1, the general hierarchy of streets and layout, plus locations of squares and the main open space is supported. The side and rear elevations of mews to the west backing onto the countryside is considered to be a poor transition between the development and the countryside. There are a number of issues within these comments that should be addressed. Further comments on phase 1 plans to follow.

11/11/10 Phase 1 Firstly, I would like to reiterate that I would be happy continue a constructive discussion with the designers in order to mutually resolve any issues highlighted in these comments. At pre-application stage, the detailed discussion on phase one was cut short as the application was submitted to the councils. I feel that had discussions continued, some of the issues raised below could have either been better understood, redesigned or overcome. I have tried to put together some constructive solutions to areas of the scheme that I have suggest need readdressing, but would be happy to consider alternatives.

Layout Phase one appears too inward looking. I am especially concerned regarding the countryside edge to the west; this is unsatisfactory and presents a poor transition between the countryside and the development. I understand that the parking courts are desirable in order to remove parking from the street, and the FOGs present an opportunity to overlook the courtyards and provide natural surveillance. I also understand that the positioning of the phase 1 park have been carefully located in order to keep it central to the development as a whole, and this has a knock on impact on the road network and therefore positioning of properties; however the edge layout is still not particularly satisfactory and the preferred option would be to have a small number of houses fronting onto the countryside. There could be other options and layout alterations that may present a better transition. The termination of the street in a blank cul-de-sac outside units 210-211 is unacceptable and would benefit from being softened.

The situation of the back gardens fronting onto the hedge and tree belt to the east is also not ideal. However, compared to the western edge, the eastern side has the opportunity in the future to be overlooked from buildings in later phases. Although the land to the east is in a later phase, a solution to this issue could be a commitment to later development positively addressing the hedge line in this location. The tree/hedge belt in this location would however need to be off sufficient thickness in order for the close boarded fences of the rear gardens not to be visible. Should a commitment to this be forthcoming, on balance, this is arrangement could be acceptable.

The bridge over the brook and “island” in front of the CHP plant is an interesting arrangement that does bring some character in landform to this particular part the development. I feel it works in urban design terms, but this should not be outweighed by comments of the landscape architects and Natural England with regards the use of the landform in this way. At first glance the arrangement of the buildings on the island appear at odds with the garden suburb layout to the south, but I feel the transition over the brook allows for a different arrangement to occur. It is true that glimpses of the CHP plant will be seen through the rows of properties, but the alternative; having dwellings facing the brook then gardens facing the street to the rear would in my opinion be more awkward.

The arrangement of the access road from the junction, the green, pond and houses over looking this space aims to create an attractive entrance to the development. The landscaping in this particular area is welcomed, although it should represent a transition

71 between the countryside and the development.

At this south western entrance, the use of “gateway” buildings is supported. The legibility of the proposed streets, with the defined primary and secondary routes is aided by the use of buildings and street width in order to way find through the development. Subtle uses of changing street surfaces, orientation of buildings and use of buildings heights, bulk, typology and layout are welcomed in order to aid legibility. The north square and junction should also help with this. The desire line pathway through the park is interesting and should help concentrate pedestrians who try to “cut through”

There is concern regarding some of the rear parking courts. FOGs have been used in some places to help overlook the courts, however I am concerned regarding the safety of some of these courts and where only one FOG is proposed. Two of the parking courts (those serving 41-52 and 81-97) are a little large. It is appreciated these serve blocks of flats, however consideration should be given to their division into two or other means of reducing the size.

Apart from these, most of the layout appears sensible; there are a number of individual or smaller groups of buildings & spaces areas that would benefit from being realigned. These are bullet pointed below:

 No 21 should have an entrance onto the street to increase activity on the street, rather than via the rear  Street between 71/72 & 98/115 – accumulation of side elevations creates an unattractive street. Suggest re-positioning of some unit entrances & parking  Side street 130-136 – location of garages on the side creates an unattractive entrance to the space – suggest removal of garages/change of house type

Architectural style and individual unit details In general, the principle of an arts & crafts/Sussex vernacular style is not objectionable and taking the development as a whole is an obviously easy way to provide some transition between the countryside and the urban area. However, contemporary architectural style should be encouraged for the later phases; the DAS provides a simple section on how the architectural principles could be interpreted as contemporary in later phases. The plans submitted for the details include elevations and a helpful materials plan which gives some indication of how facing materials will be grouped together to help give a particular area character. For individual plots and street scenes, the comments below are in bullet form; again, I have suggested some alternative detailing etc. I would welcome proactive discussion on the items should that be possible:

 Plots 9-20. I feel that the use of the arts & crafts style is not particularly successful in some of the 3 storey properties, particularly for the flats, where some of the elevations appear a little cluttered and the roofs bulky.  Plots 55-66, However on these flats, the arts and crafts style has been somewhat watered down and appears a little plain. It is obvious that these are the affordable units. The transition between the three storey block of flats and the two storey properties adjacent at plots 67-71 is too abrupt. Suggest stepping down of flats and redesign of elevations. Perhaps more that one entrance may help to animate the front elevations.  Plots 180-186. This building could benefit from having a prominent entrance; perhaps a double door or larger door may help.  Plots 190-198 & 200-207 and 239- 273 These executive type homes facing the park appear too continuous and further variety in the street and house types is encouraged.

72  274- 291: the contemporary approach to these apartment is acceptable, perhaps however that future detailing on some of the elevation may help to provide interest; at present they are a little plain.

As the development is proposing traditional style architecture, traditional materials, including plain clay tiles, timber windows, timber cladding and detailing (eg bargeboards, porches, car barns, garage doors etc) local brick should be utilised. Quality materials can add to the character of the development and sustainable sources for these materials is encouraged.

Additional comments regarding the additional information submitted by the applicant 17/12/10. These comments should be read in conjunction with the additional information submitted.

Space standards Although specific standard sizes are not a material consideration, I am supportive in principle of the outcome CBC are trying to achieve, especially with regards to securing a reasonable sized dwelling and garden for the majority of the plots. Some supporting evidence outlining why other gardens have not been altered, with examples, may help officers understand the issues the designers faced in order to increase garden sizes.

FOGs Concern has been raised in regards to some of the isolation of particular dwellings in courtyards throughout this process. There is particular concern still over plots 67, 149, 155, 160, 194.

Neighbourhood centre design brief & station square design brief Although it is appreciated that CSP is willing to commit to a neighbourhood centre design brief, as this is the priority for the development, it is considered that this particular issue is too important to leave to a later date as it forms an integral part of the neighbourhood. It is however understood and welcomed that with the uncertainty of the station, a design brief for the station square would be an appropriate way forward .

CHP Noted

Bridge principles Welcomed and noted

Bus stops Understood and noted

Impact on listed building Noted; I am of the opinion that although necessary, the impact on the setting of the listed building, taking into account its already suburbanised setting, would be minimal. It is disappointing that this was not considered as part of the JAAP.

Phase 1 Numbers as per HDC response schedule

73 1. Noted 2. Although the design meeting in November explored the issues of the layout and position of the neighbourhood park and the western edge, the issues were not satisfactorily resolved and do not appear to have been addressed in this latest letter and amended plans. Although it is noted that there is an opportunity for the western edge to be overlooked in the future, there is no guarantee the reserve land will be developed. 3. The arrangement was supported on the grounds that the later phases could overlook this area and that the hedge would be robust so that views of a close boarded fence and any security issues could be mitigated. The response from CBC is noted and agreed with. This does not appear to have been addressed in the latest plans. 4. noted 5. noted 6. noted 7. Disagree that none of the FOGs are isolated. HDC, the Crime Prevention Adviser and CBC have previously commented on this particular issue at length. At pre-application stage consistent concern was raised with regards to the FOGs and this has been raised above and previously. 8. Unit 21 has its door to the rear parking court. This is an unacceptable situation as the front door would be accessed between two parking spaces without defensible space for amenity. 9. noted 10. Noted, however a simplification of this building would be welcomed. 11. Noted, however I am still of the opinion that the properties are not tenure blind. 12. noted 13. Although agreed the typology is distinct and contributes to the legibility, individual house styles are repeated too often. Suggest a further house style to be introduced to this area. 14. Please note the contemporary approach is welcomed, not the overall approach which I am of the opinion still lacks interest that could be accommodated without being fussy. 15. noted

It is also noted that the comments of the Crime Prevention Adviser have not been addressed/responded to by CSP.

Comments on additional information submitted

 There is a general issue around the footbridge at the station – some plans and text include it as structure or route but it is omitted from others. Please amend all plans and text to include it.  Please amend the DAS & other plans to illustrate the foot bridge.  The key principles as in the Open Space Strategy should be in the DAS also.  The principles in the Open Space Strategy should be transferred to the DAS design principles for this space also. The initial concern was over the overreliance of space sizes that relate well to town and village centres (Petworth and Horsham) although I agree it is useful to provide a range of types & size in order to seek out the most appropriate. The shared pedestrian central space is welcomed, but is only likely to be successful with the right level of animation and use – otherwise pressure for more parking or a totally pedestrian environment could arise.  There is still concern over the relationship of the supermarket and retail outlets to any car park to the rear.

74  The comment over the secondary access & pick up drop off is noted. These principles should be added to the DAS.  For all points relating to the neighbourhood centre, including the school and car parking, I would support either adding to the principles in the DAS to gain some clarity, or for a development & design brief for the neighbourhood centre.  I would support a development & design brief for the station square, should the station not be delivered as the currently proposed principles may need to be altered.  Please clarify in the text. At present the space does not appear to be overlooked.  As CBC point 13 response. Suggest possible views/elevations from the countryside be submitted to clarify how the development will appear from the reserve land.  I would prefer a design solution where there were views through to the countryside from the courtyards and the other routes were legible in order to dissuade people from accessing the countryside via the courtyards. A post and rail fence should be enough in order to delineate, yet not enclose/cut off.

28/02/2011 I have the following final observations:

Neighbourhood Centre Design Brief: The design principles of the neighbourhood centre have been much discussed at pre-application stage and post application stage. Officers of both CBC and HDC have raised concerns over some of the principles, including the amount of residential in the square, the access to the school and how the square may address any car parking outside. Although a number of the principles are acceptable and have been amended in the supplementary DAS information, there are areas that need to be strengthened to give a greater sense of clarity to this core and important area. In order to move forward, a constructive way of securing an appropriate set of principles would be to, by way of condition require the submission of a design brief, to be developed with the LPA and local residents, and agreed in writing, prior to the commencement of development by phase 2. I am happy to discuss the details of this condition.

Space standards: HDC do not have adopted minimum residential space standards in the form of an SPD or similar. CSP has increased some of the phase 1 garden sizes to help meet the standards of CBC, who do have adopted space standards. Taking all matters into account, including other recently approved strategic sites to the West of Horsham, the amendments to the scheme undertaken so far and the opinion of CBC, I feel it would be unreasonable for HDC to pursue this point further. Should HDC members feel that minimum space standards would be useful tool for securing an appropriate size of units and garden spaces in the future, it may be something HDC may wish to address for our other strategic housing sites and future phases of Kilnwood Vale. It should be noted that both Crawley Borough and Mid Sussex DC have adopted such an approach.

Flats over garages (FOG) /parking courts: Although throughout this process there has been no objection in principle to FOGs, there has always been concern over some of the more isolated examples of these within the phase 1 layout. It is disappointing to see that some of specifics of these previously raised concerns over units 149, 191, 194 has not been addressed. Following on from this, some of the outlook and environment around the FOGs would appear to look like a car park, rather than an active and space of character. This is especially concerning with the courts to the western boundary where they will be visually open to the countryside beyond. Furthermore gated car parking courts increase the isolation to individual dwellings and do not enable such areas to be connected to the wider community and network. A set of design principles for these areas could help secure an appropriate approach for parking courts.

Western and eastern edges:The inward looking layout of phase I has always been a concern, but officers at pre-application and application stage have listened and understood the reasoning behind this approach, albeit tentatively. A well designed and managed approach to the edges to help mitigate the issues of having rear fences onto the countryside and the tree/hedge line to the eastern boundary has always been welcomed. A compromise between a high close boarded fence (which would be inappropriate and unacceptable visually) and a secure boundary by having a 1.2metre close boarded fence and a trellis above, with landscaping to screen the fence is on balance, acceptable.

Eastern edge:The amended screening of the eastern edge is welcomed, and subject to the Landscape Officers comments, is acceptable.

Issues not addressed: Unfortunately there appears to still remain a number of issues that are yet to be resolved. Culmulatively, these and the issues identified above have a impact on the design of the development that together still is yet to meet the high standard set in the JAAP. Please refer to my comments in the previous design schedule 24.11.10. (numbering as per previous) 20. Other spaces- with the exception of Kilnwood Vale Park: Text not amended or clarified as requested

Environmental January 2010. This document provides a response to the Environmental Statement provided in support of the Planning Application for Officer Kilnwood Vale. This response has been made having taken a broad overview of the EIA as a whole, but also makes some more detailed comments on the individual chapters.

As a starting point for assessing the EIA, I have had regard to the EIA regulations and other supporting information such as the Note on the EIA directive for Local Planning Authorities published on the CLG web site1. This document provides a summary of a number of factors that the Council must take into account when considering the Environmental Statement. Of particular importance is the point that “The authority has to ensure that it has in its possession all relevant environmental information about the likely significant

76 environmental effects of the project before it makes its decision whether to grant planning permission.”

EIA Content In general, the Environmental Statement contains sufficient information to meet the requirements of the EIA regulations, for example addressing alternatives and examining permanent, temporary and cumulative effects over a range of environmental issues. Nevertheless there are areas where further information will need to be provided by the applicant in order for the Council to be in a position where it is in possession of all relevant environmental information. These concerns are addressed in turn below:

ES / DAS Parameter Plans It is understood that the Parameter Plans contained in the EIA are for the purpose of modelling the maximum parameters of any development (in effect a worst case scenario), whereas the plans that would be listed in any decision notice would be those in the DAS.

Whilst technically this should not be a problem (as issues set out in the DAS should have a lesser environmental impact), it is considered that the greater detail contained in the DAS has not been transposed into the Environmental Statement. The ES parameter plans are therefore not necessarily the worst-case scenario suggested. For example, the Land Use Parameter Plan in the ES (Fig 2.6) does not separate the location of the employment land from the neighbourhood centre and car park, unlike Fig 15.1 in the DAS. There is therefore the potential that this greater level of detail could generate a more severe environmental impact than predicted in the Environmental Statement. For example the precise location of the car park, could in combination with the precise topography at that site result in greater rates of run off than predicted with the more generalised layout. Furthermore the Land Use Plan in the ES also indicates that some areas green space are larger that those contained in the DAS layout. This could result in the assessment of the impacts of open space being overstated.

For outline applications, case law requires that any permission is 'tied' to the environmental information in the ES. If, as outlined in the paragraph above more detailed information has become available and these impacts have not been fully assessed as part of the EIA the Council may be in a position where it cannot permit the application, as the subsequent reserve matters applications and statements of conformity with the Environmental Statement would contain different information to that which is currently set out in the ES. To rectify this problem, it is suggested that the ES is reviewed and updated where necessary to take into account information submitted as part of the application that has not been tested through the EIA process.

Once the Parameter Plans have been agreed, and any necessary amendments made to the ES it is suggested that the following condition be used to ensure that the application and ES remain tied - 'The development on this site shall be carried out in substantial accordance with the layout included within the parameter plan(s) entitled ‘xxxxx’ submitted as part of the application and shown on yyyyyy’. Reason: 'The layout of the proposed development is the subject of an Environmental Impact Assessment and any material alteration to the layout may have an impact which has not been assessed by that process.'

Level of Detail within the ES Whilst the majority of the information contained within the Environmental Statement is considered to be sufficient to enable an assessment of the likely environmental effects, there are two areas where this information is considered to be lacking. These are as

77 follows:

Proposed CHP plant As has already been indicated, an ES for an outline application must contain sufficient information to enable the determining authority to assess the environmental effects of the development prior to granting permission. Case law has demonstrated that it is not sufficient for this information to be provided at a later date via a planning condition.

The lack of detail in relation to the proposed CHP plant therefore limits the ability of the Council to take into account all the significant effects it may have before granting planning permission. Whilst the ES indentifies where the plant would be sited, it does not give any indication as to its likely design, the precise nature of its fuel or emissions or likely levels of noise during operation. Furthermore, the ES indicates that the stack from the plant could be as high as 60m, yet there is very little detail in the landscape section as to how this might appear from the surrounding landscape, and in particular from the nearby AONB. It is therefore considered that a greater level of certainty as to the nature and type and scale of the CHP plant needs to be provided before the likely impacts of this element of the scheme can be taken into account with any level of certainty.

Landscape Issues In addition to the issues raised by the Landscape Architect, I would wish to add the following remarks in relation to the EIA.

Firstly, landscape fails to meet the requirements of the EIA directive as it does not address the temporary impacts (e.g. cranes) which may be visible during the construction phase. Whilst it may be that these impacts are not considered to have any significant effects, it is still necessary to provide an explanation as to why this issue has not been considered in any great detail.

Secondly, I note that ES does not provide any photomontages illustrating the impacts of the proposed scheme. CND stated their intention to provide this in their Request for a Scoping Opinion, and this approach was supported in this Council’s response. The absence of these images from the ES is therefore of some concern, as without such images it is difficult to get a sense of how the new development may appear. These images would also assist in understanding how the proposed knoll and stack from the CHP plant may appear within the surrounding landscape. These images should therefore be provided, as set out in the Scoping Report, in order to ensure that the Council is provided with a complete set of data required.

Other Remarks In addition to the comments set out above, the following more detailed comments aim to indicate where further discussion, work or planning conditions may be necessary, or where potential inaccuracies exist, which should be taken into account when considering the Environmental Statement.

Chapter 6 – Sustainability and Climate Change Given the discrepancies between the DAS and the ES, it is considered that some of the positive impacts identified in this section are overstated. For example the area allocated for allotments set out in the DAS will not provide sufficient plots for all residents, and it is unlikely that food miles and consequent carbon emissions will be significantly reduced. Additionally, there is no guarantee that the low energy light fittings provided will be retained, resulting in an overly positive outcome from this section of the assessment. .

78 Chapter 7 – Socio Economic and Community Impacts The results of this section are broadly acceptable, with the exception of the point that the health care provision will be ‘moderately beneficial’ over the existing baseline. Any development must make land available for health care and open space at a level required to meet the expected needs of the new community. Whilst preventing adverse pressure being placed on existing infrastructure, the level of provision is not over and above what would normally be expected (which would result in a positive impact), and the impact of providing this new infrastructure should therefore be amended to neutral.

Chapter 8 – Ground Conditions, Land Quality and Remediation This section is generally considered to contain sufficient information to enable the level of contamination on the site to be taken into account as part of the ES. I note however the comments made by the EHOs, and agree with the need to ensure ongoing monitoring which will help ensure that future residents are not exposed to any localised patched of contaminated ground that may remain.

Paragraph 8.3.53 makes reference to the presence of Japanese Knotweed on the site, but states that as it will be removed it does not form part of the baseline. This statement is strongly disputed as the baseline is the current situation as to what is present on the site. Furthermore, the removal of this species is strictly controlled and it is noted that as it is no longer intended to remove much material from the site and to use it for re-modelling the risk of spreading this species is increased. Given that the spread of the species prohibited by law the ES should be amended to clarify the current extent of the species and how it is intended that it will be removed. I note that the Environment Agency have suggested a condition regarding this species which will help to address this matter.

Chapter 10 – Ecology and Nature Conservation Generally this section is considered to have adequately assessed the likely impacts of the development on the ecology of the site. It is however noted that since the submission of the application, a local resident has submitted evidence suggesting the presence of Great Crested Newts. Having seen the response on this matter by the County Ecologist I am in agreement that pond is not likely to be suitable habitat. It may however be possible that the pond to the north may be more suitable, although the lack of vegetation in this pond would limit its attractiveness to this species. Whilst there is not reason to doubt the integrity of the 2008 surveys, the new information will need to be addressed, although recent case law limits the ability of the Council to use planning conditions in this regard.

Chapter 12 – Transport and Access I note that there is currently a holding objection from the Highways Agency and following the receipt of their final comments it may be necessary for the EIA to be updated to address any issues that they raise.

Chapter 13 – Noise and Vibration My primary concern in relation to this chapter is the lack of information relating to the proposed energy centre means that it is not possible to predict the effects that may arise with any certainty. Although mitigation measures are suggested, there is no guarantee that they will be sufficient to off-set any negative impacts. As has already been indicated more detail will need to be provided on this matter in order to enable to Council to take these effects into account fully when considering the application. In addition, further information will also need to be provided to meet the concerns identified by the Environmental Health Officers in relation to other noise and vibration impacts.

79 Chapter 14 – Air Quality As set out earlier in this response, it is necessary for the applicant to supply further detail regarding the likely emissions from the CHP plant and its potential impact on air quality.

Chapter 16 – Cumulative Impacts It is broadly considered that the information contained within this section is sufficient to meet the requirements of the EIA to address this issue.

The Environmental Officer is satisfied that the additional information submitted addresses the concerns as raised above.

Engineering The Surface Water Drainage Strategy proposals described within various sections of the Environmental Statement outlining the regime of Sustainable Drainage System (SuDS) Areas and features will accommodate this development and should pose no increased flood risk.

Therefore until detailed drainage design schemes and SuDS maintenance responsibility arrangements are submitted I have no further comments to make on this Outline Application.

Public Health and Land Contamination Licencing As highlighted in the Environmental Statement the site has been subject to extensive and continuing ground investigation and monitoring work. Generally it is concluded that the site can be rendered suitable for residential development provided that the following conditions be attached to both the full and outline permissions:  A Method Statement detailing the remediation requirements, including measures to minimise the risk from ground gas and impact on controlled waters, using the information obtained from the Site Investigations shall be submitted to the Local Planning Authority (LPA). The method statement shall be approved in writing by the LPA prior to that remediation being carried out on the site.  Development of the site shall be carried out in accordance with the approved Method Statement.  If during development, contamination not previously identified, is found to be present at the site then no further development (unless otherwise agreed in writing with the LPA) shall be carried out until the developer has submitted, and obtained written approval from the LPA for, an addendum to the Method Statement. This addendum to the Method Statement must detail how this unsuspected contamination shall be dealt with.  Upon completion of the remediation detailed in the Method Statement a report shall be submitted to the LPA that provides verification that the required works regarding contamination have been carried out in accordance with the approved Method Statement(s). Post remediation sampling and monitoring results shall be included in the report to demonstrate that the required remediation has been fully met. Future monitoring requirements and reporting shall also be detailed in the report. Noise There are significant concerns in respect of noise information submitted. In particular the noise modelling presented in the Environmental Statement is indicative at best and does not give any picture of how the physical layout of phase 1 will affect the noise exposure of future

80 occupiers. There is no detailed consideration of the potential noise impacts of the Western Relief Road. Although sections 13.5.21 and 13.6.6 of the Environmental Statement identify that a noise barrier similar to that proposed for the southern boundary of the site may be required, no further information is provided.

Despite the construction of a noise bund it is clear from the noise maps submitted that the southern part of the proposed phase 1 development area will be adversely affected by noise. The detailed design of the proposed phase one development shows that the majority of residential units most affected by noise from the A264 and future Western Relief Road will have the bedrooms located on the nosiest facades. The floor plans submitted for these units do not follow the advice quoted in paragraph 13 of PPG24. Gardens and other outdoor amenity spaces subject to noise levels in excess of 55dBLAEQ should be regarded as offering a poor level of environmental amenity. The lack of any detailed noise mapping does not allow any assessment of the number of dwellings or amenity spaces that will be affected by adverse levels of noise.

Section 13.5.7 of the Environmental Statement recognises the importance of design in protecting gardens and amenity spaces from noise. It is considered the same principle should be applied to the designing the internal layout of the proposed dwellings. Compared to other assessments completed for similar sized developments affected by transport noise the information submitted is considered to be insufficiently detailed to allow proper consideration of those elements of the application for which full permission is sought. . With respect to the issue of noise from the Energy Centre and other commercial, industrial, employment or utility infrastructure uses there is not enough detailed information to reach any definitive conclusions. The presence of the residential properties close to these areas is likely to prove a significant constraint. Although the adoption of the noise target of 10dB below background noise levels for fixed plant in section 13.5.9 is welcomed, it is considered that the issue of noise from non–domestic premises should be subject to further scrutiny once detailed development proposals are received.

Construction Noise The impact of construction noise is best managed by the requirement for an environmental management plan. Accordingly it is recommended that the following condition be attached: The applicant shall prepare a Construction Environmental Management Plan that shall incorporate the measures to mitigate the noise and vibration from construction including those measures identified in sections 13.5.1 to 13.5.4 of the Environmental Statement. The Construction Environmental Management Plan shall be submitted to and approved in writing by the Local Planning Authority. The requirements of the Construction Environmental Management Plan shall be met for all works associated with the construction of the proposed development.

Air Quality and Odour It is not considered likely that any significantly adverse air quality or odour impacts from the development will occur within Horsham District. For the proposed Energy Centre it is considered that the details contained within the Environmental Statement are not sufficiently detailed to allow a full appraisal of the air quality impacts of atmospheric emissions. Accordingly the requirement for further air quality assessment of the impact of emissions and any necessary mitigation should form part of any submission for detailed permission for the energy centre.

With respect to dust emissions it is recommended that appropriate measures to control dust emissions including those detailed in Section 5 of appendix 14.2 of the Environmental Statement be incorporated into the Construction Environmental Management Plan. The scale of

81 the development together with the proposed public transport infrastructure offers an opportunity to develop a Low Emissions Strategy for the site which would offset some of the construction and operational air quality impacts. Measures could include requiring use of construction plant and vehicles that comply with current emission requirements, discounted parking charges for residents with cleaner vehicles and subsidised public transport for residents.

25/11/2010 From my initial look at the maps (additional information submitted) I am quite concerned about the noise levels for the phase 1. It’s clear that for a significant number of dwellings it will be necessary to rely on attenuated ventilation in order to maintain satisfactory internal noise levels. While it’s true PPG 24 “allows” development in NEC B I would point out that iIn the description of NEC category A in Annex 1 to PPG24 it states that “…the noise level at the high end of the category should not be regarded as a desirable level”. In addition clause 13 to PPG24 recommends a range of approaches to mitigate noise that may affect proposed development while clause 14 recommends early consultation between applicants and local planning authorities.

In many respects PPG24 is now out of step other guidance, particularly the WHO guidance issued in 2000 and 2009 as well as the review conducted by Bernard Berry for the DEFRA sponsored Interdepartmental Group on Costs and Benefits of Noise subject group. In assessing the amenity offered by the proposed development simple reliance on the criteria of PPG24 could be regarded as questionable.

23/02/2011  There appears to be no mention of the discussion concerning re-orientation of the internal layouts of the plots indentified.  I can’t see the objection to measuring the performance of the barrier at night. None of reasons quoted are insurmountable.  The comments in respect of the accuracy of the noise modelling are noted. However from my recollection it was the accuracy of Soundplan in respect of PPG24 that was under discussion with a potential margin of error of up to 25m in the modelled contours.  In my opinion it is a bold statement to state that a particular requirement would not be considered reasonable. I would argue that the suitability of this part of the site for development depends on the noise barrier. The plans showing noise levels on first and second floor levels demonstrate this. Therefore it is only prudent to ensure the barrier performs as predicted. Such a condition would be relevant, technically feasible and necessary. As I have stated before much of this debate could be resolved if the internal layout of the affected plots were to be rearranged so that bedrooms were not overlooking the A264, particularly for those units that derive least protection from the noise barrier.  With respect to the CHP plant/Energy Centre the additional detail helps but it is clear that the selection of technology for the CHP plant/Energy Centre will be constrained by the proximity of residential development and the resultant noise targets. At this stage it is not clear how significant ancillary noise such as fuel deliveries etc will be.

Building Control The purpose of these comments is to highlight areas for further consideration at detailed design stage to ensure the development proposals can comply with the requirements of the building regulations.

Vehicle access

82  Within the street hierarchy do the surface finishes and design criteria allow for Fire Brigade and Refuse vehicle access to all residential properties?  A review of the Phase 1 detailed layout shows the following plots may be problematic in achieving compliance o Plots 132-135 o Plots 253-257 o Plot 239

Site Layout  Does the site topography require any plots to be considered for stepped approaches?

Drainage design  Pumped drainage systems should allow for 24hr storage capacity to allow for disruption in service.  Capacity of balancing ponds to accommodate surface water drainage to be verified.

Sustainability  The approach to sustainable design will meet the minimum standards required within the 2010 Building Regulations.

CRAWLEY BOROUGH COUNCIL

Urban Design Comments were made by the Crawley Urban Design Manager prior to the submission of the application. For the purposes of this Manager consultation document those formally submitted as part of the application process only are set out below.

Comments received 06/10/2010 Thank you for consulting me on the above proposal. My initial comments on the Design and Access Statement are as follows and are all submitted as Officer comments on a without prejudice basis: - 1. The purpose of a DAS at the outline application stage is to establish the principles that will guide the development and to demonstrate, typically by reference to examples, how these principles will ensure good quality. The ‘fix’ required at the outline stage is one of quality not detailed design, as other interpretations may prove equally acceptable if they meet the quality standard. This means that none of the information provided in the DAS should be regarded as merely illustrative. 2. The various statements regarding bus and generally pedestrian, cycle and equestrian links and access to other services and facilities (e.g. DAS paras 3.3, 6.43, 12.7, Figure 17.1) are not supported by the proposals that could be delivered within the submitted application boundary. The provision of sustainable transport cannot, therefore, be relied on and the proposal set out in the outline application does not constitute a sustainable, integrated form of development. The detail of, and the means for securing, these linkages needs to be made clear. For example, arboricultural assessments should extend beyond the application boundaries to encompass areas that would be affected by off-site works. 3. The future responsibility for the management of Ancient Woodland within the site, under a ‘conservation management plan’

83 4. The DAS does not identify or set out the impact of off-site highway improvements referred to in paras 5.47 and 6.43. Any works to the junction of the A23 and A2220 may affect an adjoining listed building or its setting. 5. Footpath and cycle links to Ifield and Bewbush should not be viewed as leisure routes and need to be safe as part of being ‘good’ (para 5.50) – are links identified elsewhere included in detailed proposals? Links need to be safe to facilitate/accommodate use of the station, shops and facilities from adjoining neighbourhoods and to reduce the risk of crime. Without safe links, the scheme cannot claim to be integrated. 6. Figure 6.2: Engineering Constraints Plan identifies 6 possible sustainable transport links from the development into Ifield and Bewbush, which would either not be provided as part of the scheme or would not integrate well with adjoining development (Does the southern equestrian link already exist?). The indicated pedestrian, cycle or equestrian links to the north (e.g. Figure 13.3) are not shown as connecting to the wider area (e.g. Figure 14.1). 7. There is a lack of clarity regarding public (i.e. not passenger) access across the railway station footbridge. Whilst there may be management issues regarding free access, without it the walking distance for residents in the centre of the site, north of the railway, for example, to the neighbourhood centre would increase from 400m to approximately 1.2km. This distance would be unlikely to encourage walking, use of the centre shops and integration. The lack of pedestrian permeability does not support the statement in section 17.1 regarding less direct access for private car drivers. The need for a lift suggests that access would be limited and a clear and attractive alternative route for pedestrians would need to be provided. 8. ‘As the crow flies’ distances shown in figure 13.2 do not represent the reality of what walking distances would be when the scheme is complete, particularly given the barrier of the railway and should not therefore be used. 9. The number of dwellings proposed for the neighbourhood centre is low at 16 units, particularly as the centre would comprise an enclose square rather than a high street. Whilst an elderly care home may be appropriate it is not clear whether this use will help populate and provide effective natural surveillance over an enclosed neighbourhood centre square. The suggestion of residential use over the supermarket is too vague although it appears to work well at Southwater village centre, which is assessed in the DAS. 10. Landmark buildings (16.1). These features should aid legibility but no guidance is provided indicating where these should be visible from e.g. how easy would it be to locate the neighbourhood centre from key decision points? 11. There is limited information in the DAS regarding the landscaped noise attenuation bund adjacent the A264. 12. How will character info on other areas and neighbourhood centres be used? 13. The Design Concept (Section 12) does not refer to how the scheme would address the countryside to the west. 14. The schedules within the Hybrid Application setting out garden size and gross internal floor space for each unit have not yet been assessed. 15. The proposed building heights of 15 metres to the highest part of the roof structure for 3 storeys and 18m for 4 storey landmarks are high do not represent a credible height restriction. Clarity is needed as to whether these are parameters test heights rather than potential actual building heights. 16. The building parameters table (Figure 16.2) if confusing in respect of the figure relating to ‘Y’ and the purpose of the inclusion of a ‘Z’ dimension is unclear. 17. Will the scheme provide a footbridge and Fastway terminus even if the station is not provided? 18. The pedestrian and cycle movement plan (Figure 17.1) indicates that the secondary foot/cycle routes do not extend beyond the bus gates, reducing sustainable transport benefits. The equestrian route would have a large gap in it which is not explained. As integration is a key requirement, it would be helpful for drawings to show off-site rights of way to demonstrate

84 19. Paras 17.9 and Figure 17.2 indicate that the Circus is part of the central bus interchange. This possibility is excluded by the Key Space section. 20. Para 17.40 suggests that the secondary access would include a right out lane? In addition the right in lane does not appear to be very long. Could this result in queuing onto the A264? 21. The Woodcroft Road bus gate appears to make alternative provision for lost resident parking. The cost of this parking should be included within the S106 agreement? The delivery mechanism should be made clear. 22. One of the key objectives of the landscape and open space strategy is to create legibility by having different parts of the site have very different characters. These Character Areas are not clearly set out in Paras 19.13 to 17 which could lead to the creation of a monotonous development. Density alone does not dictate character and further guidance should be provided. 23. The key spaces information should be consistent in terms of the information provided. For example, there should be information regarding storey heights, scaled plans and the quality/clarity of the illustrative perspectives varies greatly. In some cases, such as Brook Crossing and Station Square, the sketches are too vague to act as a quality benchmark for the whole space. Without scaled plans it is not possible to establish the physical extent of the spaces in detail or whether the spaces would be deliverable, for example because they do not show how resident parking and private amenity space would be accommodated. 24. The Gateway formal circle of trees extends south of the new A264 roundabout, which is possibly too far as the space is about more than an entrance to Kilnwood Vale. However, this more extensive treatment may have a traffic-calming effect on drivers heading east. A high quality landscape treatment of the acoustic bund is necessary in terms of visual impact and welcomed. There should be stronger justification for the avenue of trees which extends further into the reserved land as this could simply interfere with an attractive, wider view. 25. The DAS does not include any detail or perspectives regarding the pond and green or the northern attenuation feature. 26. The North and South Square plans and the related perspectives do not correlate with each other, particularly in terms of trees, and the relevance of the photos is questionable. Whilst the proposals are attractive, these areas are proposed for adoption and a low maintenance design is likely to be required. This comment could apply to other key spaces including the Greenway Squares. 27. The term ‘neighbourhood park’ is confusing as it could also apply to Kilnwood Vale Park. The landscape treatment at the south-western corner, with trees enclosing the path and adjoining side boundaries and private parking and secluded seating areas, may not form a safe route in the evenings or at night and the area could become a focus for anti-social behaviour. 28. The Axis Spine should have a role to play in terms of legibility as well as providing a vista. Legibility may be an issue regarding vehicle and pedestrian journeys across the railway line. The southern section of the spine appears to be private (Figure 18.45). Whilst there is strong support for the use of a spine as an ordering urban design concept for Kilnwood Vale, there are significant doubts that the obvious, but not clearly expressed, benefits of vista, legibility and linkage could be achieved without modifications. This is because the station pedestrian bridge is on the route of the spine and is unlikely to offer 24/7 pedestrian, cycle, push and wheelchair access. Alternative routes are available but would be flawed in terms of their legibility and convenience. This will lead to newcomers and visitors losing their way and residents resorting to their cars. In this case, where the desire line is unlikely to be feasible, other than for rail passengers, the vista could be maintained but the urban design should act as a guide to the alternatives and these should be convenient. 29. Suggestions in the Design Strategy regarding ‘intrigue’, where for example buildings would be paced on top of the axis, could undermine legibility and this should be the over-riding test/guideline for any detailed proposals. A pedestrian view perspective

85 30. The central orientation feature proposed is welcomed but the indicative needle would be two thirds the height of the Dublin Spire and might cost, on a pro rata basis, £2.2m. The public art statement (Para. 20.16) is insufficient a guarantee that art would have any real role to play in any of the phases of development. Index linked sums of money per phase, via a S106, would provide a robust mechanism. A cross reference to other statements that provide this information would be helpful. There appears to be no commitment to public art in Phase 1 which includes the main entrance to the scheme. Where would the parking be located for the Circus dwellings? A small area of defensible space should be provided in front of dwellings around The Circus? 31. The neighbourhood centre would take on a different form to that found in other centres within the town, comprising the neighbourhood facilities closely focussed around an enclosed square split/animated by a main road. Whilst the provision of the mix of uses is welcomed, the information provided raises a number of concerns: -  The proposed shared space parking area is likely to be chaotic at the beginning and end of the school day, with small children mixing with manoeuvring cars. The car park would be split creating a number of separate parking areas with parents etc. competing for the limited number of convenient spaces and queuing blocking potentially the only vehicular access across Bewbush Brook. A similarly difficult car park layout can be found at the Gales Drive centre. An alternative school drop-off point for cars should be provided.  There would be a total lack of parking spaces for other uses or customers around these times. What parking and access restrictions would there be with respect to the food store car park?  The vehicular route and junction arrangements to access the food store, possible filling station and employment area have not been made clear.  Being enclosed, the resident population of the centre would be limited to the uses above the small shops. There is no commitment to providing additional units above the food store, as provided at Southwater. The proposed vertical mix is limited to the short row of shops. Whilst there is a proposal for a care home, this does raise a question mark regarding natural surveillance and activity around entrances and within the square. A commitment to additional dwellings should be demonstrated.  The food store is likely to have its pedestrian entrance along its northern elevation and this is likely to result in an inactive frontage onto the primary street. This elevation be ‘wrapped’ with another, more active use, or there should be a clear commitment to the provision of active (not just architecturally interesting) frontages?  Notwithstanding the potential positive contribution to the square, would the neighbourhood centre provide sufficient custom to support a food-based pub?  Pedestrian access from the food store car park to the square would be via alleyways which would be unattractive and not just after dark. The small row of shops would not address the main pedestrian flow, which would run east to west, and food store customers would be addressed by the rear and service areas to these premises. The shop could be rotated to face south and a more generous pedestrian link, with a corner unit also addressing the square.  The perspective illustration has been too tightly drawn around the building enclosing the square to aid understanding or rear service, parking, gardens and relationships with adjoining dwellings.  The food store car park would not be an attractive space and would have development backing onto it rather than addressing it.

86 32. There is no mention of the quality of the bridge within the Brook Crossing and Station Square key space information. Sections through the extent of the illustrated key space should be provided to demonstrate the changes in level proposed. Would the developer have control over the design of the station as suggested by the sketch? Where would the transport interchange be located were the station not to proceed? A legible, safe alternative pedestrian route should be provided if the station footbridge was not to be made available to non-passengers 24 hrs a day. The design of the area north of the bridge directs visitors towards the station but does little to guide people to the bridges over the railway. The development proposed adjacent the Brook bears little resemblance to that shown in the design testing sketches (Figures 11.10 and 11.11) and there is insufficient information provided regarding its quality. Would a café/retail use be proposed as part of, or adjacent, the station? 33. Would shallow defensible planting spaces be appropriate in front of dwellings in and around the Terraces Square? 34. The Viewpoint section of the DAS should refer to the development around the space. The proposed pitches would be crammed in to the detriment of neighbours, players and spectators and would perhaps be better as an unmarked green or a single pitch. 35. The Kilnwood Park area of the site would not facilitate direct and safe access from the northern section of Bewbush to the station. A footpath north of the Brook with a bridge connection back into the north western corner of Bewbush would, with off- site works as the area may be subject to flooding, create a supervised route compared to that proposed along the edge of the park. The illustrative plan (Figure 18.27) does not show that the indicated path link to Bewbush would be through wooded areas which would not offer a safe route and could not be regarded as fulfilling the integration requirement of policy. 36. It is not clear how the Informal Square would aid legibility, as claimed. 37. It is difficult to assess the quality of the buildings around Greenway from the illustrative perspective. 38. Has the palette of landscape materials (Para 18.88) been agreed with the Highway Authority? Figure 18.45 indicates that the SUDS would be offered for adoption. Has this been agreed with the Highway Authority? 39. Should the western bridge and approaches be regarded as secondary streets? 40. Why are there so few key spaces north of the railway and no special frontages to the south?

41. Residential block principles – general points: -  Is it helpful that they are generic and therefore open to being challenged by developers?  Where would these typologies be found in the new neighbourhood?  How would they reflect their particular character area?  The plans should be scaleable to be of use.  The layouts rely too heavily on unsupervised rear alleyways to service rear gardens which may become blighted by lack of ownership, anti-social behaviour, crime and dumping and are unlikely to be popular with future residents/purchasers.  There needs to more than just consideration to servicing and storage, in some instances the need to use rear gates would result in long and inconvenient journeys with bins and siting 3 large wheeled bins at the front would take up most of the front garden and would be a streetscene disaster. Similarly bike storage where garages are not provided needs to be thought through and accommodated.  The minimum size of garages is welcomed.  The reference to high quality materials is too vague and examples would be helpful.  Front entrances should be placed on side elevations where these would be adequately surveyed. Similarly, surveillance within courtyards should be provided by more than one dwelling to prevent residents of these units becoming victims of crime

87  There are few references to solar orientation.

42. Courtyard – there would appear to be a lack of natural surveillance over the internal parking areas which may also provide easier access to unwelcome visitors to rear gardens, particularly where alleys would be created. Increased back to back distances are likely to be required where buildings are above 2 storeys and the distances should be specified. It would be for the designer to justify departures. The diagram could be used to justify some very small gardens that would not be fit for purpose. The materials for prominent boundaries should be set out. Street lighting provision? 43. Mews – again back-to-back distances for all likely storey numbers should be set out. Cars should not only be visible from upper floors if these would be too distant to offer natural surveillance or influence behaviour. 44. Communal open space – the indicated principle of small gardens is unlikely to be acceptable as these would not be fit for purpose. Physical means of securing the private communal space are likely to be necessary to prevent anti-social behaviour. How will these spaces be managed and maintained? 45. Sloping block – the diagram suggests that, apart from on the southern-most route, there would be limited active frontages to east-west routes. The central east-west route would be dominated by gables, side boundaries and unsupervised parking and the northern route by buildings which may turn the corner but would be too far apart with a frontage that does not generally address the countryside. Why would a developer provide an additional open space? 46. Car park typologies – the cut out or drive through appears to create an unsupervised area that may provide easy access to cars, rear gardens and doors or windows on side elevations. Rear courts are mentioned twice. Integral garage – what is a doubled fronted bay window (height)? 47. Space typologies – indicative trees species would be helpful. All street sections should be indicated on the associated plan. There are no indications of the range of front garden depths shown on the plans which could lead to minimal provision to the detriment of different but legible characteristics. Would shared surfaces be limited to certain numbers of dwellings or are they meant to be shared spaces?

48. Appearance – the materials strategy refers to the adoption of a “restricted and wider colour range”? Whilst there may be general support for the idea of a local colour palette this is unlikely to extend across materials as render or weatherboarding painted a terracotta colour is unlikely to be acceptable and would omit the important textural characteristics of vertical tile hanging. With regard to public art, both Councils have been active in this area and would welcome the opportunity of being involved.

49. Building form, materials and details  The references cited would only be acknowledged in superficial terms and the use of terms such as ‘inspired by’, ‘redolent of’ and ‘underlying recessive influence’ is not justified by the resultant forms, architecture and choice of materials.  Roofs with a minimum pitch of 35 degrees have nothing to do with Sussex vernacular architecture but more with Georgian, Victorian and Edwardian pattern book development and second half of twentieth century volume house building. Similarly, slate on steeper pitch roofs would be uncharacteristic.  Information relating to frontages is vague e.g. gaps will ‘vary’ and ‘significant variations in building line and gaps’ and

88  The Urban Form and Structure Plan (Figure 19.1) indicates that there would be a number of occasions where there are open space edges which include prominent corners and so, where this occurs, both building faces should be active.  The proposal for clipped gables and for 200mm boxed eaves everywhere is not representative of Sussex Vernacular or Arts and Crafts architecture. Hips are a key roof shape and bonnet hip tiles a key detail.  The proposals for porches within cat slides would be attractive but should not create deep recesses that would create opportunities for crime.  The term ‘flat roof’ gives not indication of materials or appearance.  The use of slate ‘occasionally featuring’ is too vague and should relate to building form and urban design not a desire to sprinkle ‘variety’.  Key characteristics of vernacular plain tile roofs are texture, irregularity and colour. A precise clay product is often used but rarely captures the characteristic appeal of a traditional roof. For example, a Redland concrete ‘Heathland’ may be preferred to a ‘Rosemary Clay Classic’. Differential weathering often creates darker roofs and lighter vertical elements.  The string course guidelines do not apply to three storey block of flats?  The schedule makes no reference to brick bonds, balconies, bargeboards and boundaries.  In terms of building form, the areas behind the key streets and frontages should presumably be guided by the Residential Block Principles. The wording used implies ‘anything goes’.

50. Illustrative Tile and Elevations – a key requirement is for alternative schemes to match the illustrative material in terms of being high quality (Para. 21.3).  Most of the text relating to the Primary Street is concerned with The Axis.  Figure 21.6 does not appear to relate to a Primary Street. The almost random use of porch and gable finishes to Plots 68 to 71 seems to refer more to mock incremental development rather than a planned garden suburb. Additional guidelines are necessary.  The Secondary Street – Special Frontage illustrative block tile does cover the whole block and includes an open space that is unlikely to be provided.

51. What will be the initial pedestrian/cycle link route between Phase 1 and Bewbush? It is concerning that there will be no bus or main link until Phase 3, by which time there would be around a thousand residents, some of whom would have been living in the neighbourhood for at least 5 years. A paved pedestrian link at least should be provided as part of Phase 2, preferably with a minor adjustment to phasing boundaries. 52. Quality of actual buildings around key spaces? 53. Where would the supermarket vehicular access be? 54. Are there a finite number of dwellings proposed as the figures seem to vary by quite a margin? 55. How would the development address trees to the north of the site? Rear gardens would not be acceptable.

Phase 1

89 56. Phase 1 – the boundary excludes the access and is not consistent with the boundary shown on the Phasing Plan (Figure 24.1). 57. The Urban Design Strategy (Section 29) includes the entrance pond area, northern attenuation area and the park as important spaces but there are no guidelines included within the DAS. The DAS appears to focus on spaces enclosed by buildings. 58. Are any controlled pedestrian crossings proposed for the primary street e.g. for children in the vicinity of bus stops? 59. The specified height limit for 3 storey dwellings is excessive at 15 metres (para 33.1). 60. The logic for including 2.5 storey buildings within the south-eastern corner of the phase is unclear. 61. Materials often have a link to built form e.g. roof shapes and pitches and to architectural styles. The use of slate combined with render or weatherboarding is not supported by vernacular examples such as Arts and Crafts and the traditions of West Sussex. The use of early twentieth century suburban forms, wrapped in uncharacteristic materials would create an unconvincing ‘New England waterside’ theme. 62. The introduction of slate within tiled areas, particularly terraces, appears to be seeking to convey fake incremental development and ‘interest’. A range of treatments to front gables within terraces would similarly appear as fakery. There is sufficient variety in terms of materials, scale, form and architecture to make this approach unnecessary whilst a degree of cohesion is, however, important. 63. The inclusion of arched openings to car ports gives undue status to this element and undermines the importance of front doors. The arch is then weakly enclosed within a catslide. The house type which includes an integral double garage takes the approach of underplaying the front door to the extreme and gives too much prominence to the garage in the streetscene. 64. Notwithstanding the need to secure Phase 1 during Phase 2 works, care should be exercised to ensure that Phase 1 buildings properly address links into Phase 2 when it is complete. For example this could be achieved through windows to side elevations, high quality treatments to prominent boundaries and planting, including defensive shrubs where appropriate. 65. The distance to bus stops and the neighbourhood centre should be measured along actual routes, not ‘as the crow flies’.

17/11/2010

1. Comments related to the submitted schedules have considered dwelling sizes and the relationship between dwelling and garden sizes have been submitted separately. In summary: -

a. Internal space standards Flats  Nearly all the flats, whether affordable or not, do not meet the CBC standards.

b. External space standards Houses  50 houses meet the external standards by + or - 10%  66 houses exceed the standards by more than 10%  94 houses fall below the standards by more than 10%

90 Flats  7 flats meet the external standards by + or - 10%  7 flats exceed the standards by more than 10%  67 flats fall below the standards by more than 10% (generally by around 80% as flats to the south of the water feature would be provided with little or no private amenity space)

Way Forward  Internal space shortfalls in respect of affordable units may be picked up if the grant route is being pursued.  Flats are generally deficient in terms of both internal and external space and changes to the layout would generally be necessary to address this. These changes are generally likely to affect the final number of units.  There is scope to reallocate garden space from plots which exceed standards to plots which are deficient.  Changes to the layout are also likely to be necessary to address other pockets of garden under provision.  The aim of these comments is to secure private gardens that are fit for purpose and can contribute to the attractiveness of the area, for example by providing space for trees to reach a positive size. Currently views across rear gardens such as Plots 161 to 164 and 166 to 169 would be unattractive and probably cluttered with sheds etc.

2. Dwellings above garages (FOGs) are an efficient use of land which creates natural surveillance but the needs of that future resident need to be carefully considered in relation to security and quality of life, including isolation and external environment. This has not been addressed in respect of the parking courts along the western edge of the development.

3. The number of areas that would be parking dominated has been reduced but this remains a problem in areas including the flats at Plots 9 -20, the street beside Plots 71 and 72 (outlook from Plot 98), which exacerbated by side elevations and boundaries, and the affordable housing cluster at Plots 210-225.

4. The parking area to the rear of Plots 166 to 170 and 197 and 198 would create a visible but unattractive rear service area rather than the courtyards to be created elsewhere. There would appear to be scope to significantly improve the situation by bringing the dwelling on Plot 197 in line with the green frontage of Plot 198.

5. The aesthetic quality of the paving materials and boundary treatments proposed for the courts should be high to avoid exacerbating potential for negative visual impact. Prominent garden boundaries throughout the scheme should also be in brickwork.

6. The layout does not positively address the high quality countryside and reserved land to the west, generally offering close- boarded rear fences, parking courts and side elevations. Views into parking courts and the access to the reserve land could provide attractive views of the countryside/greenery through railings. The proposed fencing adjacent the parking courts would not be robust and is likely to lead to informal routes through spaces that should be largely private and the potential for dumping.

7. The arrangement of dwellings to the east of the large green would create a 300m length of relatively repetitive ‘executive’ housing and close boarded fencing to the rear, as opposed to the more varied and permeable layout shown on the ‘hardworks’ plan. The plans do not indicate the type of planting and fencing to be used to create an attractive and defensible area to the rear, for example railings with an under storey of planting to screen the fences and create a secure area adjacent the rear gardens. The northern eastern properties would now turn the corner positively but is a repeat of the gate/toll house type appropriate?

8. There is a general concern that crime reduction has not been properly integrated into the scheme. The scheme would result in a number of properties which may also be vulnerable to crime due to limited natural surveillance, for example in respect of the potential was unsupervised access to front doors, side windows or entrances and rear gardens. Plots potentially affected include all plots with rear boundaries adjacent the retained trees along the eastern and western boundaries and also Plots 1, 119, 132, 143, 149, 155, 160, 190, 194, 272 and 273. Car ports would often obscure views to rear gates or side windows and doors.

9. Views north along the main spine road and across the large green and the layout of Plots 277 to 296 could be terminated by the potential CHP plant which may create an inappropriate landmark.

10. The Indicative Masterplan shows that Plots 210 and 211 would provide a ‘key frontage’ but the proposed pair of semi- detached houses and their environment do not appear to live up to this. Where plots would terminate a new view, e.g. Plots 37 and 38, special attention should be paid to the quality of the architecture, landscape treatment and materials. Views should not be closed by garages and parking e.g. Plots 142 and 209.

11. Some properties would have rear gardens served by lengthy shared alleys which could create opportunities for crime and anti-social behaviour, including dumping e.g. Plots 68-75 where there appears to be scope to create even shorter runs. The need for such a facility in relation to former Plots 103-109 and Plot 119 and for pedestrian access from Plot 119 to the allocated garage has been removed.

12. Comments on house types A1 – poor front elevation AF3 – no additional comments C – Would there be sufficient space within the occupier’s garage to move wheeled bins alongside the car (same comment for C1, C2 and C3 types)? C1 – No comments C2 – Front elevation to Plot 21 would be prominent but very bland. Are vertical racks accessible to the elderly etc (general

92 point)? D – Are bike stores and bin areas to be provided by the developer? Bonnet hips to front hip to D2? E- Plain tile roof? Would elevations differ between the 2 versions? Suggest robust boundary treatment for Plot 208, e.g. low wall and railing, as located on strong desire line and could be affected by ASB. F1 – south-eastern side elevation too bland for prominent position, lack of natural surveillance over Plot 17 parking and lack of planting in car park. F2 – poorer quality architecture in comparison with F1, potential for duality at prominent site and 2 landmarks in close proximity but of similar appearance appears a wasted opportunity F3 – concern that orientation of blocks would provide view to CHP plant and across car parks, opportunity for natural surveillance from kitchen missed, what is local reference? Architecture of insufficient quality and a missed opportunity on this prominent site. The weather boarded corner building at the Manor House scheme in Horsham town centre (Middle Street/Blackhorse Way) offers an attractive approach to contemporary, locally distinctive flats. G, G1 & 2 – Gable brickwork decoration in burnt headers? H, H1 & 2 – incorporate side openings to porch to deter crime, scale of dormer inappropriate – suggest ‘lead’ roof J – porch attractive but concern regarding concealed front door L & L1 – With L1 is the area above the drive a void and would the front façade be an overly dominant element in the street and terrace? M – no comments. N & N1 – N1 alley serving 1 dwelling only? P – appears to be a departure from architectural approach, 2.5 storeys (as opposed to 2 storeys plus rooms in the roof) appears difficult to translate. More of a standard house type with half-hip. Could dominate due to height and scale, particularly from private gardens. Side and front elevations do not match in respect of the dormers. The dormers would appear larger than the first floor windows creating a top heavy appearance. Flat roof dormers one with ‘leaded’ cheeks would help reduce this effect. P1 – even worse with parking arch that is completely out of character, gives undue prominence to the drive, would be too narrow to allow the driver to access the front of the house when parked adjacent, same issues with dormer as type P but less well balanced, chimney height excessive against hipped roof. R - front elevation dominated by garage, squashing central section, deep gabled front projection adds to bland side elevation which would be prominent on Plot 87. S - no additional comments S1 – car port would provide concealed access to utility side door and gate access to rear garden, prominence of dormer and

93 parking arch and practicality of latter (see above). A1 – extensive flat front elevation with insufficient interest. Bonnet hips? A2, 3 & 4 all types – gable/side elevations prominent but lack interest and of low architectural quality. Front elevation to A3 poor quality architecture. The units are not ‘tenure blind’ and the quality of architecture needs to be significantly increased. AF1, 2 & 3 – not tenure blind and all prominent but lacking in architectural quality. AF1 blocks possibly visible from A264. 17/11/2010 Assessment of Phase 1 against CBC internal and external space standards

1. Internal space standards Houses  The houses generally meet our standards (although as we only have standards up to 6 bed spaces and 79 units would have 7 to 9 bed spaces).  21 units would be only 1m2 below the standard (so presumably not a problem).

Flats  Nearly all the flats, whether affordable or not, do not meet our standards.

2. External space standards  CBC external standards do not have a number of bed spaces limit. 5m2 is added for every additional bed space over 6 spaces.  All dwellings which would provide family accommodation suitable for young children will normally be required to provide individual areas of outdoor space. Dwellings with more than 2 bed spaces could be argued to offer family accommodation.  Each proposed plot has been assessed against the standard and the result recorded as +/- percentages (I am suggesting that we do not take issue over + or - 10%, but this has not been discussed or agreed).  Whilst there are now garden provision percentages for each plot I have for now summarised and mapped the results in the following groups. The number of units within each group is also set out below: -

Houses  50 houses meet the external standards by + or - 10%  66 houses exceed the standards by more than 10%  94 houses fall below the standards by more than 10%

Flats  7 flats meet the external standards by + or - 10%  7 flats exceed the standards by more than 10%  67 flats fall below the standards by more than 10% (generally by a sign. margin)

3. Way Forward

94  Internal space shortfalls in respect of affordable units may be picked up if the grant route is being pursued. Most units have significant garden size deficiencies.  Flats are generally deficient in terms of both internal and external space and changes to the layout would generally be necessary to address this. These changes are generally likely to affect the final number of units.  There would appear to be scope to reallocate garden space from plots which exceed standards to plots which are deficient.  Changes to the layout are also likely to be necessary to address other pockets of garden under provision.

24/11/2010 In response to the developments comments regarding the above.

1. The approach set out in paragraphs 4.6 to 4.8 and in Policy WB4 in the JAAP, based on the Filton appeal letter, was accepted by the Inspector and prevented the document failing the effectiveness test in respect of design (Inspector’s report paragraph 8.2). The changes to the JAAP explain what the DAS should contain and how they will be drawn up. The DAS should translate the underlying principles and strategies into detailed high quality examples in order to fix the quality of the development, not the particular design. 2. The DAS does not set out how these links would be secured beyond the application boundary. The clarification regarding the legal agreement is helpful. 3. The DAS does not set out how the management of these areas would be secured and the clarification regarding the legal agreement is helpful. The clarification provided should form part of the application. 4. The transport assessment shows the location of the new section of road at the A23/A2220 junction, but does not assess its impact on the setting of the listed building or in respect of the loss of trees. The proposal would also affect a clear desire line for children walking and cycling to two of the town’s secondary schools. Need to assess the impact of development on the setting of the listed building against CBC policies, but also PPS5. I would suggest a brief assessment of the significance of the building, its history, the areas development and its’ setting, (in compliance with PPS5-HE6) including the proposals sustain and enhance the setting of the heritage asset (PPS5 HE7.4) 5. The proposed links would not be overlooked once they leave the application site boundary. The likely desire line into/from the north-western part of Bewbush could be made safer were a link to be provided adjacent the housing between the brook and railway line. 6. See responses to 2 and 5. 7. The footbridge would need to be suitable for cyclists and the disabled and the clarification provided should form part of the application. 8. The ‘barrier’ of the railway referred to is mitigated by the 3 bridge crossings and the clarification provided above should form part of the application. 9. The number of dwellings proposed for the neighbourhood centre is low and the reference to the possibility of a residential use over the supermarket is too vague given the lack of other opportunities. 10. The ability to work out the location of a specific destination, e.g. the neighbourhood centre, from a distance would be helpful. 11. There is limited information in the DAS regarding the landscaped noise attenuation bund adjacent the A264. 12. No further comment.

95 13. Phase 1 will be introverted and largely turns its back on the countryside. Whilst the longer term impact of the scheme will be determined by what happens to the reserve land, the DAS says very little about how Phase 1 should respond to the countryside. Para 12.9 of the DAS states that the built form would positively address the network of linking hedgerows but this is not the case. 14. The concern is that the private amenity space provide for many of the dwellings would not be fit for purpose and restricts the potential for rear gardens to contribute to the appearance of the scheme. 15. No further comment. 16. No further comment. 17. See response to 7. 18. It would be helpful if the Design and Access statement could be clearer on these matters. 19. The Circus, as a suburban space, would benefit from the activity generated by the bus facilities. Bus stops would be more difficult to accommodate in adjoining streets and are often found in attractive key spaces. 20. No further comments. 21. How will the replacement spaces be secured? 22. No further comments. 23. See response to 1. The Filton DAS provides axonometric/3D sketches based on different residential blocks (meeting 12/11/10) which are more useful than just the unscaled plans in the Kilnwood Vale DAS. The perspectives generally of good quality apart from the exceptions identified. 24. No further comments. 25. The DAS should explain the proposals set out in the planning application. The area around the pond will be a key space and appropriate information provided as per the Phase 1 key spaces. 26. The distinction between adoptable and private area is unclear with regard to Figure 18.45. 27. The belt of trees in the south western corner remains an area of concern with respect to crime and anti-social behaviour. Opportunities for natural surveillance would be limited from the path and ineffective at night. 28. The DAS does not indicate that any part of the shared surface would be adopted as highway and see response to 7 above. 29. No further comment. 30. The public art statement (Para. 20.16) is insufficient a guarantee that art would have any real role to play in any of the phases of development. Public Art is not proposed by the applicant as part of Phase 1 although the pond entrance area or north and south squares would be appropriate locations. The S106 agreement would provide a robust mechanism. 31. The DAS should explain the proposals set out in the planning application. Reliance on briefs has not been agreed. The alternative pick-up/drop-off location has not been identified. Food store car park. No further comment. Food store vehicular access. No further comment. Residential above food store. See response to 9 above. Active frontages for the food store/building of the size and prominence proposed should be provided to the square and the primary street. Public house. No further comment. The orientation of the shops is a matter of concern and should be resolved at this stage. The food store car park would not be an attractive space and would have development backing onto it rather than addressing it, including rear gardens and boundaries. 32. As discussed at the meeting on 12/11/10 a commitment to aesthetic quality where not precluded by the

96 33. No further comment. 34. No further comment. 35. See 5 above. 36. No further comment. 37. Greenway Square North. 38. Have these matters been agreed? 39. The clarification provided should form part of the application. 40. No further comments. 41. Please clarify where in the code. Routes to rear gardens can be provided securely through continuous frontages. The provision of a gate does not manage access. Phase 1 demonstrates provision and accommodation can be provided inconveniently and is likely to lead to residents leaving bins on their frontage. Garages. No further comment. Materials – what would the public realm materials be for streets within the character areas but not covered by key spaces etc? Security – the comments were related to specific instances and the response does not address them. Concerns remain regarding unsupervised front doors and lone dwellings in parking areas. 42. The intention is to create more certainty with regard to distances. Reduced distances would be for the designer to justify through detailed proposals.The plan identifies parking spaces for which dimensions are known and the size of gardens can be deduced. The block principles drawings and the special frontage sketches are the only sample layouts provided. It is reasonable to request that sample layouts should be to scale in order to demonstrate that the principles would be deliverable.The Code appears to only address front garden boundaries? Would the courtyards be lit to aid surveillance etc? 43. See response on distances above. 44. No comment 45. Concerns relating to the relationship of woodlands to development eg near Kilnwood Lane. Active corners on isolated dwellings on the edge of the countryside are more likely to create an opportunity for crime rather than effective natural surveillance. Active corners would not provide natural surveillance over the central and northern streets illustrated and the streets are unlikely to be attractive for the reasons given. The scheme would not positively address the countryside to the north. 46. The area is semi private and appears to offer shielded accessible to all to cars within the plot and to rear gardens. 47. No further comments 48. There is general support for a local colour palette. However, a visible metal roof painted a terracotta colour (pantone 7522c) may not be as acceptable as a clay tile roof the same colour as they would have different textural and weathering properties. 49. The approach is not in question. The concerns are set out below but include the architectural quality of certain house types including A1/3/4, AF3, C2, F3, L1, P, P1, R.The concern is for example that shallow pitched roofs covered in clay tiles are not locally distinctive and would be more of a vernacular wrap.The code is also rather vague e.g. 8m max. Consistent 1m gaps would not contradict an 8m max dimension for gaps but would not create variety. Does ‘noted’ in respect of active corners mean the statement will be changed? Boxed

97 50. See 1 above re illustrations. 51. The DAS should explain the application. The phasing does not appear to be a robust reason not to provide a better link given the close proximity of the potential link to the edge of Phase 2. 52. No comment. 53. Noted but reliance on briefs not agreed. 54. Noted 55. There are concerns with this typology (see 45 above). 56. Noted 57. The DAS should explain the application. The Phase 1 northern and southern squares feature in the DAS. 58. Noted. 59. No further comment. 60. Or potentially confuse? 61. The materials themselves are not a concern. The architecture would be traditional suburban but wrapped in uncharacteristic materials. 62. A cohesive framework should identify buildings for special treatment not an incremental approach. 63. The car port concern principally relates to the P1 house type. The integral garage concern relates to the R type. 64. No further comments. 65. This is a general point to demonstrate accessibility on the ground.

05/01/2011 The Borough Council agrees with the matters raised by the Horsham District Council Design Advisor. The comments below should be read in conjunction with previous versions as these have not been repeated here.

1. Dwelling and garden sizes

As of 5th January 2011 amended plans have been submitted showing proposals to enlarge 10 gardens but no supporting explanation or schedule has been received. The front projections to 2 of the gardens may create visibility issues with regard to crime in terms of reduced visibility of the front door to Plot 1 and highway visibility with regard to Plot 259. As 94 houses fall below the standards used in the town by more than 10% and 67 flats fall below the standards by more than 10%, generally by a significant margin, the adequacy of the size of gardens remains a concern. There is scope to reallocate garden space from plots with large gardens to plots which are deficient.

Whilst some open spaces could be used as a form of garden, this would require modification to the boundaries e.g. fencing

98 and access and, if this was done, would create semi-private not private space. Front gardens would not generally be used for activities such as unsupervised play, sunbathing and general outdoor eating and should not be considered as mitigation for small rear gardens.

Given the concerns raised regarding garden sizes, it should be noted that the layout plans should do not show the proposed cycle and bin storage facilities. Each bin storage area (drwg. 16702/441/PA-05) would be for 3 wheeled bins, with at least 2 collections per week so their location needs to be convenient.

2. Flats above garages (FOGs)

The FOGs along the western boundary (Plots 149, 155, 160 and 194) would only have contact with adjoining residents when they do something with their cars or garages. These particular dwellings would not have passers or other dwellings in the court, as would be the case with FOGs at Plots 179 and 191 or 255 and 261 for example. In this respect Plots 149, 155, 160 and 194 would be isolated. The crime prevention advisor does not support parking courts which would not have natural surveillance from pedestrian footfall and active rooms within dwellings. The parking courts would have very limited footfall and be overlooked by just one active room within a small dwelling which clearly is only active when the occupant of the flat is at home. The design advisors at CBC and HDC have consistently raised this as a matter of concern. With regard to Plot 155 and its associated parking area the situation could be improved if Plot 160 was fitted with a south-facing kitchen window which provided an opportunity for overlooking.

3. Parking-dominated areas

 Plots 9 – 21. The submitted comment relates to the quality of the private residential environment being proposed, which is essentially a car park with no private amenity space. The designer’s response regarding the appropriateness of on or off plot parking in no way addresses the concern.  Plots 71 – 72. The street would still be parking-dominated. The main planting area for trees and shrubs is also identified as a collection point for six wheeled bins, limiting its ability to ‘soften’ the parking.  Plots 210 – 225. No revised plans so please refer to previous comment.

4. Parking court related to Plots 166 to 170 and 197 and 198.

The view into this court would be the least attractive and the layout would not accord with Police advice regarding supervision.

5. Parking court materials

The proposed use of ‘Tegula’ concrete block paving and the use of bricks walls would be robust, attractive and appropriate to courtyard settings. Please could the applicant confirm where information regarding the paving mixes is set out.

6. Addressing land to the west The JAAP Conceptual Masterplan shows the access route between the open space and reserved land. The Phase 1 proposal

99 moved away from this approach to make developing the ‘reserve’ land more straightforward. The local authorities accepted the changed approach only the basis that the disbenefits would be satisfactorily resolved but an introverted layout has been the result. Concerns have been consistently expressed regarding the aesthetic quality of rear boundaries onto the countryside and future green routes and the security implications.

7. Dwellings east of the green.

The Borough Council supported the arrangement on the grounds of the potential disturbance to Phase 1 residents from remediation works and on the basis that concerns regarding security and views of the fences would be addressed, perhaps through the use of railings and planting. The proposal for defensive planting is insufficiently robust and would take time to establish even with proper management. In terms of the frontage, the scale and layout would be largely repetitive and the proposed vehicle gates would protrude forward of the general building line and be unduly prominent. Vehicles would block the road whilst the gates were being opened.

8. Crime reduction

The police design advisor has not raised major concerns but has provided detailed advice that does raise issues for the scheme. The Safer Places guidance highlights that crime reduction is a matter for a wide range of professionals who should be seeking to work together. The Applicant’s designers have responded in writing to the police comments but have not taken the opportunity to address the following matters: -

 Parking in small parking courts must have natural surveillance from pedestrian footfall and active rooms and be well illuminated. Of the 14 small parking courts proposed (i.e. not a mews or car parking associated with a block of flats), 3 would be overlooked but from just 1 active room, 2 would have overlooked gated entrances and 9 would not have either of these facilities. 4 of these would also not be lit (Drwg 16702/441/PA-09). As the courts would be small, with either one or no flats within them, their ability to generate legitimate footfall and effective natural surveillance would be limited. The majority of these courts would be readily accessible and some easily accessible from the countryside due to the post and rail fencing proposed.  The frontages of dwellings should be open to view – front boundaries are generally formed by hedging the height of which will be controlled by residents. In terms of the principle, views to the frontage to Plot 119 would be significantly obscured by a detached garage and a number of plots would be relatively isolated including Plots 1, 119, 272 and 273.  Side and rear gardens are vulnerable and should be protected by walls or fencing to a minimum of 1.8m. The police may not support the use of 1.4m fencing plus 0.4m trellis to rear gardens adjoining the east and west boundaries of the site as this would provide the opportunity to identify whether occupants were not at home from unsupervised areas of mature planting behind these homes. The proposed maintenance access routes would allow easy access to rear boundaries and prevent the use of defensive planting.  Gates to rear areas should be the same height as the fencing. The newly introduced driveway gates to properties along the eastern boundaries would have gates less than 1.6m high.

100  Gates to rear areas must be located on/near the front building line. There are many examples of where this is not the case which provides opportunities for crime e.g. the significant number of plots with car ports or parking down the side of the dwelling and also specific plots such as Plots 119, 143 and 210.  Avoid windowless elevations and blank walls adjacent areas with public access which attract graffiti and loitering. Buffer zones can comprise railings, defensible planting or both and can also protect vulnerable windows. Dwellings at Plots 199, 239 and 273 would benefit from this approach, for example.  The boundaries of the flats would benefit greatly from 1m defensible railings and the vulnerable windows from defensive planting. None of the blocks of flats proposed would have the benefit of 1m defensible railings and planting is not generally directed to protecting vulnerable windows.  Cycle access. The Applicant’s designer did not address this point in their response.  Secured by Design accreditation including BS: PAS 024. The Applicant’s designer did not respond to this point. The British Standard does however highlight the need for front doors to be equipped with robust locks, viewers and chains. There is also a need for front doors to be visible in order for natural surveillance to act as a deterrent and to enable neighbours to be aware that a crime is taking place and hopefully offer assistance. Recessed front doors and open porches with solid side walls are more interesting architecturally but unfortunately can create a shielded area from which to commit a crime.  Lighting is important around parking areas, buildings and communal areas. The number of small parking courts without lighting has been highlighted above. There are also individual plots that would benefit from additional lighting including Plots 6, 7, 8 and 239.  Concerns have also been expressed regarding the proposed treatment for the parking courts on the western boundary which will result in these parking areas ceasing to be semi-private and thereby less secure because they will provide easy access to and from the countryside beyond. Whilst some of the pedestrian traffic will be residents from the wider development simply going for a walk, there will also be roaming groups of children/youths looking for something to do and potentially others residents looking to dump cuttings or waste, gain access to cars or properties or behave anti- socially. A side effect of this may be that if residents around the court begin to perceive the area as being insecure area they may seek to park any second cars in alternative locations near their homes, principally on verges and visitor spaces along the roads, and this will also reduce legitimate activity in the court. 9. CHP plant

The local authorities are keen to ensure that the provision of a CHP plant is not precluded by its visual impact, airport safeguarding or impact on the amenities of new neighbours. I understand that a robust response is awaited.

10. Prominent frontages

The buildings and landscaping of the plots identified would not provide the necessary high quality end stops to views. Garage set backs of 7 or 8m would not influence the fact that a garage would be terminating a long view and this would be an underwhelming response to a clear opportunity.

101 11. Architecture

Please refer to previous comments.

12. Refuse and recycling collection points

There will be direct conflict between a number of the proposed collection points and street planting areas (e.g. adjacent Plots 72), which will undermine their effectiveness, and also with the suggestion that some residents would use their neighbour’s front garden (e.g. Plots 2, 4) including areas identified for private boundary hedging. The use of refuse and recycling vehicles that collect mechanically from the road edge of the footways may make certain sites unusable, e.g. collection sites behind visitor parking, planting or those in groups, or may make the use of certain collection vehicles impractical.

13. Pedestrian routes though reserved land

The routes could be set out now rather than waiting for an application relating to the reserved land?

Design and Access Statement 1. Design Brief for neighbourhood centre The local planning authorities have set out their concerns on a number of occasions and putting off the discussion to a later date and incorporating the guidelines within a weaker document would not be in the public interest. 2. Design Brief for station area A commitment to a design brief process in case the station is not delivered appears to be a reasonable approach. The commitment to the provision of the important pedestrian bridge is welcomed. 3. Design principles for Bridge Structures The commitment to additional design principles is welcomed. 4. Communal open space block typology The commitment to security and natural surveillance is welcomed. 5. Active corners The commitment to all faces relating to the public realm being active is welcomed. 6. Landscape principles For others to comment. 7. Gateway For others to comment. 8. Public Art What is the agreed value, would this be index-linked and will suitable sites be accessible/owned/managed by the local authority? 9 - 11 Bus gates, Sustainability and Phase 1 Movement For others to comment.

102 19/01/2010 The garden size schedule was received on 7th January 2011 and details the changes set out in the revised layout plan received in December. The aim of raising the issue is to secure private gardens that are fit for purpose and able to contribute to the attractiveness of the area, for example by providing space for trees to reach a positive size. My comments are as follows: - 1. Overall (houses and flats) Initial provision  130 dwellings meet, exceed or be within 10% of the Crawley standard  161 dwellings fall below the standards by more than 10% Adjusted Crest figures  149 dwellings meet, exceed or be within 10% of the Crawley standard  142 dwellings would not meet the standard by more than 10%

Note: The revised figures from the applicant have been adjusted (see above) to remove suggested mitigation to shortfalls in private amenity areas in the form of front gardens (which would not be used in the same way as rear gardens), adjoining open space without appropriate amendments (see 3 below in respect of flats), Juliet balconies (i.e. a rail to a French door not a usable space) and suggestions that only certain residents of flats would have access to the areas provided (leaving some with no access).

2. Garden provision for affordable houses For houses generally 64% would meet, exceed or be within 10% of the standard whereas for affordable houses (which are more likely to be occupied at or near capacity) this falls to only 40%.  Houses generally 136 houses would meet, exceed or be within the standard (64%) 74 houses would fall short by more than 10% (35%)  Affordable 11 houses would meet, exceed or be within 10% of the standard (40%) 16 houses would fall short by more than 10% (59%) It is not known whether the small garden sizes proposed for a number of affordable units would deter RSLs from implementing those units. Affordable units would not have the benefit of garages for additional storage. Given the concerns raised regarding sizes of a number of gardens, it should be noted that the layout plans should do not show the proposed cycle and bin storage facilities which need to be convenient to encourage residents not to leave bins in front of their homes.

3. House garden sizes As 74 houses fall below the Crawley standards by more than 10%, the adequacy of the size of gardens remains a concern. There is scope to reallocate garden space from plots with large gardens to plots which are deficient without reducing the numbers of dwellings. For example: -  Plots 221 – 223 (affordable) with under provision of 21, 35 and 39 square metres adjacent Plots 235 and 236 with 46 and 97 square metres over provision

103  Plot 225 (affordable) with under provision of 23 square metres adjacent Plot 233 with 34 square metres over provision  Plot 132 – 135 and 140 with under provision of 12, 31, 31, 29 and 32 square metres adjacent Plots 141 – 143 with 72, 95 and 37 square metres over provision

4. Flats - external and internal space External space - Whilst 67 flats fall below the standards by more than 10%, generally by a significant margin, the emphasis should be on providing useable space, particularly with regard to affordable 2 bedroom units that would accommodate families. The space should be designed, directly accessible to residents, secure/private and laid out to prevent disturbance to adjoining ground floor flats. Small usable balconies can only meet certain needs. Other space would be needed for planting to contribute to the quality of the environment. On this basis Plots 9 – 20, 55 – 67, 180 – 186 and 274 – 291 are currently unacceptable but could possibly be made acceptable subject to changes in accordance with the above. Plots 41 – 52 and Plots 212 – 217 would not be acceptable as the proposal would create shallow areas where affordable units may create high demand and also potential impact on ground floor units. The northerly aspect in the latter case reduces its potential to meet the needs of residents. Internal space - Nearly all of the flats, whether affordable or not, would not meet the Crawley standards. It is not known whether the proposed internal size of affordable units would comply with the standards used by RSLs.

21/02/2011

Thank you for consulting me on the letter from Savills, dated 7th February, and the accompanying information. My comments are as follows: - At the design meeting on 24th January 2011 a number of outstanding matters were discussed. Some issues were resolved, whereas others were addressed in part or could be addressed but were not being pursued. 1. Neighbourhood centre design brief The key outstanding issue is that the Applicant refuses to, in principle, seek to provide residential uses above the relatively large and prominent food store. The make-up of the actual scheme for the centre will depend on the circumstances at the time a detailed scheme is determined. Without this commitment and the consequent amount of actinity and natural surveillance, the Borough Council does not support the design brief approach as a quality ‘fix’ would not have been achieved. There is also a concern regarding road safety in and around the small neighbourhood centre car park at the beginning and end of the school day. 2. Private rear garden sizes The Borough Council has acknowledged that, as the scheme is in Horsham District, the standards that apply in the town could not be applied to this new neighbourhood. However, the approach has been, since June 2010, to highlight specific plots where the fitness for purpose of private rear gardens is questionable. The Borough Council is keen to ensure that rear gardens have sufficient space for active play, planting that can contribute to the quality of the wider streetscene as well as the individual dwelling and to reduce neighbour conflict. The need for each dwelling to have space to store three wheeled bins and sometimes a bike store/shed without reducing the garden to merely a yard, and creating a depressing outlook or pressure to leave bins in the street, also needs to be taken into account.

104 Amended plans have been submitted showing proposals to enlarge 10 rear gardens. For houses generally 64% would now meet, exceed or be within 10% of the standard whereas for affordable houses this falls to only 40%. The Borough Council emphasises again that in some areas plots with rear gardens that significantly exceed the guidelines back onto rear gardens that are too small for the type of home proposed. Some of the most deficient gardens would be for affordable homes that are likely to be fully occupied. Improving the size of these gardens could be easily achieved without affecting the mix, density and number of units. For example: -  Plots 221 – 223 (affordable) with under provision of 21, 35 and 39 square metres adjacent Plots 235 and 236 with 46 and 97 square metres over provision (95 square metre shortfall versus 143 square metre over provision).  Plot 225 (affordable) with under provision of 23 square metres adjacent Plot 233 with 34 square metres over provision.  Plot 132 – 135 and 140 with under provision of 12, 31, 31, 29 and 32 square metres adjacent Plots 141 – 143 with 72, 95 and 37 square metres over provision. (135 square metre shortfall versus 201 square metre over provision).

Front gardens would not generally be used for activities such as unsupervised play, sunbathing and general outdoor eating and should not be considered as mitigation for small rear gardens. Front gardens provide a setting. 3. Flats – semi private amenity space The Borough Council has suggested that some areas of incidental open space could be modified with fencing and direct access to provide semi-private amenity areas for flats. The latest boundary treatment plans show that, whilst there would be some fencing enclosing adjacent areas: -  Plots 9-29 would have no direct access and the significant gap in the fencing would make its role ambiguous. Not all of this area would need to be semi-private space.  Plots 41-52 would not have a fully fenced area.

The Police have also advised (letter dated 8th September 2010) that the grounds around the flats would benefit greatly from 1 metre defensible railings with defensible planting to vulnerable windows. The Borough Council supports this approach as it would take time for the hedge to establish into a robust boundary for security purposes and gaps would be unsafe for small children, particularly near paths and water areas. Plots 41-52 would mostly have some post and rail fencing but Plots 9-20, 55-67, 180-186 and 274-291 would generally have no fencing. There is a concern that flats adjacent paths could be subject to crime and anti- social behaviour without the fences. Juliet balconies comprise a rail in front of ‘French’ doors and should not be used as a substitute for private amenity space or walk on balconies. 4. Flats over garages (FOGs) The suggestion of gated parking courts adjacent the FOGs was not supported by Horsham District Council in January. The amount of natural surveillance over the parking courts that can be achieved from one small flat would be limited. 5. Western and eastern edges The proposed boundary treatment adjacent the parking courts would be more robust, although the longevity of mesh is questionable, but the 1.2m height would be an insufficient deterrent. The Council has expressed concerns regarding the

105 introverted layout of Phase 1 since June 2010. The scheme would present rear garden boundaries to accessible planted areas, providing opportunities for crime and dumping. Council officers had agreed to the layout at the pre-application stage subject to the adjacent planted areas being enclosed by railings and privately managed. 6. Secured by design  Eastern boundary gates - The concern expressed was related to the proposed position of the driveway gates, forward of the building line. The gates could be set back without impacting on parking numbers.  Gates to rear areas – The change to Plot 210 is welcomed. The response regarding the introduction of another window to Plot 119 to overlook the rear gate would only be potentially effective when the property is occupied. When the home is empty, the rear gate is remote from natural surveillance. The concern regarding the obscured side gate to Plot 143 has come about as a consequence of the proposed layout and could be addressed, for example by a change of house type or removing a garage from Plot 142.  Car ports – the addition of a side window is only potentially effective when the property is occupied. The concern remains that these car ports, which add variety to the streetscene, would nonetheless create accessible but screened access to rear gates, garages, cars or side doors. This concern relates to house types H1, P1, S1, L and M.  Walls adjacent public areas – the addition of a buffer zone to Plot 239 is welcomed. The proposed change to Plot 199 does not appear on the latest plans. The concern regarding Plot 273 concerns the north eastern boundary wall, which has been exacerbated by the inclusion of an unsupervised play area nearby.  Defensible spaces to flats – The additional areas of planting to Plots 9-20 are welcomed. The Borough Council supports the advice of the police regarding the reinforcement of these areas with railings (see above).  Porches and additional lighting – the changes are welcomed and address the security issue raised.

7. General layout amendments  Prominent frontages - the changes to the layouts of Plots 142 and 209 to more positively address views are welcomed and resolve the issue.  Unit 21 - the reorientation of the main façade to the street is welcomed and resolves the issue of the bland elevation. A canopy to the front door would add interest and convenience.  Refuse and recycling - the changes to collection areas are welcomed.

8. Elevational amendments  The concern regarding the eastern edge to the park is principally concerned with the repetitive form of the buildings and layout, not materials (comment June 2010).  House type F3 - the changes to the elevations would create more interesting and locally distinctive prominent buildings and are welcomed.  Outstanding concerns not addressed in the letter. 1. Affordable dwellings - Parking dominance of affordable housing area (Plots 210-225) combined with a lower quality of architecture

106

2. Isolated dwellings – concerns remain regarding the lack of natural surveillance to the frontages, side gates and boundaries of Plot 1, 119, 143, 149, 155, 160, 272 and 273 and the extent to which residents would come into contact with neighbours.

3. Rear alleys to Plots 68-75 and 132-135,139 and 140 remain a concern with respect to crime, anti-social behaviour and dumping.

4. Plots 166-171 – the cluttered parking court with limited natural surveillance and adjacent small gardens could be significantly improved if Plot 197 were moved closer to the green.

5. Unit 67 - the reorientation of the main façade to the street, as proposed for Plot 2, could also address concerns regarding this prominent but bland elevation.

6. Bus gates etc. – these would need to be secured through the planning application to ensure that the scheme would be integrated into the wider town.

7. A23/A2220 highway works – the existing trees would be lost to create the additional lane, without replacement, and pedestrian/cyclist desire lines between Gossops Green and Southgate made more difficult. The setting of the listed building would be negatively affected.

8. The footpath and cycle links into Bewbush and Ifield West lack natural surveillance and the detailed design of these links should take account of this e.g. lighting and an open aspect.

9. The Woodcroft Road bus gate drawings should make provision for lost on-street parking as there is a shortage of parking in the area. How will these relocated spaces be paid for and delivered?

10. The key spaces information in the DAS is lacking in sufficient clarity with respect of Brook Crossing and Station Square to establish a design quality fix for this prominent and important location.

11. Proposed palette of hard landscape materials - for areas to be offered for adoption, has the palette been agreed by West Sussex County Council as the Highways Authority?

12. Public art - What commitment is there to pay for and deliver public art?

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Contaminated Land In general, this division accepts the findings of the Kilnwood Vale Environmental Statement: Chapter 8: Ground Conditions, Land Quality and Remediation and the SLR Remediation Strategy (SLR Ref: 403-0404-00027) However, I would like to make issues with the remediation of the site a reserved matter for comment, once more detailed development plans have been submitted and the nature of the receptors is confirmed.

Environmental The Western relief road. Protection Officer  Policy WB 23 requires land to be safeguarded to allow for the possibility of a western relief road (WRR). The primary access route to the development has been designed with the potential for a WRR in mind (2.123 - 2.129 of the planning statement).  The EIA scoping opinion prepared by the applicant identified noise from a WRR as a major noise impact on the western boundary of the development. Phase one of the development is on the western boundary.  The WRR is mentioned in the ES. However there is no detailed consideration of the possible noise impact of a WRR or of ways in which it might be mitigated. At 13.5.21 and 13.6.6 the ES identifies that a noise barrier similar to that proposed for the southern boundary of the site might be required to mitigate noise to acceptable levels and there would appear to be space for such a barrier to the west of phase one. However, the practicality of placement and the projected performance of such a barrier it is not considered within the ES or the outline application.  The LPA may wish to consider that if, on balance, a WRR is likely then its acoustic impact should be considered, as far as is reasonably practicable, and reasonable allowances made within the development plan for the mitigation that may be required.  The major noise impacts identified at the scoping stage have been assessed as far as possible at this stage and suitable mitigation has been identified in outline. The outline application includes application for a noise bund on the southern boundary of the site which is predicted to substantially change the exposure of the site to noise from the A264.  The noise modelling methodology described is sound. The noise contours of the development site have been modelled and the model verified by field measurement at sites which I can confirm were satisfactory.  A “with development” scenario as of 2022 has been predicted, with a noise barrier (earth bund) in place along the southern perimeter of the site. Data is not given for the current noise exposure of the site without a noise bund in place. The noise modelling with the bund in place shows that the site is suitable in principle for development.  The ES states that residential development will be restricted to within NEC’s A and B. It is recommended that this is secured by condition.  The provision of a noise barrier along the southern boundary is essential to achieving acceptable noise levels on the development site, including the phase one area. It is recommended that provision of a satisfactory noise barrier, prior to the occupation of any residential dwellings, is secured by condition. The condition should include a requirement for post completion testing of the barrier to verify its effectiveness.  The ES shows that it is possible (given suitable mitigation for dwellings within NEC B) for the internal acoustic environment of all residential housing is to conform to the “good” standard as defined in BS 8233 1999. It is recommended that this is secured by condition.  For development on land falling within the NEC B contour, noise mitigation measures will be required to ensure that the internal and external acoustic environments meet the agreed BS 8233 “good” criteria. Detailed noise mitigation proposals that are satisfactory to the LPA will need to be secured by condition for each phase of development that comes forward including phase one (see below).

108  Notwithstanding the requirement to use suitable noise insulation measures, wherever possible the noise exposure of residential dwellings within the predicted NEC B contour should be minimised by the layout and orientation of dwellings and the use of non noise sensitive development as barrier. Gardens and private amenity spaces should be located so that buildings act as a noise barrier to any major noise sources (in accordance with 13.5.7 of the ES).  Noise from the proposed Energy centre (of an as yet unknown type and exact location) is considered within the ES and some operational sound power limit levels are indicated which will achieve the agreed BS4142 rating level of 10dB below background. The ES indicates (at 13.5.17) that the nearest noise sensitive residential development to the energy centre is proposed to be built during phase one, before the nature of the energy centre is determined.  Once built, the northern part of the proposed phase one residential development may therefore place a substantial constraint on the design and technology that can be used at the energy centre (given its outline proposed position), the times at which it can reasonably operate, receive deliveries etc. This may not be satisfactory to the LPA.  The issue of mitigation of noise from the energy centre and the other industrial and employment areas should be reserved for comment when more detailed development proposals are made.  The agreed BS4142 criteria, to ensure that complaints are unlikely, is that the rating level of industrial noise sources and any associated plant must be 10dB below the existing background level. This is addressed in the ES and it is recommended that this is secured by condition.  The outline proposal to place the school on one of the quietest parts of the site is welcome and should be secured by condition. Detailed proposals for the acoustic design of the school and its compliance with BB93 standards will be required and this aspect should be reserved for comment when more detailed development plans are submitted.  The noise impact of the proposed sewage storage and pumping station on the Eastern side of the development is not considered in detail within the ES. At this stage we do not know what plant may be associated with the facility and comment should therefore be reserved for when more detailed development plans are submitted.  The noise and vibration impact of the railway and the potential railway station have been considered and the modelling shows it to be within acceptable limits given the outline position of housing to the railway. Where possible the use of non residential development to shield residential development from railway noise should be employed. Again this matter will require further consideration and appropriate conditioning when more detail is known about the station and when future development plans for phases adjacent to the railway are submitted. It should therefore be reserved for comment.  Mitigation of noise during the construction phase will be dealt with by compliance with best practicable means and BS5228 2009 requirements.  With regard to the full application for phase one of the development: With regard to development on the southern boundary of the site, adjacent to the noise bund and the A264. The effectiveness of the noise bund is crucial to achieving acceptable noise levels at dwellings on the southern border of the site. Residential development proposals on the southern border of phase one contain 3 storey residential units. The effectiveness of the bund in reducing noise from the A264 to any dwellings at first and second floor level will be significantly lower than at ground floor level. Data for noise exposure at the facades of proposed first and second floor dwellings on the southern boundary of phase one is not given within the application. This data is required before detailed comment can be made on the suitability of the proposed locations for first and second floor dwellings on the southern boundary.  Once the above matter has been clarified. Satisfactory detailed proposals for the acoustic insulation of the residential development in phase one should be required by condition.

15/02/2011

109 Response to Technical Notes dated 7th February 2011 The technical notes address a few issues raised in my memo dated 4th November 2010 (appended) which commented on the hybrid application, they also refer to a meeting on 6th January 2011 for which, as far as I am aware, there are no agreed minutes. With respect to the noise bund (barrier)  My understanding is that the hybrid application (planning statement sec1.9 D and para. 2.71) includes full application for construction of the noise bund along the southern edge of the development.  The noise bund is integral to the environmental design of the development. It’s performance will significantly affect the noise exposure of a large number of residences, not just those closest to the bund. It is reasonable for the LPA to have confidence in the performance of the barrier. As such the LPA needs to be able to ensure that the noise barrier is built in accordance with a verifiable design that matches or exceeds the insertion loss performance of the design used in the noise modelling exercise.  With respect to the recommendation for post completion testing of the barriers performance, this is based on the data submitted with the application. It is not possible, as is correctly pointed out, to quantify the noise levels due to traffic at 2022 levels. However, the insertion loss of the barrier, as built, is the relevant parameter and this can be measured (using an agreed protocol) and compared to the modelled insertion loss.  However, it is accepted that post completion testing will not be required if confidence and verifiability can be achieved in other ways.  The figures supplied within the technical notes for the accuracy of the noise modelling are accepted as nominal. I would request confirmation of the grid resolution used and of any efficiency settings used during the modelling exercise and their effect (if any) on the accuracy of results.  It was requested that the predicted noise contours for the site, at ground, first and second floor level be submitted and referenced to drawings showing the bund design used to achieve these levels.  Predicted ground, first and second story NEC contours have now been submitted as figures 1 to 6 within the technical notes.  Figures 1-6 reference drawing 16702/441/PA-01. This drawing does not describe the bund shown on the noise contour mapping either completely or in enough detail to allow verification (see below).  To achieve a verifiable design, accurate drawings (or other data acceptable to the LPA) of the barrier, showing its position and height along the length of the southern boundary of the site are required. It is not yet clear from what has been submitted, that the entire bund as modelled is proposed to be built in this phase. What the height of the bund is along its length and how this compares with the barrier design used in the noise modelling exercise.  Within the ES (sec 13.4.5 ) reference is made to a barrier of 3m in height (above current ground levels) as having been used within the noise model (figures 13-2 and 13-3 of the ES) The barrier used in modelling covers the whole of the site’s southern boundary, with two gaps.  Drawing 16702/441/PA-01 (referred to in figures 1-6 of the technical notes) shows in plan view the position of only approx.

110  Drawings 0404.00027.16.DT.001-002 provide some height data for the barrier to the West of the secondary access but does not give enough detail to enable accurate verification.  Drawings 0404.00027.16.DT.003-004 show some elevation detail to the East of the secondary access but again the data is not complete enough to enable verification.  Section a-a on drawing 0404.00027.16.DT.003 appears to have a typo (94.100 repeated) and section c-c on drawing 0404.00027.16.DT.004 has no height data.  In summary, the data so far supplied for the noise bund is neither complete nor detailed enough to allow for verification of the design and performance of the built barrier with that used in the noise modelling.  Full, verifiable, details of the noise bund’s position and height along the southern boundary of the site should be obtained before permission is given.

With respect to the completion of the noise bund relative to the occupation of residential development.  As mentioned above, the performance of the bund will significantly affect the noise exposure of a large number of residences within the development (not just those closest to the barrier).  The bund is integral to the environmental design of the development, as identified within the ES. It is my understanding that major landforming work (including construction of the noise barrier) is planned to take place prior to the residential build. Completion of planting and landscaping of the bund is not relevant to its performance as a noise barrier.  I continue to recommend therefore, that construction of the bund, to the satisfaction of the LPA, is completed prior to first occupation of dwellings. The proposed energy centre  My comments of 4th November 2010 remain as advice to the LPA. Building up to the boundary of the proposed energy centre at this stage may place constraint on the design and technology that can be used at the energy centre site. This may not be satisfactory to the LPA; it depends on the type and mix of energy sources envisaged, as I understand it this has yet to be agreed.  The technical notes outline three energy source options which could, with correct mitigation, meet the agreed BS4142 criteria of a rating level of 10dB or more below background.  At no stage has it been recommended that occupation of dwellings be conditional on certainty about the energy centre proposals.

111 Orientation of dwellings  Firstly, from my point of view there is no confusion. Monitoring of the impact of the noise bund was never connected in any way to the re-orientation of dwellings.

 The developer had stated that only a small number of second floor bedrooms were affected by noise levels above 60dB LAeq, 16h. As such, I suggested that it may require very little effort at this stage to minimise this exposure, by considering simple reorientation of building footprint or internal layout. The applicant advises that their architects consider this not to be achievable, given the design of the affordable units proposed.  The developer has already committed to noise insulate all dwellings to achieve the “good” standard of BS8233 for internal noise environment. Which in my previous memo is one of the matters that I recommend is secured by condition for the whole development.

Environmental 1. Construction Phase Impacts Health Officer  The main potential impacts during the construction phase are dust deposition and elevated Particulate concentrations (PM10). There is also the potential for organic matter, within the former inert landfill, to be disturbed during construction activities giving rise to odour.  The construction impacts can be minimised through the use of the recommended mitigation measures. This should include a Construction Environmental Management Plan (CEMP), which should be agreed with the Local Planning Authority prior to works commencing.  The CEMP should take account of the recommendations of the two key guidance documents that address the control of dust and other emissions during construction activities: The control of dust and emissions from construction and demolition best practice guidance: Greater London Authority and London Councils, London, 2006 Controlling particles, vapour and noise pollution from construction sites, BRE, London, 2003  Piling methods that avoid or minimise bringing buried waste to the surface should be used where feasible to mitigate any odour impact.

2. Operational Phase Impacts  NOx and PM10 are the pollutants of most concern from traffic and the proposed Energy Centre during the operational phase.  Energy Centre/CHP: The air quality dispersion modelling for the Energy Centre/CHP has relied on assumptions about fuel type, stack height and the exact size, design, location and layout of the plant.  As proposals for the development are progressed there may be changes in these parameters that will affect the results of the modelled air quality impacts on sensitive receptors and may also change the visual impact of the plant (eg stack height)  Crawley Borough Council would therefore recommend that the Energy Centre/CHP element of this outline application is listed as a Reserved Matter requiring a further AQ impact assessment when the design parameters are know for certain at the Full Planning Application stage.  The CHP may fall under the regulatory regime in the Environmental Permitting Regulations 2009 and require a permit to operate. Consultation with the regulator will be required. This will be the Environment Agency for appliances with a rated

112  Traffic Emissions: The AQ impact of increased traffic emissions as a result of the proposed development is assessed as small to medium.  A number of traffic mitigation measures have been proposed in the Transport Assessment, including the provision of public transport, improvements to road layouts and cycling and walking facilities.  However, it is recommended that even where the impact is considered small or medium, further mitigation in the form of a Low Emission Strategy (LES) should be incorporated into the design scheme to ensure that the development conforms to best practise standards and is “air quality neutral” as far as is reasonably practicable.  Crawley Borough Council is working with Sussex Air Partnership to develop a LES for the Sussex authorities and would encourage the uptake of a Low Emissions Scheme on a development of this size, supported by contributions from the developers.

3. Cumulative Impacts  The EIA also considered the cumulative impacts of the development alongside other developments proposed in the area. It was concluded that there were no significant adverse cumulative impacts expected.  However, as described above, even low to medium changes in pollution concentrations can lead to “background creep” and the implementation of a LES designed to accelerate the uptake of low emissions fuels and technologies in and around the development can be effective in combating cumulative impacts.

4. Sewage Storage Tanks  The AMP5 capital expenditure was determined in November 2009, following which a decision was to have been made on the provision of sewage storage tanks on the site (to hold sewage so that it could be sent up the pipeline at a controlled rate). However, there is no information in the application regarding this provision.  As there is a risk of septicity and possible odour emissions, the design and exact location in relation to sensitive receptors needs to be assessed. Therefore Crawley Borough Council would like to see this element of the outline application held as a Reserved Matter requiring a further AQ impact assessment when the design parameters are know at the Full Planning Application stage.

Development September 2010 Management  Bus routes on Figure 17.2 of the Design and Access Statement seem to reflect discussions with Metrobus who overall have indicated that they are supportive of the proposed routes and the way in which they integrate with existing bus services.  The general spacing between bus stops shown on Figure 17.2 seems appropriate. However, figure 17.2 is a tube style route diagram and it is not possible to gauge the actual distance between stops.  Figure 17.2 indicates that there is a stop named the Gateway near the A264 but this does not seem to be shown on any other plans. The usefulness of a stop so close to the A264 would also be questioned.  The names of the stops shown on the tube style map such as North Square, The Circus, Market Square etc would seem to imply that the stops would be in the squares. However, the location of the bus stops shown on the overall site layout for Phase 1 show the North Square stops a distance to the east of the square itself. Similarly the Circus is on the one hand

113  It is unclear if the bus stop would continue to be provided at the station if the station itself was not constructed. However, as this is the end of the Fastway 10 route and will be the nearest Fastway stop for those houses north of the railway that there should continue to be a stop in this location. It should be noted that buses will need to turn round at this point as it is the end of the route.  The stops referred to as South Square on the tube style map are located outside of the housing area itself when compared with the Phase 1 overall site layout. It is felt that they should be located within the housing area to maximise the number of people within a 400 m walking distance. Located where it currently is, only half of its 400 m walking circumference has houses within it.  The two stops to the east of North Square on the phase 1 layout plan are shown on carriageway opposite each other. Buses could be stopped at both these stops at the same time, thereby blocking the road. They are also very close to a horizontal deflection in the road width which could again lead to problems.  No reference to bus shelters is made or shown on the plans. Bus shelters should be located at all stops used for boarding buses. For South Square and North Square stops this would mean on the western and northern side of the road respectively. Shelters in other locations will depend partly on which way the 300 loop will operate.  Sufficient space on the verge/pavement should be left to accommodate a bus shelter and still enable pedestrian access around and to it. The footprint of a bus shelter is generally 4 metres long for a 3 bay shelter with a roof width of 1.6m. Full width end panels would be around 1.6 m but shelters can also be provided with half or quarter end panels. The verge/pavement adjacent to the North Square stop shown on the phase 1 plans would have sufficient space to have a shelter. However, concerns about the positioning of this stop have been expressed above.  Thought should be given to the way in which residents walk to the bus stop and access the buses. Pavements should be wide enough to enable residents to walk safely to the bus stop. In some cases assessing the Phase 1 plan, permeability from some of the housing areas is not direct. The plans for the North Square stop on the northern side of the road also imply that the stop which is on-carriageway is adjacent to an area of roadside parking. It would not be acceptable on safety grounds for passengers to have to pass through parked cars to access the bus. Furthermore, this would not also allow level access from the pavement for pushchairs or those with mobility impairments. All bus stops should have raised kerbs to enable level access from the pavement to bus.  Shelters should be able to incorporate real time information boxes. Has financial provision for the shelters and boxes been addressed?  The design of the shelter should be in keeping with other shelters in Crawley. i.e. flat or with a shallow elliptical roof and of similar branding/colour. Shelters should also have seating, lighting and a timetable case. (Currently advertsing shelters are provided by ClearChannel and we are about to award (Oct 2010) a contract to another company to provide non advert shelters at a number of locations throughout the town.  Figure 38.1, the Phase 1 movement plan shows only two pairs of stops for the temporary shuttle route. Could additional stops

114  Reference is made to 200 spaces being provided at the railway station. This is considered to be too many for a station of this size. It would attract trips from outside the area to the station and could also encourage residents of the neighbourhood to drive to the station rather than using more sustainable means, on foot, bike or by bus. There should be ample cycle parking provided at the station.  Figure 17.1 Pedestrian and cycle movement plan shows the network of foot and cycle paths. It is presumed that the cycle routes on the primary and secondary roads are actually provided on road. This is considered acceptable. Those routes shown on the plan with a dotted line are considered recreational. However, it is felt that these routes would serve more than just a recreational purpose as they help residents access the primary and secondary routes which provide access to services and facilities. It is unclear if some of these “recreational” routes share paths with pedestrians. If this is the case are they to be segregated i.e. with a white line. Consideration at the appropriate time should be given to signing destinations for cycle and pedestrian routes. E.g. to the neighbourhood centre, station, school etc  Where cycle and pedestrian routes cross roads, attention should be given to how this is achieved and whether any priority to cyclists / pedestrians is appropriate. Sometimes this is achieved with vertical deflection although this is often not desirable for other reasons.

COUNTY COUNCIL 15/10/2010

115  WSCC is concerned that there will be insufficient funding to deliver the full traffic signalled junction at Cheals roundabout upon completion of Phase 4 of the development (approx 2,100 dwellings).  WSCC is concerned that the plans used in the Design Statement would not appear to accord with the landscaping plans which include additional features (such as walls) which will need to be subject to RRRA. Therefore, either the Design Statement or landscaping plans need to be amended to be consistent.  WSCC has serious concerns about the impact of construction traffic accessing Phases 3, 4 and 5 through Phases 1 and 2 of the development and the damage that this is likely to cause on the roads which will be laid out to Manual for Streets standards. There would also be a significant amount of disruption to residents living in the new development whilst this occurs.  Although the design of the internal access road layout is broadly in accordance with Manual for Streets, certain speed criteria has to be met if a 20mph Zone or 20mph speed limit is to be accepted. At this stage it is not clear what speed limits will be generated within the development and these will need to be measured and monitored to provide the evidence base for the introduction of such a limit. If speeds do not meet the requirements, then additional features may be required on certain routes as necessary – Section 106 requirement.  WSCC requires that the shuttle bus service is of satisfactory quality and frequency and would want details of the service to be submitted for approval and reviewed as development progresses until such time as the Sullivan Drive bus gate is provided and Fastway services can access the site – Section 106 requirement.  It is also not clear what level of bus service subsidy will be required to encourage bus operators to divert the services into the development until additional patronage results in the extended services becoming self-financing. This has been mentioned in Appendix 1 of the proposed Section 106 Heads of Terms but no detail is given.  The red line of the planning application does not include the land required for the bus gates and their delivery is therefore uncertain. This would have significant implications for the applicant’s public transport strategy and WSCC would want confirmation that the bus gates can indeed be delivered. If not, then WSCC will be raising an objection to the planning application on the grounds that it is not satisfied that the public transport strategy can be delivered.  A Landscape Condition will be required to ensure that all perimeter planting to the south and west of the site (in particular) to be locally appropriate native species. This should also apply to planting on the highway including the roundabout.  The submitted landscaping and A264 access arrangement plans appear to give conflicting information about the proposals for decorative 'formal walls' along the entrance. It is suggested that these installations are not appropriate to the setting of the development and would be best located away from the main highway.  There are significant numbers of street trees planted. It would be beneficial to the green infrastructure approach if the connectivity that the canopies of these trees could provide is maximised through careful location planting. There is potential for the trees to provide connectivity at above ground level between existing trees and hedgerows across the site.  The opportunity should be taken to maximise the use of native grass and wildflower seed mixes where locations do not require a hard wearing turf construction.  The retention of existing hedgerows and trees ideally should be co-ordinated with the open space strategy so that the existing trees are designed into open spaces linked by green corridors. It is unfortunate that in phase 1 of the development this has not been achieved and there is a large area of public open space separated from the existing retained hedgerow trees by a line of proposed housing. The east/west road connections between the two elements are not shown as green gateways. Further design input could be made to achieve this in a more pro-active way – with further tree planting in particular. Two issues – to address as follows: avoid this happening in future phases by negotiation and feedback on design; additional design input to resolve lack of connectivity in detail design.

116  WSCC has no strategic ecological objections to the planning application subject to conditions.  No objection is made to the proposals on archaeological grounds, subject to suitable archaeological safeguards, as expressed in the detailed comments and proposed planning conditions, set out below.  In terms of direct impacts, the proposals should have no effect upon most of the visible ancient historic assets, save for new access roads driven through the historic hedge and bank, possibly a small-scale impact by construction of the Energy Centre Area upon the woodland boundary earthwork in Pondtail Shaw, and by new landscaping upon a large former quarry pit to the northeast of the proposed new Railway Station. The proposed Woodland Management Strategy for the site, especially for Pondtail Shaw, should take account of the desirability of conserving visible historic assets, such as the minepits, and where practicable of enhancing their setting and visibility to the public enjoying the woodland.  Buried historic assets (archaeological remains), such as the site of Little Bewbush Farm, the alluvial deposits of the Brook, areas of buried minepits north of the railway (near the surviving two earthworks), any associated iron ore processing near the minepits, and any presently unknown buried historic assets within the site, may be damaged or destroyed by new road, station and building construction and landscaping, excavation of attenuation ponds, and creation of the Energy Centre Area. If new buildings sitting above the former landfill are founded on concrete piles, these foundations may involve considerable excavation through the areas of surviving stream alluvial deposits, which may contain ancient artefacts as well as ancient pollen.  A series of heritage/archaeological measures, set out in Chapter 17 of the Environmental Statement, have been proposed, in order to mitigate the above actual and potential impacts of the proposals upon historic assets. These are broadly acceptable, but where ancient earthworks should not directly or indirectly be affected by the proposals, invasive investigation, where undertaken, should be small-scale only, intended to enhance understanding of these assets, but conserve the earthworks intact. The main mitigation strategy in relation to presently unknown/ as yet uninvestigated buried archaeological remains, involving observation by an archaeologist of all topsoil stripping works, and a strip-map-assess-sample-record approach to areas of buried remains, where exposed, is also acceptable.  In addition to these mitigation proposals, the proposed Woodland Management Strategy should take full account of visible historic assets within areas of woodland, and include proposals to improve and enhance, where appropriate, their visibility and the understanding of their historical significance. Heritage/ archaeological mitigation proposals should also include a strategy for the public enjoyment and best experiencing of the visible historic assets on the site, and of the recording and results of other heritage/ archaeological mitigation on the site.  There are no definitive public rights of way that cross the proposed site, but there is a public bridleway (BW 1550) that runs along the northern and western boundaries. The northern part of this bridleway forms part of the Horsham to Crawley cycle route, the width and surface of which has recently been improved to make it easier for cycle use. This cycle route heads eastwards from the bridleway north of the railway line towards Ifield West where it then follows a route through the existing urban area. That length of bridleway that continues southwards to the A264 and Buchan Park has not been improved and is difficult for cyclists and equestrians to negotiate. It does though appear fairly popular with walkers. The main deterrence for cyclists and equestrians from using the route is the poor surface, narrow width in places, the potential hazards of crossing the unmanned at-grade railway crossing, and the even more hazardous crossing of the A264 to access Buchan Park. The Countryside Access Forum for West Sussex (CAFWS) has advised that more walkers, cyclists and equestrians would use this bridleway if safe crossings of the railway line and A264 can be achieved. In this respect, a new eastern bridge will be provided by the development over the railway lines to be fully design compliant for equestrian use. A new Pegasus crossing will also be provided across the A264 as part of the secondary traffic signal access serving the development to allow bridleway users cross this busy road much more safely. This crossing, however, will be some distance west of the definitive route of the bridleway, so new links would have to be provided to

117  According to the Planning Statement, the applicants do not propose to deliver the secondary access and Pegasus crossing on the A264 until Phase 3 is built (2017-2020 and 800-1,550 dwellings). This is considered too late as there will be many people then living on the development who will want to access Buchan Park to the south of the A264 and safe provision should be made for them to do so. WSCC therefore considers that the delivery of the secondary access and Pegasus should be provided much earlier in the development, ideally as part of Phase 1.  It is noted that only two railway bridges are now proposed and understand that HDC/CBC members have formally agreed to this with the removal of the third western bridge indicated in the JAAP. According to the Planning Statement, the proposed eastern bridge will be designed for pedestrians, cyclists, equestrians, public transport (northbound only), emergency/service vehicles and private vehicles. The proposed central bridge will be designed for pedestrians, cyclists, public transport (southbound only), emergency/service vehicles and private vehicles. The eastern bridge is due to be delivered as part of Phase 4 (2019-2021), or by 1,550 dwellings. The central bridge is due to be delivered as part of Phase 5, or between 2,100-2,500. Although WSCC has no objections to the proposed phasing of these bridges, the removal of the western bridge for pedestrians, cyclists and equestrians will now concentrate these users onto motorised routes and WSCC is of the view that the central bridge should therefore also be designed for equestrian users. As regards, the state of the existing Public Bridleway 1550, the northern section of this has recently been improved by WSCC as it forms part of the Horsham to Crawley cyclepath leading to Ifield West. However, there is a long section of public bridleway to the south of this point which is substandard in nature and will need improving as part of the sustainable cycle and pedestrian links from the new development to the existing neighbourhood.

HIGHWAYS AND TRANSPORT

Transport Assessment and Forecast Transport Modelling

 The scope of the Transport Assessment (TA) has previously been agreed with the applicants using the SATURN forecast transport modelling work carried out during the preparation of the JAAP. This modelling work was generally considered to be robust for the JAAP and included an assessment of the likely modal split in terms of sustainable transport (rail, bus, cycling and walking) and the impact of residual development related traffic on three key junctions on the surrounding highway network. These junctions are the M23 Junction 11 (Highways Agency junction), the A23/A2220 (Cheals junction) and the A264/A2220/Sullivan Drive (Sullivan Drive junction). Consideration has also been given to the safeguarding of a route for a potential Crawley western relief road (CWRR) as required in the JAAP and for potential rat-running implications between the development through the neighbourhoods of Bewbush, Gossops Green, Ifield and Langley Green to the airport and industrial estates at Manor Royal.  In terms of the modelling assumptions relating to the development itself, this has changed slightly from the JAAP and whilst the main A264 roundabout access would remain the same, the secondary traffic signal junction has been revised from a left in/left out/right in junction to a left in/left out/right out junction in order to safely accommodate a new Pegasus crossing for Public Bridleway users. The secondary access junction was not identified in the scoping report for the TA as there was some uncertainty about its provision, but was considered in the forecast transport modelling at the JAAP stage, albeit in its former configuration.  As regards safeguarding a route for a potential CWRR, the applicant’s highway consultants have carried out some preliminary

118  The trip rate data used in the TA has been based upon two scenarios (with or without a new railway station), as agreed at the TA scoping stage, and these trip rates are broadly similar to those used at the Examination in Public. Although the secondary access is not included in the TA, the presence of one or two points of access from the site onto the A264 would make no difference to the SATURN model assignment, provided that neither results in unacceptable delays on the A264 as both accesses are on the same link. Although the model only indicated one access point, the detailed junction modelling includes both accesses with the main access roundabout being modelled using ARCADY and the secondary access using LINSIG. The public transport packages were included in the modelling, as described in the scenarios within Section 10.2 of the TA. A maximum 400m walking distance was assumed which is a standard parameter. Values for transit and waiting, which make up the components of public transport journey cost along with fares were agreed as part of the modelling validation. The early provision of public transport has now been modelled directly for Phase 2 (800 dwellings + foodstore) with a shuttle bus and mode choice results are shown at Table 77 in Section 14.1. Bus mode share is predicted to be 6% in the AM peak and 5% in the PM peak which is less than the 9% predicted for 2022 (full development + full public transport package). However, car share (both as driver and passenger) shows little variation and it is the walk/cycle mode share which the table shows as higher in Phase 2 than with the full development. As the model does not directly represent walk and cycle trips (other than public transport access trips) the table is not a pure reflection of the outputs of the model and includes adjustments from National Travel Survey figures, which are set out in Appendix C to the Scoping Report, which is Appendix A to the main TA. This methodology was previously agreed with WSCC in Spring 2008, when it was included in the supplementary report to the 3rd Draft TA as part of the JAAP process. From the information in Table 77, whether a predicted shift from walk/cycle to bus occurs as the development is built out is not relevant to the transport sustainability of the site or highway capacity issues. Bus service viability, however, may be relevant.  It is confirmed that the potential for rat-running through Bewbush and Ifield was an issue at the Examination in Public and this is why journey time surveys were conducted by the applicants in 2006 for routes via the main roads and via rat-run routes between Sullivan Drive roundabout and the A23/Ifield Avenue. The model select link analysis plots provided at Appendix E in the TA demonstrate to WSCC’s satisfaction that the model does not predict any significant levels of rat-running of development generated trips through Bewbush and Ifield which subsequently re-join the A23. However, as a result of development trip generation, the model indicates that improvements to the M23 Junction 11, Cheals junction and the Sullivan Drive junction will eventually be required. As previously advised, the M23 Junction 11 is the Highways Agency’s responsibility, so they will be commenting on the impact on their junction separately. As regards the Cheals and Sullivan Drive junctions, WSCC is inclined to agree with the suggestion of monitoring the Sullivan Drive junction with a clause in the Section 106 agreement requiring a financial contribution to improve this junction if needed. This is because this junction would only receive a material impact in the event that the modelled prediction of background traffic growth is realised. Peak hour flow comparisons to date show that peak hour flows have not increased between 2006 and 2010. As this includes a period prior to the current economic recession, there is some uncertainty as to how traffic flows will respond at such time as the local and national economy fully recovers. Therefore monitoring and securing a financial contribution through the Section 106 agreement is the best way to deal with uncertainty and minimise risk.  As regards the Cheals junction, WSCC is satisfied with the applicant’s analysis of the triggers for improving this junction. The

119  As regards the funding of the aforementioned improvements, the developer is proposing to 100% fund the construction of the A264 main roundabout access, A264 secondary access, and the Stage 1 improvement at Cheals roundabout. However, proportional contributions are being proposed towards the Stage 2 Cheals traffic signalised junction, the Sullivan Drive gyratory, and the M23 Junction 11 (Highways Agency) with the balance of funding coming from other potential developments in the area. However, since the JAAP was adopted, a number of potential developments in the area are now unlikely to be forthcoming and therefore additional funding opportunities will be limited. This of particular concern in relation to the Cheals roundabout junction as this junction will come under increasing pressure in future years as development progresses. And although the Stage 2 Cheals traffic signalised improvements are not required until much later in the development, it is likely that there would be a significant funding shortfall to deliver this improvement when needed. o WSCC requires that the Sullivan Drive junction be subject to continuous monitoring over the development period and a proportional financial contribution provided to mitigate the impact of the development if found necessary – Section 106 requirement. o WSCC requires that the interim works to the Cheals junction be delivered by the developer upon completion of the 300th dwelling on their development – Section 106 requirement. o WSCC is concerned that there will be insufficient funding to deliver of the full traffic signalled junction at Cheals roundabout upon completion of Phase 4 of the development (approx 2,100 dwellings).

Access Strategy and Design Statement  The proposed access strategy for the development was agreed as part of the JAAP process based upon a phasing plan put forward by the developer at that time. However, this phasing plan has now changed and as a result, the access strategy has been reviewed.  Previously, the new roundabout access onto the A264 was to have been used by construction traffic to re-contour the site and build out the early phases whilst the secondary traffic signal junction onto the A264 was to be have been used as the access point for the new dwellings. This was to ensure that construction and other traffic was segregated to reduce disruption and potential hazards for new residents/visitors. However, as a result of the phasing changes, the first phases of the development will now be accessed from the new roundabout whilst the secondary junction will be used by construction traffic.  The construction and completion of the new A264 roundabout will therefore be required prior to the occupation of any dwelling

120  As mentioned previously in the PRoW section, the proposed delivery of the secondary junction is considered much too late in the development programme as between 800 and 1,550 dwellings could be occupied on the site before its provision. This would mean that there would be no safe crossing point of the A264 for those new residents who wish to access the public open space to the south of the main road. This is considered unacceptable and I would require the secondary traffic signal junction to be provided as part of Phase 1 and before significant demand by residents arises.

 As regards the Design and Access Statement, this has previously been submitted to WSCC for approval and only one departure from standards was identified which was subsequently signed off. However, this has been again reviewed in light of the further documentation submitted and WSCC has some further comments to make :  VAS sign: Although WSCC would want to reserve the right to require the triggering of the VAS (Roundabout - Slow Down Sign) by inappropriate approach speeds on the A264 approach to the roundabout, it is suggested that a switched system should also be installed so that the sign may either be activated by loops in the builders merchants access road in addition to the speed of traffic on the A264. A commuted sum for maintenance will be required for the loops and sign.  Vertical features within/adjacent to the highway: WSCC questions (again) the appropriateness of using anti ram-raid bollards to protect the pond on the entrance to the site. They are not a recognised Vehicle Restraint System. The Road Restraint Risk Assessment (RRRA) needs to be amended to consider these as a hazard in themselves. The drawings in the Design Statement Doc Ref R04/RevA do not accord with information provided by the landscape architect. It will therefore be necessary for the developer to seek further approval for the inclusion of any additional Planting, landscaping and walls or other vertical features that were not included within the submitted (RRRA) documentation, and to submit a revised version of the same.  The developer shall submit a landscaping maintenance plan that includes details of who will be responsible for maintaining all areas and infrastructure within the site. It will also be necessary for the developer to enter into legal agreement(s) to cover maintenance liabilities for areas do not form parts of private plots (see below).  One other issue of particular concern to WSCC is the construction traffic routing for Phases 3, 4 and 5. According to the Phasing Plan, construction access to these would either have to be provided through Phases 1 and 2 which will already have been occupied and served by access roads to Manual for Streets standards with special surfacing treatments and speed reduction features. The routing of construction traffic through these early phases to build out Phases 3, 4 and 5 will cause considerable disruption for existing residents and would require construction traffic to use internal access roads which will not have been designed for this purpose.  WSCC is concerned that the plans used in the Design Statement would not appear to accord with the landscaping plans which include additional features (such as walls) which will need to be subject to RRRA. Therefore, either the Design Statement or landscaping plans need to be amended to be consistent.  WSCC has serious concerns about the impact of construction traffic accessing Phases 3, 4 and 5 through Phases 1 and 2 of the development and the damage that this is likely to cause on the roads which will be laid out to Manual for Streets standards. There will also be a significant amount of disruption to residents living in the new development whilst this occurs – Section 106 requirement.

Access and Parking Layout for Phase 1

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 According to the TA, the following transport proposals and mitigation measures are proposed for Phase 1:- Main access roundabout; Small shuttle bus operating to and from site and Dorsten Square (unless extension of a bus service agreed with Metrobus); Contribution to deliver new slip road at A2220 approach to Cheals roundabout; Foot/cycle route to Kilnwood Vale; Travel Plan.  The provision of access to Phase 1 from the new A264 roundabout is acceptable in principle. However, it is clear that this phase of the development will be physically isolated from shops, schools and other local facilities in Bewbush and Crawley for some considerable period of time until the new neighbourhood centre is developed as part of Phases 2 and 3. It is therefore essential that public transport and cycle/pedestrian links are introduced to serve Phase 1 during this interim period to better integrate it with the adjoining neighbourhood and to reduce dependence on the private car, so that travel planning targets can be met. In this respect, the applicants are proposing to introduce a small shuttle bus service between the early phases of the development and Dorsten Square until such time as the Sullivan Drive bus gate is provided to allow Fastway or an extension of another service to access the site (comments on the proposed shuttle bus service are provided under public transport). WSCC would also require the applicants to deliver the new slip road at the A2220 approach to Cheals roundabout as this is required in capacity terms to mitigate the impact of Phase 1. The timing of this improvement would have to be secured in the S106 agreement to ensure delivery by the occupation of the 300th dwelling. As regards the proposed foot/cycle route between Phase 1 and Bewbush, this is shown as running within the site boundary along the northern side of the A264 to Sullivan Drive and is acceptable in principle, although users will have to cross the main construction access at one point.  The access and parking layout for Phase 1 has been designed to the philosophy of Manual for Streets which promotes a design led approach to reducing speeds. It is proposed that the development will form a ‘Homezone’ with a blanket 20mph Zone or 20mph speed limit covering all internal access roads. WSCC generally support this approach but it is important that the layout meets the necessary criteria for either a 20mph Zone or 20mph speed limit in order for it to be self-enforcing and hence supported by the Police. This has been fairly challenging as certain internal access roads need to be designed to accommodate buses and lorries which restricts the amount of curvature in the road. However, WSCC considers that submitted layout is generally acceptable, but that the layout needs to be monitored and additional features introduced as necessary in order to keep speeds down.  As regards materials and features, it is not proposed to introduce any raised junction platforms or block paving on the main bus routes serving the development, so speed reduction on these routes must be design led. It is likely that the widespread use of surface dressing type treatments will be used throughout the development. WSCC will liaise closely with HDC and the developer to ensure that satisfactory materials are used on those areas to be adopted as public highway.  Although the design of the internal access road layout is broadly in accordance with Manual for Streets, certain speed criteria has to be met if a 20mph Zone or 20mph speed limit is to be accepted. At this stage it is not clear what speed limits will be generated within the development and these will need to be measured and monitored to provide the evidence base for the introduction of such a limit. If speeds do not meet the requirements, then additional features may be required on certain routes as necessary – Section 106 requirement.  There have been earlier discussions on the proposed level of car parking to be provided to serve the different dwelling types and the other uses being proposed within the development. The proposed parking standards to be used are indicated in Section 4.4 of the TA. These standards are considered acceptable, but it is essential that access and parking layout is well designed so that on-street parking does not occur on bus routes or in locations where service access may be obstructed or compromised.

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Public Transport

 The public transport strategy to serve the development has been discussed with WSCC and Metrobus and is generally in accordance with the JAAP and therefore acceptable in principle. However, the delivery of the strategy as a result in the changes to the development phasing does cause WSCC some concern. According to the TA, the agreed public transport strategy cannot start to be implemented until the first bus gate is provided from the development to Sullivan Drive. According to the TA it is proposed to build this bus gate and connecting access road to Phases 1 and 2 as part of Phase 3(between 2017-2020) when between 800-1200 dwellings could be occupied. The applicants are therefore proposing to operate a shuttle bus to serve the two early phases of the development from 2012 until such time as the bus gate is built which could be at least 5 years and possibly 8 years into the development. This shuttle service would link the first two phases of the development with the Bewbush neighbourhood centre and would need to be of sufficient quality, frequency and capacity to encourage new residents to use it. However, as passengers using the shuttle bus would have to change at Bewbush to access Fastway and other bus services, the service will not be seamless and there will be delays whilst passengers wait for connecting buses. This is likely to deter bus usage in the early phases as embedded bus services will not become available within the development from commencement of development which will naturally have an impact on travel planning decisions.  As regards the interim shuttle bus service, WSCC would want to ensure that this service is of satisfactory quality and frequency because it would, effectively, be the only bus service serving the development for a number of years. WSCC would also want the shuttle bus to start operating earlier upon occupation of 50 dwellings.  It is also not clear what level of bus service subsidy will be required to encourage bus operators to divert the services into the development until additional patronage results in the extended services becoming self-financing. This has been mentioned in Appendix 1 of the proposed Section 106 Heads of Terms but no detail is given.  In addition to the above comments, it is noted that the red line of the planning application does not include the land required for the bus gates to connect to both Sullivan Drive and Woodcroft Road and there are large areas of third party land between the site boundary and the public highway. It is essential that this land is included within the red line of the application and the formal agreement of the third party landowner obtained, otherwise the public transport strategy cannot be delivered and the transport modelling submitted in the TA would not be robust.  WSCC requires that the shuttle bus service is of satisfactory quality and frequency and would want details of the service to be submitted for approval and reviewed as development progresses until such time as the Sullivan Drive bus gate is provided and Fastway services can access the site – Section 106 requirement.  It is also not clear what level of bus service subsidy will be required to encourage bus operators to divert the services into the development until additional patronage results in the extended services becoming self-financing. This has been mentioned in Appendix 1 of the proposed Section 106 Heads of Terms but no detail is given.  The red line of the planning application does not include the land required for the bus gates and their delivery is therefore uncertain. This would have significant implications for the applicant’s public transport strategy and WSCC would want confirmation that the bus gates can indeed be delivered. If not, then WSCC will be raising an objection to the planning application on the grounds that it is not satisfied that the public transport strategy can be delivered.

Travel Planning

123  There is a Travel Plan Strategy in Section 9 of the TA, but more details about implementation and monitoring need to be submitted which will evolve as and when new transport links and measures are delivered. This will need to be also covered in the Section 106 agreement.

EDUCATION

 Detailed discussions have taken place between WSCC and the applicants as regards the provision of facilities or financial contributions towards pre-school, primary, secondary, sixth form education and youth. This has now been agreed and WSCC’s requirements are to be secured in the S106 agreement supporting the development.  Pre-school - There is a requirement in the JAAP to provide a pre-school or nursery facility. The developers have agreed to provide space in the new neighbourhood space, a stand-alone facility or provide an appropriate financial contribution.  Primary – There is a requirement in the JAAP to provide a new 2-3 form entry primary school. The land required for this school has been identified as being close to the new neighbourhood centre and is acceptable in principle to WSCC, although the area of land may need to be reconfigured to meet specific requirements for playing areas. The timescale for the delivery of a fully serviced primary school site has been agreed and financial contributions are being secured in the S106 agreement.  Secondary – A financial contribution is being secured in the S106 agreement towards providing secondary education places based upon WSCC’s contributions methodology.  Sixth Form – There is no specific requirement in the JAAP as it was assumed that sixth form was classed as secondary education. However, discussions are continuing with the applicant on this.  Youth - I understand that HDC is leading on this and will specify any requirements.

LIBRARIES

 Library services have indicated that they would like the option to provide a sub-library facility if the new community building with a maximum area of 150sq.m. However, the facility provided must not be stand-alone and would need to be combined with a range of other community facilities in order to share operational costs.

FIRE AND RESCUE SERVICES

 The requirement to provide fire hydrants to the satisfaction of the Fire and Rescue Service is being secured in S106 planning agreement supporting the development.

WASTE PLANNING

 WSCC Waste Planning has advised that there is a requirement on the existing landfill operator to restore part of the site is to agriculture following the cessation of landfilling operations. However, in this particular case, it has been known for some time about the plans to redevelop the site. WSCC has therefore not been pushing too hard for any aftercare as it could essentially be a waste of time and money in practical terms. WSCC Waste Planning has previously offered technical advice to both the applicants and HDC on the site, but it is now up to the local planning authority to decide how to resolve the issues on site. Once the planning permission for the site is granted, WSCC should be satisfied that this supersedes the extant landfill /

124

WSCC addendum report received 20/12/2010 further to additional information submitted by the applicant.

 To mitigate the impact of the A264 access works on the AONB to the south, WSCC will require a scheme of appropriate planting within the public highway together with a long-term management plan that requires the developer to maintain the planting until completion of the development in 2023 with commuted sum payments for a 13 year period post- completion – Section 106 requirement.  The applicant has now agreed to the inclusion of this requirement in the Section 106 agreement with WSCC. The requirement will be for the developer to carry out native species planting within the highway to be maintained by the developer for a period of 13 years until the completion of the development. There will also be a requirement for a commuted sum payment to maintain the planting for a further period of 12 years post-development completion until the trees have reached semi-maturity.  The secondary traffic signalised access and Pegasus crossing needs to be delivered much earlier in the development programme to provide a safe crossing point to the AONB for new and existing residents.  Discussions have taken place with the applicant and it has been agreed that the secondary access and crossing point will now be completed prior to the construction of the 300th dwelling on the development. This is much lower than the 800th dwelling previously proposed and will ensure that a crossing is in place much earlier in the development process to the benefit of existing public bridleway users and new residents. This will be a Section 106 requirement.  The area shown for the new A264 access roundabout will incur significant loss of tree cover as a result of the development. The amount of replacement planting shown on the proposals in this location does not provide sufficient buffering or containment of the development from the west and is not in accordance with the adopted WSCC Landscape Strategy.  WSCC and HDC landscape officers require that there be a requirement for a planning condition requiring the applicant to provide thick hedgerow planting on the access road embankment and 20m width woodland planting on the boundary of the reserved land. I understand that the HDC landscape officer will be recommending an appropriate planning condition.  Further investigation into the cumulative visual impact of the proposed (outline) vertical orientation feature in the Circus, and the proposed height of the Energy Centre Stack is required. Views from the AONB and land to the north of the development site, in particular, must be considered.  I understand that the HDC landscape officer has been considering this issue.  Further details are required for the provision of further structure and succession planting within the existing retained green corridors together with the inclusion of a significant numbers of parkland trees which are located to allow the development of their full, natural shape.  I understand that the relationship of the neighbourhood park to the eastern greenway has been discussed at a recent meeting between the applicant and HDC. I further understand that they are not willing to compromise on this so any concerns will have to be included with any other design issues. I note that this is being considered by the HDC landscape officer.  The central bridge over the railway line would need to be designed to safely accommodate equestrian users.  Both railway bridges will be designed to safely accommodate equestrians, but only the eastern bridge will have a segregated equestrian route. This is considered acceptable to WSCC.  WSCC requires that the Sullivan Drive junction be subject to continuous monitoring during the development period and

125  The Sullivan Drive junction is not predicted to be close to capacity until much later in the development programme and will be monitored after the commencement of Phase 4 (1151st dwelling) and a financial contribution made towards future improvements if necessary. This is acceptable and will be secured in the Section 106 agreement with WSCC.  WSCC requires that the interim Stage 1 improvement of the Cheals junction be delivered by the developer upon completion of the 300th dwelling on their development – Section 106 requirement.  This has now been agreed with the applicant and will be secured in the Section 106 agreement with WSCC.  WSCC is concerned that there will be insufficient funding to deliver the full Stage 2 traffic signalled junction at Cheals roundabout upon completion of Phase 4 of the development (approx 2,100 dwellings).  The applicant is prepared to make a sizeable proportional contribution to a Stage 2 full traffic signalisation at the Cheals junction upon completion of Phase 4 of the development. However, there would still be a significant funding shortfall if this scheme is to be delivered and there is considerable uncertainty that the funding shortfall can be made up by contributions from other developments by the time required. The applicant has therefore been requested to provide an alternative modified roundabout option that was initially considered as part of the traffic modelling work in February 2008. Although not as effective as the traffic signalisation scheme for improving pedestrian/cycle links or bus priority, a modified roundabout scheme would improve traffic capacity whilst still retaining the existing pedestrian/cycle crossing points and would be much more deliverable in terms of funding. A modified roundabout scheme could also be designed to complement the Stage 1 interim improvement therefore being more cost effective. It would also have least impact on the access arrangements for the proposed new fire station site on land in the south west corner of the junction.  WSCC is concerned that the plans used in the Design Statement would not appear to accord with the landscaping plans which include additional features (such as walls) which will need to be subject to RRRA. Therefore, either the Design Statement or landscaping plans need to be amended to be consistent.  Both WSCC and HDC landscape officers have objected to the curved wall features. It is understood that the applicant’s are now proposing a ‘living wall’ which is more acceptable in landscaping terms.  WSCC has serious concerns about the impact of construction traffic accessing Phases 3, 4 and 5 through Phases 1 and 2 of the development and the damage that this is likely to cause on the roads which will be laid out to Manual for Streets standards. There would also be a significant amount of disruption to residents living in the new development whilst this occurs.  The applicant has agreed to a planning condition requiring that a full construction traffic management plan is submitted to and approved by the LPA indicating the proposed routing of construction traffic from the A264 to each phase of the development.  Although the design of the internal access road layout is broadly in accordance with Manual for Streets, certain speed criteria has to be met if a 20mph Zone or 20mph speed limit is to be accepted. At this stage it is not clear what speed limits will be generated within the development and these will need to be measured and monitored to provide the evidence base for the introduction of such a limit. If speeds do not meet the requirements, then additional features may be required on certain routes as necessary – Section 106 requirement.  The applicant has agreed to carry out speed surveys once the roads have been constructed and ready for use. It is contended that traffic speeds will reduce with higher volumes of traffic using the roads as each phase is delivered. There will need to be a mechanism in the S106 planning agreement to reflect this.  WSCC requires that the shuttle bus service is of satisfactory quality and frequency and would want details of the service

126  The specification and frequency of the shuttle bus service along with the diversion of other services will be included in the S106 agreement. However, Metrobus has advised that they would like to see a more frequent 20 minute service during the day with services lasting longer into the evening. Although WSCC is content for any bus subsidy to be agreed between the applicant and the bus operator, there needs to be an adequate mechanism in the S106 planning agreement to enforce the provision of this bus service so as to embed bus services within the development at an early stage.  It is also not clear what level of bus service subsidy will be required to encourage bus operators to divert the services into the development until additional patronage results in the extended services becoming self-financing. This has been mentioned in Appendix 1 of the proposed Section 106 Heads of Terms but no detail is given.  There is likely to be a significant level of subsidy required to encourage bus operators to extend services into the site during the early years. Although WSCC is content for any bus subsidies to be agreed between the applicant and bus operators, there needs to be an adequate mechanism in the S106 planning agreement to enforce the provision of the specified bus services so as to embed bus services within the development from an early stage.  The red line of the planning application does not include the land required for the bus gates and their delivery is therefore uncertain. This would have significant implications for the applicant’s public transport strategy and WSCC would want confirmation that the bus gates can indeed be delivered. If not, then WSCC will be raising an objection to the planning application on the grounds that it is not satisfied that the public transport strategy can be delivered.  It is understood that the developer is in the process of acquiring the necessary land for the bus gates from Crawley BC and that separate planning application may be submitted for these features which are outside of the red line of this planning application.

WSCC Comments on Travel Plan

The proposed Travel Plan in the TA has been reviewed and there are a number of points which need to be addressed. The previously recommended Green Travel Plan planning condition therefore needs to remain.

127  How detailed application comply with ES.  Strategy has been submitted to support the detailed applications describing how the local community will aid the management of ecologically sensitive sites as nature reserves, i.e. LNR, Pocket Parks.  Phase 1 – an improved scheme of works, buffer zone and ecological enhancement scheme to be submitted.  Phase 1 – an improved native planting scheme  Heritage Asset Mitigation Strategy  Programme of archaeological work including a Written Scheme of Investigation has been submitted to and approved by the local planning authority in writing  A construction traffic management plan has been submitted to and approved by the LPA indicating the proposed routing of construction traffic from the A264 to each phase of the development.  Satisfactory provision made within the site for secure construction compounds, construction materials storage, the loading, unloading and turning of delivery vehicles and an area to be set aside for construction employees parking. In accordance with details to be approved by the LPA.  The existing Public Bridlepath 1550 shall be improved to cyclepath standards to the satisfaction of the LPA where it forms part of the new cyclepath connection between the development and the Bewbush neighbourhood.  No dwelling or buildings hereby permitted shall be occupied unless and until an access from the A264 has been designed, laid out and constructed in accordance with full plans and construction details (including safety audits) to be submitted and approved to the satisfaction of the LPA.  The development hereby permitted shall not be occupied unless and until a footpath/cyclepath route has been designed, laid out and constructed to base course level between Phase 1 and Bewbush. The footpath/cyclepath shall be completed to wearing course level and provided with street lighting prior to the occupation of the 50th dwelling; all to the satisfaction of the LPA.  The development hereby permitted shall not be occupied unless and until it has been provided with a satisfactory means of access and car parking in accordance with a specification to be submitted and approved by the LPA.  The adoptable access roads serving the development hereby permitted shall not be constructed unless and until details of their design, layout and construction have been submitted to the LPA for approval.  No dwelling hereby permitted shall be occupied unless and until the access road to any occupied dwellings has been completed to base course level with the road construction to be completed within 12 months or to a later date to be agreed with the LPA.  Wheel washing equipment has been installed in a location to be approved by the LPA.  A comprehensive maintenance plan shall be submitted to the LPA clearly setting out future maintenance responsibilities for all areas of land within the development.  Satisfactory parking arrangements in accordance with plans to be submitted and approved.  The proposed bus gate links from the development to Sullivan Drive and Woodcroft Road shall be designed, laid out and constructed in all respects to a specification (including safety audits) to be submitted to and agreed by the LPA.  Prior to the occupation of any dwelling, a Green Travel Plan shall be submitted for approval by the LPA setting out details of the proposed sustainable transport initiatives.

Informative

128 Planning permission has been granted on the basis that, insofar as the adoptable highway elements of the design are concerned, the developer has checked his design for conformity with design standards and highlighted all the departures and relaxations from highway design standards in their submission and these have subsequently been agreed by WSCC, as highway authority, through the departures and standard approval process outlined in GD1/08 of the Design Manual for Roads and Bridges. Should non-compliance with highway design standards be identified, the developer may be required to submit new compliant designs for planning approval and/or undertake remedial works to the satisfaction of the highway authority at its own expense.

CONSULATION 16 letters have been received which can be summarised as follows: RESPONSES  Further clarification is required on the main pumping station, land employment uses, energy centre, engineering operations FROM associated with the landfill remediation and associated infrastructure, floor attention ponds and noise attenuation landform. NEIGHBOURS,  Concerns are raised regarding the noise from the development, and in particular the bypass. RESIDENTS OF  Concerns are raised regarding light pollution 24 hours a day. NEIGHBOURING  The development will increase pollution. AREAS AND  Concerns are raised to the emissions from the chimney. OTHER  The soil in the area is of very poor quality. INTERESTED  Soil guideline values are not safe levels of exposure and marginally exceeding these levels is till exceeding. PARTIES  Houses in this area suffer from damp due to the moisture in the soil  The EA and WSCC state they have no evidence of the importation of prohibited waste and disposal by burning. However, there have been 5 fires on the site plus 14 further occasions when fires are likely to have taken place. In some instances the Fire Brigade were informed there would be controlled fires on the site.  The operators deposited construction waste at another site.  The presence of contaminates makes the site unsuitable and will impact future residents.  How can the long term stability of the site be ensured?  The proposal is a missed opportunity is terms of its carbon footprint.  Concerns are raised to the loss of the park and the safety of children playing.  Consideration should be taken for the need of an archaeological sweep.  The proposal will result in the felling of many trees and have a harmful impact on wildlife.  A wider tree barrier is requested around Kilnwood house to prevent overlooking.  The ancient woodland is home to at least one badger set and roe deer, barn owls, bats and woodpeckers.  Access to the countryside will be via Kilnwood Lane which is a privately owned and maintained bridal path.  Dogs, horses, cyclists will proliferate as the development progresses – Kilnwood Lane will be seen as a convenient gateway to the countryside.  Great Crested Newts have been found in a pond adjacent to the property Kilnwood End.  Wildlife mitigation should be submitted before a decision is made on the application.  The proposal would impact on private views from neighbouring properties (a private view is not a material planning consideration)  Concerns are raised to the impact on water supply and the potential for drought.

129  It is disputed that the affects of the development will be negligible on local residents.  Parallels can be seen with the design proposed for phases 4&5 when compared to existing gardens which back onto the countryside were gates have been installed and rubbish left behind these fences. The countryside has been turned into wasteland.  Concerns are raised to the density of the scheme.  Concerns are raised to the impacts of crime in an unlit land backing onto back gardens which could be a ‘getaway’ route.  Masterplan and housing trajectory is significantly altered when compared to the public consultation as part of the JAAP. This could be open to legal challenge.  The proposal should provide 40% affordable housing.  A railway station should be built.  The A264 is very difficult to get onto from the Bewbush roundabout. Therefore concerns are raised to the additional access. Traffic lights are suggested similar to Peas Pottage.  The development will put a burden on the A264 and supporting roads. There are already existing problems.  The proposal would have a detrimental impact on the residents of Bewbush.  Will there be an option to link Ifield to this development?  Will the development adversely affect property prices in Ifield? (this is not a material planning consideration)  Should there be an access roundabout from Sullivan Drive at the roundabout?  The associated infrastructure and surrounding infrastructure will have a harmful impact on future occupiers.  Horsham DC will receive the benefits of this development whilst Crawley BC will receive the impacts.

130 Crawley Borough Council

Report No: PE23

Report to Development Control Committee

7th March 2011

CBC consultation response on planning application for a proposed new neighbourhood on land West of Bewbush

HDC Application DC/10/1612

CBC Reference: CR/2010/0423/CON

1. Key Points

1.1 This report considers planning application DC/10/1612 submitted to Horsham District Council for a new neighbourhood West of Bewbush and sets out Crawley Borough Council’s comments and response as a statutory consultee.

2. Recommendations

2.1 The Committee is recommended to raise NO OBJECTION to the planning application subject to:

1. HDC seeking further clarification on the outstanding detailed design issues set out in paragraph 9.31 of this report which the applicant must incorporate into the DAS. 2. The receipt of further design revisions to address specific concerns with the Phase 1 layout outlined in the report paragraphs 10.21 –10.30 and authorise the Head of Planning and Environmental Services to respond in writing to these revisions and provide a list of suggested conditions if these concerns are satisfactorily addressed. 3. The imposition of the conditions listed under section 13 of the Officer report, the precise wording of which to be agreed with CBC.

1 4. CBC Officers being consulted, as part of the continued joint working arrangements, on the content of the emerging S106 agreements.

ANGELA TANNER

Head of Planning and Environmental Services

2 3. Reason for reporting to Committee

3.1 The application is major strategic development affecting Crawley Borough in particular Bewbush and Ifield. In addition, under the terms of the Planning Performance Agreement, the formal response from Crawley Borough Council in its role as a ‘statutory consultee’ is required to be considered by the Development Control Committee.

4. Background to the planning consultation

4.1 This application has come forward through an extended planning process as the result of collaborative joint working with Horsham District Council (HDC). The western side of Crawley was identified in the then West Sussex Structure Plan 2001 and required that the development area should accommodate 2,500 dwellings and associated uses. This strategic allocation was incorporated into both Council’s LDF Core Strategies both now adopted and the Joint Area Action Plan(JAAP) was the mechanism chosen by the Authorities to steer the development of this Strategic location.

4.2 Crawley Borough Council (CBC) have been joint working formally with HDC since February 2006 to formulate a JAAP for the Strategic Development Location West of Crawley. The JAAP allocates land west of Bewbushfor 2,500 dwellings and associated development and infrastructure and contains a series of objectives, policies and a conceptual masterplan to steer and guide the location, nature and form of development. The JAAP was subject to a public examination and was formally adopted by both Council’s in July 2009.

4.3 In September 2008 reports were taken to both HDC and the CBC General Purposes Committee setting out the proposed procedures and mechanisms for the determination of planning applications submitted within the JAAP area. Both Councils agreed to the principle of joint working at Officer and Member level for the consideration and determination of applications West of Bewbush and to the concept of a specially constituted Development Control Committee with Members of both Councils to determine the application/s.

4.4 The joint working arrangements established for the JAAP preparation have continued into the pre-application and post application submission stages for the development. A Planning Performance Agreement (PPA) between HDC, CBC and the developer (Crest) was signed in February 2009. This agreement outlined the development ‘vision’, objectives for the delivery of the project and procedural arrangements for collaborative working through the pre- application stages. It also proposed a timeframe for the consideration of the application, application consultation arrangements and intended decision making arrangements. The PPA agreed to a cooperative approach to take the project forward, it is not a legal agreement nor does it guarantee the eventual grant of planning permission.

4.5 On 15th December 2010 HDC took a report to its Council setting out the proposed decision making arrangements for this planning application. Following Counsel advice that given no part of the red edge application site was within Crawley Borough, HDC alone possesses the statutory function to

3 determine the planning application and therefore the joint decision making committee approach previously envisaged has had to be put aside. The need for continued joint working on this development is recognised and the involvement of Members and Officers of CBC in this project is important.

4.6 The report agreed that 4 Members of Crawley Borough Council could be co- opted onto the Development Control North Committee with the power to speak at the meeting but would have no voting rights, there would be continued involvement of CBC officers in Steering and specialist meetings in connection with the application and, that in the event the application is permitted, a further report is brought back to Council to agree consultation arrangements with CBC on subsequent reserved matters and other applications. CBC has put forward its Members to HDC to be co-opted onto this committee.

4.7 In conclusion, Crawley Borough Council has been consulted and is a statutory consultee in respect of this planning application and this report provides an Officer recommendation for Members to provide a response on this basis.

5.0 The Application Site

5.1 The application site comprises a 132 ha parcel of land located on land just beyond the western boundary of the Borough adjacent to the built-up area boundaries of Ifield West and Bewbush.

5.2 The land within the site is currently a mixture of agricultural land, woodland and a former inert landfill. The site is intersected SW to NE by the Arun Valley railway line, the A264 extends along the southern site boundary beyond which is the rising agricultural / woodland of the High Weald AONB. The eastern boundary is a wooded tree belt which runs along the Borough Boundary. The northern boundary abuts a wooded footpath / rural road Kilnwood Lane and the site’s western boundary extends along the boundary of Kilnwood House and north to south along an existing track and level crossing adjacent to the subway serving Holmbush Farm.

5.3 The site to the north of the railway line slopes down from Kilnwood Lane to the railway line. The land is generally open fields except for Capon Grove which is an area of woodland located centrally within this portion of the site. There are other pockets of woodland and within the field boundaries there are a large number of established trees. The field boundaries generally delineate the water courses and drains crossing this section of the site which flow towards the railway line to the south.

5.4 To the south of the railway line the site can be divided into two distinct areas. The western portion includes an area of woodland known as Pondtail Shaw and 3 large agricultural fields between Pondtail Shaw and the A264. The fields are generally fairly level and intersected north / south by Hoppers Brook which drains north into Pondtail Shaw. Pondtail Shaw is intersected east/west by Bewbush Brook which drains across the application site towards the east.

5.5 The eastern section of the site is former landfill, the ground level in this location has been raised above natural ground level. A small central portion

4 of the site is still used for concrete crushing operations but much of the site has been covered and is used as rough grazing land. As a result of the works, the original field boundary pattern has been lost from much of this section of the site however; a belt of trees runs east to west close to the railway marking the Bewbush Brook Watercourse and the access track to the crushing operations also has an established field/tree boundary.

5.6 With the exception of a footpath running roughly parallel with the north east boundary (adjacent to Ifield West) and linking to a level crossing, there are no public rights of way across the site. On the eastern edge of the site, adjacent to Bewbush is the wooded bridle path which forms part of Crawley ‘Greenway’ beyond which lie residential properties in Chetwood Road, Manor Fields and playing pitches / open space. Vehicular access to the site is via a single access point onto the A264 serving the landfill / existing crushing operations. Beyond the western boundary is a pedestrian access track and level crossing linking the A264 and Kilnwood Lane. Kilnwood Lane is a narrow vehicular access running halfway along the northern boundary which turns into a bridleway as the route approaches Ifield West.

5.7 Within the site there are two areas of Ancient Woodland at Capon Grove and Pondtail Shaw designated post adoption of the JAAP. The land along Bewbush Brook is within the EA floodplain. The landfill site was closed in 2006 and has since been the subject of 2 years of environmental monitoring. Surrender of the waste management licence was accepted by the EA in January 2009.

6.0 The Proposed Development

6.1 The submitted application is a ‘Hybrid’ planning application for a new neighbourhood West of Bewbush referred to in the application as ‘Kilnwood Vale’. The hybrid application seeks to establish outline details for the principle of the whole neighbourhood, detailed planning permission for ‘Phase 1’ residential development, land remediation works and landscaping along the A264. In detail, the application comprises the following elements as set out below.

6.2 Outline planning permission is sought for:  Development of approximately 2500 dwellings, new access from A264 and a secondary access from A264, neighbourhood centre, comprising retail, community building with library facility, public house, primary care centre and care home, main pumping station, land for primary school and nursery, land for employment uses, new rail station, energy centre and associated amenity space.

6.3 Full planning permission is sought for:  Engineering operations associated with landfill remediation and associated infrastructure including pumping station.  Construction of a 3 to 6 metre high (above ground level) noise attenuation landform for approximately 700 metres, associated landscaping, pedestrian/cycleway and service provision.  Development of Phase 1 of 291 dwellings, internal roads, garages, driveways, 674 parking spaces, pathways, sub-station, flood attenuation ponds and associated amenity space.

6.4 The application is supported by the following technical documents. o Environmental Impact Assessment including the following reports – Landscape and Visual Assessment, Phase 1 Habitat Survey (Bat, Badger, Dormouse, Bird Breeding, Reptile Surveys), Protected species and tree mitigation strategy, Woodland Management Scheme (Pondtail Shaw / Capon Grove), Archaeological Survey, Land Quality Assessment, Soils and Agricultural Land Classification report, Geotechnical Site investigation report, Remediation Strategy, Transport Assessment, Travel Plan, Noise Survey, Air Quality report, PPS25 Flood Risk Assessment; o Design and Access Statement (including a Strategic Design Code.) o Open Space Strategy; o Arboricultural Survey; o Site Waste Management Plan; o Utilities Report; o Design Statement – A264 Accesses; o Planning Statement; o Phase 1 Street Lighting Report; o Sustainability Statement; o Draft Unilateral Agreement to WSCC and HDC for infrastructure provision.

6.5 Details of each element of the application listed in 6.2 and 6.3 above are set out below: Development of approximately 2500 dwellings, new access from A264 and a secondary access from A264, neighbourhood centre, comprising retail, community building with library facility, public house, primary care centre and care home, main pumping station, land for primary school and nursery, land for employment uses, new rail station, energy centre and associated amenity space.

6.6 The applicants are seeking to secure the principle of a neighbourhood of approximately 2,500 dwellings and the mix of uses specified above. The access matters to be considered in detail at this stage with all other matters reserved.

6.7 The applicants in their supporting planning statement state that the development would deliver the following:  A community building within the neighbourhood centre to provide flexible space and incorporate the library (although it is understood that WSCC are now seeking a ‘Resources Centre’ rather than a library),  A primary health care centre located with the neighbourhood centre,  A range of retail units within the neighbourhood centre anchored by a multi- purpose supermarket (total retail floorspace not exceeding 2,500 sq m net),  Housing Mix consisting of the following overall site mix of: 1 and 2 bed flats – 25%, 2 bedroom houses – 17%, 3 bedroom houses – 32% and 4/5 bedroom houses – 26%.

6.8 20% affordable housing is proposed within the first phase of development (291 dwellings) with 25% proposed for phases 2 and 3 (between 874 and 1100 dwellings) and 36% proposed in phases 4 and 5 (up to 1100 dwellings). If the land reserved for the Western Relief Road (WRR) is not required in full 40% of the units would be provided for affordable housing. This offer

6 (excluding the reserve land) equates to an overall provision of between 29.3% and 29.7% affordable housing provision across the site. This offer is based on no retrospective test, recalculation or reassessment. In terms of tenure split, the base guarantee is 30% social rented and 70% intermediate tenure based on nil grant, with a ‘swap’ provision to increase the ratio up to 70% social rented / 30% intermediate tenure subject to availability of grant or other funding.

6.9 Green linkages and open space to be delivered in accordance with the submitted open space strategy including 4 key areas of formal open space ‘the viewpoint’ to the north of the railway, ‘neighbourhood park’ (located in Phase 1), ‘town park’ (located on eastern side of site adjacent to Bewbush) and the Knoll (southeast corner of site). The layout proposes green linkages through the site and access beyond into Bewbush and the wider countryside.

6.10 Other infrastructure to support and funded by the development is proposed including:  Land for a 3 form primary school and nursery together with contributions for their construction and appropriate contributions for secondary school places.  Allocation of 8,000 sq m of serviced employment land adjacent to the neighbourhood centre.  A centralised energy centre /CHP plant as part of a community based energy strategy to be adopted to be located in the southern part of Pondtail Shaw within the Environmental Infrastructure Area. This is suggested as part of the proposed energy strategy which sets out a range of sustainability options.  Land within the development is safeguarded for a railway station

6.11 The primary access is proposed via a new roundabout junction onto the A264 towards the southwest corner of the site, the junction aligned so as not to preclude the delivery of any future WRR. A secondary access with pedestrian, cyclist and equestrian crossing is proposed at the existing landfill access and is proposed to be the main point of access for construction traffic and car access also when the development is complete.

6.12 Two bridge crossings are proposed across the railway line these are: a Central Bridge for pedestrians, cyclists, public transport and road vehicles and, an Eastern Bridge for pedestrians, cyclists, equestrians and road vehicles.

6.13 Off site highway improvements are proposed for Cheals roundabout (slip road works or contributions) as Stage 1 and contributions to full signalisation as Stage 2, proportional highway improvement works to J11 of M23 and a contribution to signalised gyratory at Sullivan Drive/A264 roundabout if highway monitoring proves this necessary.

6.14 In order to provide sustainable transport links 2 bus gates are proposed into Crawley Borough with access into Bewbush onto the Sullivan Drive roundabout and into Ifield West via Woodcroft Road. A third link to Crawley is proposed to serve the phase 1 development as footpath and cycle link connecting into Chetwood Road.

6.15 Contributions towards other infrastructure required for future occupants are proposed including:

7  Contributions to secure and maintain appropriate bus services through extension of existing bus routes and the operation of a shuttle bus to serve Phase 1 of the development.  Contribution towards provision of public art and maintenance of landscaped areas including the acoustic bund.  Proportional contributions to household waste recycling facilities in conjunction with domestic waste collection strategy.

6.16 The applicants have submitted an Indicative Masterplan, Land Use Plan, Open Space Plan and several other parameter plans to show the overarching layout and key spatial components of the neighbourhood. The outline submission also explains the strategy for delivery and phasing of the neighbourhood.

6.17 The development is proposed to be delivered in 5 phases. The phasing aims to allow the development to start early on the site on land which does not require significant remediation with Phase 1 on the western side of the site served by the new primary roundabout access. Remediation works are proposed to take place on the inert landfill area (Phases 2 and 3) while phase 1 is under construction, traffic for these works using the existing access. Elements of the neighbourhood centre are to be delivered in phase 2 and remainder in phase 3.

6.18 The later Phases 4 and 5 are north of the railway as significant cost is involved in bridging the railway line. Other than the bridges and possible railway station, this area is wholly residential as the neighbourhood centre would have been completed in phase 3.

Full planning permission for engineering operations associated with landfill remediation and associated infrastructure including pumping station.

6.19 The submitted Environmental Statement contains detailed technical information on the landfill conditions and includes a remediation strategy for land treatment to provide an appropriate landform and base on which the later phases of the neighbourhood can be constructed.

6.20 Approximately 1/3rd of the site (around 42 ha) has previously been used for inert waste management activities and material from this site is to be used over the wider land south of the railway line to contour the site. The report states that around 480,000m3 of inert fill will be excavated during the remediation works as part of the cut and fill works for the site.

6.21 On the Phase 1 part of the development, land along the A264 would be increased by up to 5m from existing ground level to form an acoustic bund to the residential development behind. Towards the northern end of the Phase 1 site, the land would be lowered by up to 2m to widen the watercourse and create the landscape / water feature that would intersect the northern part of this site and is required as part of the proposed SUDS measures.

6.22 Within the current inert landfill area identified on the planning drawings as phases 2 and 3, land along the A264 would be raised behind the existing highway tree belt by up to 4m above the existing ground level to provide an acoustic bund /bank to the development beyond. The masterplan provides a ‘knoll’ feature which would be created on an already raised portion of the site

8 close to the southern site boundary between the existing landfill access and the Borough boundary. The proposed knoll would increase the land level by a further 12m at its maximum height approximately 60m away from the site boundary with the A264.

6.23 Within the site the existing land used for crushing operations would be raised by around 4m from existing ground level. Much of the central portion of the landfill would be reduced by between 2 and 6m to provide a more gently sloping site towards Bewbush Brook. Between Bewbush Brook and the railway the levels would be regraded requiring land to be raised in two places by up to 10m from current ground level to provide the bridge infrastructure to cross the railway while in other areas being slightly reduced to provide a more gentle gradient for development.

6.24 Other than the ground works necessary to facilitate the railway bridge crossings, no signficant changes in land level are proposed to the northern portion of the site (phases 4 and 5).

6.25 In relation to the Borough boundary, the most significant change in levels would be in the southeast corner of the site adjacent to Beaubush Cottage where levels would increase by up to 6m. Further north along the Borough boundary the site levels would be largely unchanged with landform rising by around 1 -2 m over a distance of up to 80m away from the site boundary. The exception to this is an area of land in the northeast corner of phase 3 alongside Bewbush Brook where there is currently a dip in the landform. The proposal is to fill this area to create a more level site (identified in the masterplan for the ‘town park’).

6.26 A foul pumping station to serve Phase 1 and the western part of Phase 2 is proposed just beyond the north east corner of Phase 1 (on the eastern side of the tree belt). The proposal would provide a 8m x 10m enclosure which allows access to the sewer and pumping equipment for maintenance including space within to park a service vehicle. The plant would not be visible, the area proposed to be enclosed by a 1.8m close boarded fence and gates.

Full planning permission for the construction of a 3 to 6 metre high (above ground level) noise attenuation landform for approximately 700 metres, associated landscaping, pedestrian/cycleway and service provision.

6.27 Full planning permission is sought for an acoustic bund along the southern boundary of the site adjacent to the A264, the formation of which is linked to the remediation works described above. The bund is proposed to be landscaped and the design incorporates a pedestrian / cycle route running adjacent its northern side. This route is proposed to be implemented early in the development to provide pedestrian / cycle access for Phase 1 occupants into Bewbush.

6.28 The eastern end of the bund would start adjacent to the Beaubush Cottage and extend to a height of 4m above current ground level, the landform rising to around 6m above current ground level at the mid point along this section of the road reducing in height to around 4 m at the proposed secondary access. The landform adjacent to this section of A264 carriageway is already elevated due to the landfill. The bund would provide a landscaped edge to an elevated

9 development platform for phases 2 and 3 set behind the proposed ‘Knoll’ landform and footpath/cycleway link.

6.29 To the west of the secondary access the bund would be around 3m above road level, the land this side of the access is between 1 – 3m lower than the A264. Here the bund would involve the construction of a section of green acoustic wall, the wall linking around to form a feature at the proposed roundabout entrance. The bund / wall would be landscaped along its length to provide screening to the road and landscaped setting to the footpath / cycleway. The landscaping would continue to the west of the roundabout entrance along the main access road and its approach into the Phase 1 houses to provide a landscaped ‘Gateway’ to the development.

Full planning permission for development of Phase 1 of 291 dwellings, internal roads, garages, driveways, 672 parking spaces, pathways, sub- station, floor attenuation ponds and associated amenity space.

6.30 Phase 1 is approximately 10.3 ha broadly rectangular land parcel located in the southwest corner of the site. The site which is agricultural land is bounded to the west by Hoppers Brook beyond which is farmland (reserve land for the possible WRR, Pondtail Shaw to the north, the wooded field boundary screening the landfill to the east and the A264 to the south.

6.31 The proposed residential dwellings would be accessed from the newly constructed primary roundabout which would be situated just beyond the south west boundary of the site. The dwellings would be constructed on a re- contoured site (as detailed in paragraph 6.21) and to the south would be shielded from the A264 by the proposed noise attenuation bund / wall.

6.32 The layout proposes a single point of vehicular access in the southwest from the primaryroundabout and a central area of open space ‘neighbourhood park’ to the north and south of which would be the two main residential roads providing access eastwards to the wider development (phase 2).

6.33 The ‘neighbourhood park’ is a key feature of this first phase, designed with properties facing towards this space. The site is interesected by Hoppers Brook at its northern end which provides a landscape focus for the dwellings at this end of the site, the landscaping intended to serve as balancing pond linked to an area further west and part of the SUDs management. The landscape acoustic bund along the southern boundary provides a frontage for dwellings at this end of the site and extends to the southwest parallel to the access road serving the development which is aligned to come off the A264 at an angle before a 90 degree curve in the main road to enter the residential area. The intervening land ‘the Gateway’ to be landscaped details of which fall outside of phase 1 as part of the 3 to 6m high noise attenuation landform as set out in paragraph 6.29.

6.34 The development is a mix of houses and flats of 2 and 3 storey scale, the overall housing mix is :1 and 2 bedroom flats – 23%, 2 bedroom houses – 17%, 3 bedroom houses – 33% and 4/5 bedroom houses – 27%.

6.35 The affordable units are located within the layout in 2 groups of 42 and 16 units with parking provided ‘on-street’ or small courtyards. Within phase 1, 20% of the housing following are identified as affordable units (total 58) and

6.36 Within the general layout the dwellings are orientated with frontages facing the main road and routes through the site with parking for the private units generally provided off-street or in courtyards with garage and allocated spaces.

6.37 The scale of development is generally 2 and 2.5 storey except for the flats which are 3 storey . The houses are ‘standard’ house types the design and finish being articulated in ‘areas’ for example, the properties fronting the main route having a similar style of finish to aid legibility. The style and finish of the properties has been influenced by Arts and Crafts architecture with the properties having steeply pitched roofs, assymetrical gables, catslide roofs, chimneys, strong eaves features and strong window detailing.

6.38 The layout proposes a circular shuttle bus route from the main access in a loop around the ‘neighbourhood park’. The main northern road in the layout would eventually connect to later phases as a key bus route. Footpath linkages are provided along the southern boundary to Bewbush and centrally north / south through the layout with provision for further linkages east to Phase 2.

7.0 Planning history

7.1 This is the first planning application submitted for residential / neighbourhood scale development on this site.

7.2 The landfill part of the site has been used for tipping of construction waste from around 1977 to 2006 and had past permissions in connection with the landfill uses. The application to surrender the Waste Management Licence was accepted by the Environment Agency in early 2009.

8.0 Planning Policy

8.1 Section 38 (6) of the Planning and Compulsory Purchase Act 2004 states that applications for planning permission must be determined in accordance with the relevant provisions of the Development Plan unless material considerations indicate otherwise. In this case the site benefits from its own Joint Area Action Plan (JAAP) a Development Plan Document.

8.2 The JAAP provides a comprehensive suite of policies relating to the delivery of a neighbourhood West of Bewbush. The entire document is therefore of relevance in the consideration of this application. In addition the JAAP also engages the two respective Core Strategies of both Horsham and Crawley which are:  Crawley Borough Local Development Framework Core Strategy 2008 (policies set out in Appendix 3);  Horsham District Local Development Framework Core Strategy 2007 The following Horsham District documents are also engaged for the purposes of determining this application:  Horsham District General Development Control Policies document;

11  Horsham District Planning Obligations Supplementary Planning Document.

8.3 The Development Plan also includes the South East Plan the policies contained are relevant to this application in particular the Gatwick policies GAT1, GAT2 and GAT3 which seek to deliver sustainable economic growth and development in the Gatwick sub -region through employment and housing provision. On the 6th July 2010 the Secretary of State announced that the Regional Strategies, including that for the South East had been revoked. However, this decision was challenged in the High Court and the judgement found in favour of the Claimants that the Secretary of State had acted unlawfully. The Chief Planner at the DCLG confirmed on the 10th November that the effect of the judgement was to re-establish Regional Strategies as part of the development plan. Notwithstanding this decision the Chief Planner states that local planning authorities should consider the Secretary of State’s letter of the 27th May 2010 announcing the intent to revoke the Regional Strategies as a material consideration in planning decisions. A second High Court challenge to the S o State’s letter of the 27th May has recently been unsuccessful and is consistent with the advice of the Chief Planner given in May.

8.4 The advice contained within national policy guidance is also a material consideration. The relevant documents are considered to be: PPS1 – Delivering Sustainable Development and supplement, .PPS3 – Housing, PPS4 – Planning for Sustainable Economic Growth, PPS9 – Biodiversity and Geological Conservation, PPS10 – Planning for Sustainable Waste Management, PPS12 – Local Spatial Planning, PPG13 – Transport, PPG17 – Planning for Open Space, Sport and Recreation, PPS22 – Renewable Energy, PPG23 – Planning and Pollution Control, PPG24 – Planning and Noise and PPS25 – Development and Flood Risk

West of Bewbush Joint Area Action Plan 2009

8.5 As stated in paragraph 8.2. above, this a comprehensive site specific document and is a key in the consideration of this application. The policies contained within it are summarised below.

8.6 Policies WB1 to WB3 set out the key development requirements. WB1 identifies the land West of Bewbush as new neighbourhood of up to 2,500 dwellings and associated uses programmed for completion by 2018. WB2 requires the neighbourhood is delivered on a comprehensive basis in accordance with the JAAP and its Conceptual Masterplan (JCM). WB3 requires the development to be subject of detailed masterplanning and delivery in accordance with the following neighbourhood principles which are:  A neighbourhood centre to act as the focus for services, facilities, community activity and integration;  A concentrated number of formal and informal open spaces;  A legible layout, that facilitates access by all modes of transport to the Neighbourhood Centre and open spaces;  Clear pedestrian and cycle linkages throughout the neighbourhood for permeability and surveillance;  Practical and convenient sustainable transport linkages to and form the Town Centre, primary employment locations and adjacent neighbourhoods;

12  Clearly defined edges and character for the area making it distinguishable from adjacent neighbourhoods;  The provision of green corridors throughout the neighbourhood and into adjacent neighbourhoods;  Distinctiveness achieved through contextual and unique architecture, urban and landscape design.

8.7 Policy WB4 requires all development to be of high quality design. It requires that a good, well-reasoned, consistent and thorough Design and Access Statement (DAS) is in place at the outline stage to guide all subsequent phases of the development. The DAS is expected to include a phasing strategy, overall vision for the neighbourhood with overarching design principles, a strategic site-wide masterplan showing elements such as land uses and broad urban form. The vision and design principles would inform the detailed design process of later phases. The outline application is also expected to agree and establish a High Level Design Code again, to be applied throughout the development. The policy reads as follows:

8.8 The design principles below should be accorded to throughout the development in its entirety, and each core phase:  The design and layout of the neighbourhood should reflect the neighbourhood principle;  Development should achieve a high quality, inclusive, mixed use, safe and integrated neighbourhood;  Development should address the street, create streetscape variety, interest and legibility. Streets, paths, open spaces and communal areas should provide natural surveillance;  Densities and storey heights across the neighbourhood should vary, with the higher densities and storey heights in the most sustainable locations, such as near transport nodes and the Neighbourhood Centre;  Contextual and sensitive, but imaginative and innovate architecture, urban and landscape design to achieve a distinctive neighbourhood character;  Good quality external facing materials, surface and boundary treatments will be required.  The Design and Access Statements accompanying planning applications must provide a robust link between general development principles and final detailed designs and clearly demonstrate, through the use of examples and illustrative diagrams, how these principles would ensure high quality design.

8.9 The JAAP requires the following elements as part of the neighbourhood centre as a single building or complex (WB8):  A multi-use community centre approximately 700 sq m flexible space (WB5)  A Primary Care Centre to accommodate 4 GP’s approximately 700 sq m (WB6)  A Library of 150 sq m (WB7).

8.10 The JAAP requires the following elements / land uses within the neighbourhood:  Retail provision of between 1,250 sq m to 2, 500 sq m floorspace provided in the Neighbourhood Centre (WB9);  8,000 sq m of employment floorspace within or adjacent to the neighbourhood centre (to include space for small, start up businesses) (WB20);

13  An Environmental Infrastructure Area adjacent to the neighbourhood centre to include facilities necessary for development to meet the required environmental and sustainability performance standards (WB21).  Land made available for 2-3 form entry primary school and pre-school /nursery or equivalent facility as identified on the JCM and to meet the capital cost of construction. In addition contributions to meet the cost of additional secondary school capacity within Crawley (WB19).

8.11 In respect of housing a mix of dwelling sizes and types is expected (WB10) and a target of 40% affordable housing in the neighbourhood (WB11). The policy seeks delivery of between 30 – 50% affordable housing in each phase with a tenure split of 70% social rented and 30% intermediate tenure. The affordable housing should be a mix of dwelling sizes / types and such mix informed by guidance within the Housing Position Statement. Developers are encouraged to deliver 2% affordable houses at wheelchair standard and approximately 20% at lifetime homes standard. The policy expects the delivery of affordable housing to be kept under review during the development to reflect changes in affordable housing need. The policy also acknowledges that if, for viability reasons, the full affordable housing requirement cannot be met and the Local Planning Authority must be fully satisfied that this the case, the developer can discuss how, and to what extent, those requirements might be amended.

8.12 In addition to the policy requirement, the JAAP process through the Joint Area Action Plan Housing Position Statement prepared in May 2008 agreed in paragraph 7.7 that “The local authorities will have 100% nomination rights to the initial let of the affordable housing and 75% of subsequent re-lets. Each authority will have 50% of these nomination rights”.

8.13 Policy WB12 requires the structural and informal landscaping across the neighbourhood is delivered in accordance with JCM including provision of the identified recreational linkages around and within the site (WB14). The key landscape features at Capon Grove and Pondtail Shaw are to be retained (WB13). Policy WB18 requires 15.4 ha of open space to be provided within the neighbourhood with a broadly even split between informal and formal open space. This should be structured space being accessible to the community and a focus for activities for all age ranges and interests.

8.14 Policy WB15 acknowledges that the site is subject to noise from the railway and A264 and requires that no residential or other noise sensitive development should be located in areas where noise levels exceed 60dBA. Policy WB16 seeks to prevent development with Flood Zone 2 (along the Bewbush and Hoppers Brook watercourses) and ensure that flood attenuation measures and SuDS result in no increase in pre-development run-off rates from the site. Policy WB22 requires appropriate inert landfill remediation subject to approval of an appropriate remediation strategy and implementation of landform modifications which deliver the development in accordance with the JCM.

8.15 Policy WB21 requires the development to incorporate high standards of sustainable construction and to exploit opportunities to create a genuinely sustainable neighbourhood. The policy requires the submission of an Energy Strategy and Water Strategy and to meet the minimum standard of Level 3 Code for Sustainable Homes and BREEAM standard of at least ‘Very Good’ for all non-residential development. The policy requires an Environmental

14 Infrastructure Area should also be provided. Policy WB17 requires contributions to the provision of household waste recycling facilities.

8.16 In respect of sustainable transport infrastructure, policy WB25 requires the following:  Pedestrian, cycle, equestrian access into Ifield West, Bewbush, rural areas to north and south into countryside;  Three crossings of railway, 2 capable of accommodation vehicular traffic;  Bus gate / Fastway access at Sullivan Drive;  Bus access at Woodcroft Road, Ifield West (bus gate) and onto primary A264 junction;  Measures to secure and maintain suitable bus and Fastway services to neighbourhood during construction and for first 3 years after completion of the neighbourhood.  Provision of new roundabout as primary highway access onto A264  Provision of secondary left in, left out and right access onto A264 for emergency vehicle access  Off site junction improvements at the following locations:- A23/A2220 (Cheals roundabout) and A264/A220 junction (Sullivan Drive/A264) – ‘Delivery of junction improvements to mitigate impacts of development or additionally utilising proportional contributions towards improvements to take account of the traffic impacts of other development allowed for within the Transport assessment of the neighbourhood to be prepared and agreed as part of the planning application process.’  A proportional contribution to junction improvements at J11 for M23.  A Travel Plan Strategy  All improvements proposed subject to a Transport Assessment to be agreed as part of the application process which may identify other improvements necessary or that some identified improvements are not required.

8.17 Policy WB23 requires land to be safeguarded on the western side of the site near the neighbourhood primary junction for the Western Relief Road (WRR) and the layout of the development must not prejudice the potential for development elsewhere on the western side of Crawley (WB27)

8.18 WB26 requires the developer to demonstrate the appropriate utility infrastructure (water, gas, electricity) can be provided to support each stage of the development. Policy WB24 requires land to be safeguarded within the neighbourhood for a railway station and car park in the location identified on the JCM.

8.19 The JAAP also includes a section on specific site delivery matters including details of the delivery of this site in 3 phases over the plan period to 2018. These phases took account of the infrastructure requirements required to support each phase as the housing numbers increase, site constraints including the landfill remediation measures and the rail crossing. It was identified that delivery issues for this site included the remediation works, rail crossing, affordable housing provision and sewerage infrastructure and that some flexibility in the JCM may be necessary to deal with changing or unforeseen circumstances. The housing trajectories shown in the document are already inaccurate due to the delay in submission of the application in part due to the economic recession.

9.0 Planning Considerations

9.1 Crawley Borough Council has been consulted as a statutory consultee and can only comment on this application on this basis. The issues this Committee can comment on are however, considered wider ranging than a typical statutory consultation as the JAAP which relates to this site is also adopted as part of Crawley’s Local Development Framework. 9.2 The joint preparation of the JAAP has allowed this Council to influence the content of the document as it has past experience of delivering ‘neighbourhood’ development of this scale. The development of this site has wide ranging implications for Crawley Borough. The successful implementation of the neighbourhood on a comprehensive basis with all the required infrastructure is crucial to ensure that the development meets its own need, addresses local housing need and does not place an unnecessary burden on the wider infrastructure and facilities within the Borough and in particular, on nearby communities at Bewbush and Ifield West. 9.3 It should be noted that the ‘saved’ policies of the Crawley Borough Local Plan and the Borough Council’s SPG’s and SPD’s are not engaged for the purpose of determining this planning application, the relevant development plan documents are listed in paragraphs 8.2 and 8.3. This is of particular relevance in relation to the consideration of the Phase 1 residential development where there is a difference in design guidance between HDC and CBC. HDC does not have any adopted residential floorspace and garden size standards such as those set out in Crawley documents SPG3 and SPG4 however, the advice in these documents do provide an indicator as to the acceptability of the proposed residential layout.

9.4 The key considerations for each element of the hybrid application are set out in more detail below.

9.5 For the outline element - Development of approximately 2500 dwellings, new access from A264 and a secondary access from A264, neighbourhood centre, comprising retail, community building with library facility, public house, primary care centre and care home, main pumping station, land for primary school and nursery, land for employment uses, new rail station, energy centre and associated amenity space the key considerations are:  Principle of the development;  Spatial compliance with the JCM;  Development linkages and the proposed highway impacts on Crawley;  Design Quality and content of the Design and Access Statement (DAS);  Affordable housing;  Development phasing / Infrastructure delivery.

Principle of the development

9.6 The principle of a strategic development location on land west of Crawley was set out in both HDC and CBC’s adopted Core Strategies, a JAAP prepared for the site and therefore the principle of the release of this site for a high quality mixed use neighbourhood is firmly established.

Spatial compliance with JAAP Conceptual Masterplan (JCM)

9.7 While the outline application seeks only to agree the broad principles of the neighbourhood development (and detail of the site access), the submission is supported by an Indicative Masterplan, Land Use Plan, Open Space Plan and several other parameter plans on which technical assumptions made in support of the application are based (including the preparation of the EIA and Transport Assessments). Should planning permission be granted it would be expected that these plans would be approved as part of the process and form the basis on which further Reserved Matters applications were submitted. The submitted plans differ in several respects from the JCM and these variations are discussed in more detail below.

9.8 Since the JAAP was adopted 2 areas of woodland within the site at Capon Grove and the northern half of Pondtail Shaw have been designated as Ancient Woodland (AW). While the JCM had already identified these areas as retained, the designation has increased the protection afforded to these areas, the practical result of which is that no development should take place within a 15m buffer zone to the woodland edges. This designation has been one factor in the changes to the bridge crossings reducing the number from 3 to 2 and repositioning of the central crossing.

9.9 The westernmost crossing was proposed to provide access into Pondtail Shaw as part of a circular recreational route however, for technical reasons to meet the specifications of Network Rail, the bridge designs would have resulted the loss of part of Pondtail Shaw AW to accommodate the ramp and further damage from the recreational route passing through it. Furthermore, the attractiveness of the route through woodland in terms of pedestrian safety and level of use was also questioned. The absence of the western bridge has necessitated moving the central bridge to a more westerly alignment in order to provide an alternative and more direct link to the proposed dwellings in the northwest corner of the site.

9.10 It is considered that the loss of the third bridge crossing is acceptable given new AW status of Pondtail Shaw and that the proposed realigned central bridge crossing provides an effective linkage to future occupiers north of the railway. The loss of the bridge has not undermined the green linkages envisaged by the JAAP which have strong design emphasis within the Indicative Masterplan with legible leisure routes and green linkages proposed as an integral part of the development.

9.11 The formal open space provision has also been altered, in Phase 1 the playing pitches have been moved from the western edge of the site to within the residential development and Poplar Copse removed. It is considered that there is no objection in principle to the re-siting of the playing pitches within Phase 1 subject to a suitable design approach being adopted to the western boundary and its interface with the countryside. Given the poor quality of the trees in Poplar Copse, its loss is acceptable subject to re-provision within the wider layout.

9.12 The open space adjacent to the railway line to the north is proposed to be relocated centrally along the northern boundary of the site. This repositioning is considered acceptable given the site levels (this is the highest part of the site) and the linkage this repositioned space can provide to the countryside further north. This relocated space also works successfully within the

17 proposed Indicative Masterplan marking the northern point of the recreational route with runs though the development.

9.13 On the southern edge of the site an additional area of the open space is proposed ‘The Knoll’, a raised landform to provide a viewpoint from within the development north through the centre of the site and south to the AONB. In principle there is no objection to the inclusion of this area for amenity provision within the layout.

9.14 The main ‘town park’ is still in the location proposed in the JCM. Overall, while 2 of the formal recreational areas have been relocated and an additional area included, the overall level of formal provision is in line with the JAAP requirements at 7.73 ha. The amount of informal space provision is 15.8 ha, which exceeds the required standard. It therefore considered that the layout in terms of the amount of open space provision and its distribution broadly accords with the JCM .

9.15 The area for the proposed neighbourhood centre has moved 100 m south from the railway line and proposed railway station has also moved (due to ongoing discussions with Network Rail to identify the best location for the station). While the JCM identified that these 2 uses would be separated by the Bewbush Brook, the increased distance between the uses and linkage between these is important. Bewbush Brook is also proposed to be realigned due to the need for the remediation works and to achieve the site levels for roads etc. The overall movement of the neighbourhood centre by 100m is relatively small in the context of the wider development and subject to design safeguards to ensure an appropriate linkage with the station, this change is considered acceptable.

9.16 The JCM proposed the employment land be provided within the neighbourhood centre, the proposed Indicative Masterplan identifies only part of this land in this location and the remainder adjacent to the station and southern side of the railway line (on land previously shown as station parking). It is considered this split in the provision is appropriate given the proposed location of the station and potential attractiveness of an employment site close to this facility. The land is also most suited for employment uses given the noise from the adjacent railway.

9.17 The car park serving the railway station is considered oversized and it is recommended that if a station is delivered a detailed assessment is provided with any reserved matter application to fully justify the proposed level of station parking.

9.18 The JCM proposed that an Environmental Infrastructure Area be provided in the northwest corner of the neighbourhood centre. The Indicative Masterplan has relocated this facility to an area within the southern half of Pondtail Shaw. The applicants state the proposed site is an area that is not designated AW and is poor quality. It is considered that the relocation of such a facility has visual benefits as it would be partially screened by the surrounding woodland, therefore subject to environmental safeguards via conditions to protect the remaining woodland and amenities of adjoining occupiers the location is acceptable.

9.19 In respect of road access the primary roundabout access has been re-aligned and now cuts into the reserve land and informal open space. The secondary

18 access is in the same location but now to be used for cars and not just emergency vehicles and has been redesigned to provide a ‘right out’ rather than ‘right in’ junction. An additional footpath link is proposed into Bewbush at the southern end of the site, the extra linkage required due to the phasing of the development without which the phase 1 occupants would have no pedestrian route into Crawley. It is considered that there is no objection in principle to the creation of another point of access or the other access changes detailed above.

9.20 A proposed sewage pumping station is located on the eastern site boundary to the south of the ‘neighbourhood park’ and while locationally acceptable conditions are sought to provide additional detail on the specification of the facility and to ensure that the noise and odour impacts are fully assessed.

9.21 In conclusion, while the Indicative Masterplan has a number of changes from the JCM, for the reasons set out above the spatial distribution of land uses is considered to be spatially compliant with JCM and therefore acceptable.

Development linkages and the proposed highway infrastructure impacts on Crawley

9.22 The access points for private vehicles into the development would be from the A264, the main access being a newly constructed roundabout to the southwest of the site and an upgrade of the existing landfill access as a secondary point of access. WSCC as the highway authority have assessed the junctions and are satisfied with their design. It is not considered there are any adverse impacts from the physical design or siting of the junctions on Crawley residents. The junctions are likely to result in the approach to Crawley along the A264 being at a slower speed limit that at present and an increase in traffic along the A264 with additional vehicles from the development.

9.23 Within the site, the Indicative Masterplan shows a road and footpath layout which provides good linkages within the site. Recreational linkages are also shown to the north into Kilnwood Lane and to the south into Buchan park via new signalised crossing at the secondary access.

9.24 The development also proposes 3 key points of access for public transport and pedestrians/ cyclists into Crawley Borough. These are bus gates at Woodcroft Road and Sullivan Drive and a pedestrian /cycle link to be delivered as part of Phase 1 onto an existing bridleway (to the rear of properties in Chetwood Road). These linkages provide an integral part of the sustainable transport package and integration of the new development with the built-up area of Crawley and should improve access for Crawley residents to the wider countryside and new neighbourhood facilities.

9.25 The applicants have submitted an application with a red edge boundary including all the land they controln which extends up to the administrative boundary between HDC and CBC. However, as the adopted highway does not extend to the edge of the Borough boundary, there is intervening land required to be acquired by the applicants to deliver all 3 linkages from their site onto the adopted road / footpath network in Crawley.

9.26 The Borough Council owns this intervening land and the applicant is proposing to purchase the land they require to deliver these linkages from the

19 Council. This property matter is separate from the planning issues for consideration by this committee however, it should be noted that at the JAAP examination the principle of linking the development into Crawley Borough at these locations was accepted, the delivery of which is a requirement of policy WB25. These linkages would require separate planning applications to be made by the applicant to CBC which would be considered on their merits.

9.27 In respect of the current application it is recommended that a Grampian condition be imposed (whereby development cannot commence on the proposed dwellings until the applicants can satisfy HDC as the LPA that they can deliver the required linkages). The wording of this condition should be agreed in consultation with CBC Planning Officers. Further conditions are also needed to ensure linkages are safeguarded and delivered when required in line with the phasing of the development and, that the routes are designed to an appropriate specification to ensure these are safe for future users and adoptable.

9.28 The quantum of development proposed will have a significant impact on the road infrastructure within the Borough. The applicant proposes to deliver the road improvements listed at paragraph 6.13, the improved highway works and contributions have been accepted by WSCC. The works generally will affect traffic junctions and are visually are acceptable, although the junction improvements at the Cheals roundabout will need to be carefully designed to mitigate any impacts on trees, pedestrian rights of way and the setting of the listed building.

9.29 In conclusion, while the proposed development would result in an increase in traffic on the Crawley road network, the development is designed with sole car access onto the A264 for its residents to prevent general traffic congestion in the adjoining neighbourhoods. WSCC and the Highways Agency consider the proposed highway improvement works adequate to mitigate the impact of the development therefore overall highway impacts are considered acceptable. In respect of public transport and other linkages, it is considered the proposal could have a positive impact on the bus services serving west of Crawley, links to Fastway and a new railway station. Pedestrian links to the west of Bewbush to the wider countryside would also be improved.

Design Quality and content of the Design and Access Statement (DAS)

9.30 The JAAP requires the development to be the subject of detailed masterplanning and delivery to ensure the development follows the neighbourhood principles set out under policy WB3 (paragraph 8.6). In addition policy WB4 (paragraph 8.7) requires all development to be of high quality design and sets out detailed and specific requirements that should be addressed within the DAS.

9.31 The DAS and High Level Design Code is expected to be agreed at the outline stage and applied consistently across the development, with a robust link established at outline informing the detailed design process at later stages. The information agreed on the masterplan, design code and in the DAS should be tied via a condition to any planning permission to ensure compliance with the design principles. An addendum has been provided to the DAS by the applicant in response to Officer comments. The comments of

20 the Urban Design Manager have been sought through this consultation process.

9.31 At the time of drafting this report there are three areas of concern which remain with the content of the DAS which CBC would recommend HDC to resolve. 1- Neighbourhood Centre. CBC is seeking an agreement in principle from the applicants to look to provide residential uses above the prominent food store unit which would create more vitality and surveillance in this area. Without this commitment, the level of residential accommodation is limited to the smaller retail uses that would front onto the main square, any residential accommodation above the public house and extra care facility if delivered. The applicants are proposing a ‘design brief’ to address the detailed aspects this space however there is concern that this approach does not provide the ‘quality fix’ envisaged by policy WB4. There are also concerns regarding road safety and potential traffic conflicts and congestion in connection with the school, the neighbourhood centre car park and the important through road, as the principle point of access for the school is located in this space. It is considered that a second drop off / set down point should be considered to serve the school. The neighbourhood centre is a key area for a range of land uses including residential and as a central focus for the new community and it is considered vital that sufficient detail is provided here to deliver a quality environment. 2 - The Brook Crossing / Station Square area. Here further clarity is sought on the design concept to establish a quality design fix (in particular given the increased separation between this space and the neighbourhood centre as set out in para 9.15). A greater level of detail is sought with regard to the perspective drawing for this prominent and important key space, comparable with those provided for other spaces. There are no fundamental concerns with the proposed design principles. 3 – Paragraphs 1.27 and 1.28 of the addendum DAS relating to bus gate and linkages needs updating.

9.32 In all other areas, it is considered that the applicants have successfully addressed CBC Officer concerns with the DAS, of particular note is the railway station site which is a key space in the masterplan. A design brief approach has been agreed along with a commitment to deliver a bridge crossing to cover the scenario where the station might not to be delivered.

9.34 The other key land use components in the neighbourhood centre are considered acceptable although a condition is recommended to limit the maximum amount of net retail floorspace for the development, to ensure this is not delivered in one single food retail unit but a that a proportion of this floorspace is allocated to the smaller units envisaged for the neighbourhood centre. Further residential uses should be accommodated within this space where possible and the opportunity identified in the Open Space Strategy to formal open space provision within the school ground is welcomed preferably located in close proximity to the neighbourhood centre.

9.35 With the exception of the points listed in 9.31 above, the submitted DAS is considered to meet the objectives of policy WB4 and would provide sufficient information.

Affordable Housing

9.36 One key difference between the JAAP and the current application is the level of affordable housing provision envisaged for the neighbourhood. The JAAP requires a target of 40% but does acknowledge that if, for viability reasons this cannot be met, these requirements can be amended. This is of particular interest to CBC as part of the joint working arrangements 50% of the nomination rights for any units delivered are intended to be from the CBC housing register

9.37 As set out in paragraph 6.8 the applicant proposes a fixed 29% affordable housing provision across the whole allocated site with no more than 20% fixed in Phase 1 and 25% (Phases 2 and 3) which comprises all the land south of the railway with 36% on land north of the railway. In addition to the detail specified in paragraph 6.8, this offer is subject to the applicant securing the land required to deliver the bus gates and phase 1 footpath link which is a separate property matter, yet to be finalised and the merits of which are not for consideration by this Committee.

9.38 The tenure split proposed by the developer is a 30/70 (rented / shared ownership ) as a base position in a nil grant scenario with the opportunity to ‘flip’ the tenure should HCA grant be achieved to a maximum of 70/30 (rented / shared ownership). The Council’s Housing Enabling and Development Officer has considered the draft tenure agreement mechanism and considers that the approach being proposed is workable and realistic, the exact details would need to be secured through the S106 Agreement.

9.39 The proportion of affordable housing is fixed through the 5 phases for the life of the development however, the tenure type and unit mix (i.e. size of units) would still be negotiated at each phase. Furthermore, should the reserve land come forward, the developer would be required to deliver 40% affordable housing units on this site.

9.40 Based on the viability studies, it is not considered that this proposal is contrary to JAAP (WB11) as it has been demonstrated that the development cannot deliver 40% affordable housing in accordance with the viability clause in the policy. It is considered given the viability evidence that 29% affordable housing provision is an acceptable offer which would deliver a reasonable proportion of affordable units across the development as part of a balanced community. The approach allows tenure mix and housing mix to be adjusted to reflect changing circumstances and local need as the development progresses; this approach is in line with the requirements of WB11 to keep the delivery of affordable housing under review.

Development Phasing / Infrastructure Delivery

9.41 The development proposes to deliver all the infrastructure specified in the JAAP. The proposed timing and delivery of the key infrastructure is critical to ensure that new occupants of the development have sufficient access to Crawley and wider services while the timely delivery of ‘on site’ community facilities and ‘off site’ mitigation measures are essential to ensure an excessive burden is not placed on Crawley’s infrastructure.

22 9.42 The mechanism required to ensure the delivery of such infrastructure is via planning conditions and a S106 Agreement. The JAAP provided detail on the proposed phasing and delivery of the development. The applicants have adjusted the phasing slightly starting with Phase 1 in the SW corner of the site and have provided additional infrastructure including a shuttle bus service and footpath link to serve these residents. The neighbourhood centre would begin in phase 2 and completed in phase 3 and the emerging drafts of the legal agreements with WSCC and HDC provide for a stepped provision of services for example, phased school provision as the dwellings on site are completed. The station, bridge crossings and Woodcroft Road bus gate would be delivered in phases 4 and 5.

9.43 While the phasing details, costings and specifications are still in a draft format, it is considered that the general phasing approach proposed would deliver the key infrastructure in a comprehesive and coordinated way. CBC Officers would like the opportunity to comment on the agreements and keep a watching brief on these if HDC resolve to permit the development.

10.1 For full planning permission for engineering operations associated with landfill remediation and associated infrastructure including pumping station the key considerations are:  Impact of the remediation works on the landscape character of the area;  Impact of the remediation works on the visual amenities of nearby residential properties;  Impact of the remediation works on the health and wellbeing of Crawley residents (noise, pollution, air quality).

Impact of the remediation works on the landscape character of the area

10.2 The applicants propose that the remediation works would be implemented in 3 broad phases. The first phase would involve excavation of the SUDS feature in Phase 1, removal of topsoil from this area, ground levelling in phase 1 and initial works to the A264 bund at its western end. The second phase would involve the formation of the A264 bund and works towards the southern end of the landfill. The final phase would involve the works within the northern portion of the landfill including works to Bewbush Brook and the railway bridge crossings.

10.3 With the exception of the acoustic bund along the A264 (details set out separately under paragraph 10.11) the visual impact of the remediation works on the character of the area are considered fairly limited and generally relate only to the land south of the railway.

10.4 The proposal is to remodel the existing landfill material on the site to create a development platform for the neighbourhood. No inert material is proposed to be imported onto the site. The resultant landform would appear relatively flat and more even in gradient than exists at present except for the areas alongside the railway where the bridge crossings necessitate the road being elevated to cross the railway line and the land regrading required as a result of diverting Bewbush Brook and SUDs features.

10.5 The other key area which would be prominent from wider views is the ‘Knoll’ feature adjacent to the A264. This would be positioned behind the proposed acoustic bund on an area of the landfill which is currently elevated above

23 natural ground level. This raised landform would be further increased by 12m creating a steeper mound of earth to provide a ‘viewpoint’ within the development. This feature would be visible from the A264 over the acoustic bund although it would be set back at least 50m from the dual carraigeway. The proposed landform would be contained well within the development and while not a natural feature would be set against the backdrop of the neighbourhood, a large proportion of which would be on a relatively flat and featureless site. It is therefore considered that the proposed remediation works are acceptable in terms of their visual impact on the wider area.

Impact of the remediation works on the visual amenities of nearby residential properties

10.6 The proposed remediation works are not considered to have a detrimental impact on views into or out of Crawley. A wooded tree belt screens much of Bewbush and Ifield West from views of the site. The remediation works which involve any signficant changes in level (with the exception of a section of the acoustic bund dealt with in para 10.12 below) are a considerable distance away from the Borough boundary. The edge of the ‘Knoll’ feature 170m is distant and the infill of landform in Bewbush Brook in the northeast corner of phase 3 around 80 m distant.

Impact of the remediation works on the health and wellbeing of Crawley residents (noise, pollution, air quality).

10.7 The applicants have provided detailed technical and site analysis of the landfill to understand the nature and features of the tipped land and ground conditions on which it is located. The Council’s Contaminated Land Officer has commented that the findings of the applicants ground conditions, land quality and remediation work are accepted but that further information should be provided regarding remediation for the site via condition. The Remediation strategy states that further work will be required on the site in particular in the area still used for crushing operations and to anaylse and continue to monitor gas concentrations during and after the works. It is recommended that these works should also be subject to condition.

10.8 While the phasing of the remediation works are considered acceptable, the applicants have provided very limited information on the environment, health and safety protection measures proposed during the works. The Remediation Strategy states that an Environmental Management Plan (EMP) will be prepared prior to each phase of the remedation works, that noise from the works would be appropriately mitigated, best practice advice should be followed with regard to dust emissions and that site monitoring and sampling would continue. Measures are also proposed to deal with potential contamination into the watercourse and ground gas protection.

10.9 A key concern for Crawley is the impact of the remediation works in terms of noise and air quality for nearby residents. The Environmental Health Division therefore recommend that a Construction Environmental Management Plan is secured via conditon and agreed with HDC and CBC before commencement of the remediation works. This document should be compliant with best practice guidance ‘The control of dust and emissions from construction and demolition best practice guidance; Greater London Authority and London Councils, London, 2006 and Controlling particles, vapour and noise pollution from construction site, BRE, London 2003’.

10.10 For full planning permission for the construction of a 3 to 6 metre high (above ground level) noise attenuation landform for approximately 700 metres, associated landscaping, pedestrian/cycleway and service provision, the key considerations are:  The visual impact of the bund on the countryside character and approach to Crawley (and the adequacy of the bund as a noise attenuation landform);  The impact of the bund and pedestrian /cycleway link on the amenities of nearby residential properties. (to includeimpact on amenity land CBC)  Design, safety and delivery issues with the pedestrian / cycleway link.

The visual impact of the bund on the countryside character and approach to Crawley (and the adequacy of the bund as a noise attenuation landform)

10.11 The extent of the proposed acoustic bund has been described in paragraphs 6.28 and 6.29 of this report. The development would significantly alter the approach into Crawley along the A264 travelling east. The new roundabout is to provide a landscaped entrance to the development and within this landscaping would be the start of the acoustic wall and bund extending along the A264. The landscaped bund / wall approximately 3m in height from the new roundabout to the secondary access is not considered to be detrimental to the visual amenities of the area serving to screen the development from views of the A264.

10.12 The landform between the secondary access and Beaubush Cottage would be at a gentler gradient than the bund to the west but would be considerably more prominent due to the increased height and existing rise in land levels as a result of the landfill (rising to a height of 8m above road level at distance of 20m back from the road edge). While the bund results in a further increase in height of around 4m over the existing land level, it is not considered this feature if appropriately landscaped would be detrimental to the views / approach along the A264 or the character of the wider area.

10.13 In addition to the visual screen, the bund / wall is proposed as a noise attenuation landform and the adequacy of this landform to protect future residents has been considered by the Environmental Health Division. Any further increase in the height of the bund to mitigate any excessive noise impacts is not considered acceptable.

10.14 At the time of preparing this report there remains concern with the acoustic performance of the bund and to which of the planning drawings the noise modelling was assessed against. While the acoustic results are generally accepted, there is a need to ensure the results of the acoustic testing are achieved by the bund design. It is therefore recommended that a condition be imposed to ensure the implementation of the bund /wall in accordance with detailed plan drawings which conform with the measurements set out in the acoustic report.

The impact of the bund and pedestrian/ cycleway link on the amenities of nearby residential properties.

10.15 The property most affected by the acoustic bund is Beaubush Cottage located just off the A264 just beyond the south east corner of the site. This chalet bungalow style property has its rear garden to the north and a number of key

25 windows at ground and first floor level facing the application site. The landscaping along the site boundary has recently been cleared allowing open views onto the site and a 1.8m close board fence been erected to mark the boundary. The application site level is currently around 0.5m higher than the garden of Beaubush Cottage with a gently rising gradient away from the common boundary. The bund would begin 12m distant from the side wall of the property and rise by 4m over the existing land level 21.5m distant from the side wall of the property. The bund is not considered to have a detrimental impact on the outlook from this property given the separation distances involved and the multi aspect / outlook from key windows in this property. There is concern however regarding the potential for overlooking from the bund to this property and it is considered a condition is expedient to control the landscaping works and boundary treatment in detail in this area to protect the amenities of these residents.

Design, safety and delivery issues with the pedestrian / cycleway link

10.16 The proposed pedestrian / cycleway link runs along the northern side of the bund. The gravel bond path would be 3m wide and east of the secondary access a 4m grassed bridleway would run parallel with the path, widening the route to 7m. A footbridge is required to cross an existing ditch at the eastern end with access onto the bridleway. The most direst access is via a footpath between residential properties into Chetwood Road, this proposal would increase the use of the path however this is not considered to result in harm to the amenities of neighbouring residents.

10.17 It is considered essential that this key linkage should be of high quality in terms of surfacing and lighting as the principle pedestrian/ cycle access for the early phases of the development. The link needs to be provided to an acceptable standard, an attractive route and open as a right of way for use by the first residents, these details secured by appropriate conditions.

10.18 For Full planning permission for development of Phase 1 of 291 dwellings, internal roads, garages, driveways, 674 parking spaces, pathways, sub- station, floor attenuation ponds and associated amenity space. Detailed plans have been submitted showing the layout of Phase 1 which would be located in the southwest corner of the site. While this part of the development has no direct impact on land within the Borough boundary, it is considered vital that quality and high standard of the design and layout is established in this initial phase to provide a quality fix for the neighbourhood. Of particular interest to Crawley is the design quality of the affordable housing given the proposed nomination arrangements.

10.19 The applicants are seeking detailed approval of this layout and have submitted materials schedules, landscaping, surfacing and fencing to be considered as part of the proposal in order to reduce the number of pre- commencement conditions that are typically required when planning permission is granted. As a result, some of the comments below reflect the need to consider a greater level of detail which would often be negotiated by officers through the discharge of conditions.

Overall design approach to Phase 1

10.20 The key components of phase 1 layout are detailed in 6.30-6.38. The overall layout of the main roads, key linkages and areas of open space are

10.21 While it is considered the layout and design has sucessfully addressed the majority of the key frontage routes, the design approach adopted to the rear of these frontage properties and smaller side streets is of concern. These specific concerns are set out in more detail below.

The fitness for purpose of the parking arrangements

10.22 In terms of parking, while the overall number of spaces provided per unit is considered acceptable, the useablity and accessablity of some of these spaces is of concern. Many of the houses have parking in small garage courts located to the rear of the dwellings. The layout of a number of these areas appears cramped and difficult for vehicles to manourvre. The useablity of these spaces and in particular some of the garaging is therefore questionable for example, plots 5-7. Some houses have tandem parking spaces which appear difficult to access like plot 28 which with gates enclosing the driveway increases the likelihood of residents parking on-street. Other parking courts are less attractive due to their tight layout with limited natural surveillance for example plots 166 – 171, here the parking arrangements and adjacent small gardens could be significantly improved if Plot 197 were moved closer to the green.

The fitness for purpose of a number of rear gardens and private amenity areas

10.23 In a number of cases plots with rear gardens that significantly exceed the guidelines used by the Borough Council for the town and back onto rear gardens that are too small for the type of home proposed. For example, for Plots 221, 222, 223 and 225 (affordable) there would be a 118 sq m shortfall immediately adjacent a 177 sq m over provision for Plots 233, 235 and 236. In addition, for Plots 132 – 135 and 140 there would be a 135 sq m shortfall adjacent a 201 sq m over provision for Plots 141 – 143. Improving the size of these gardens could be achieved without affecting the mix, density and number of units. 10.24 With regard to the flats proposed with little or no private amenity area provision, Officers have suggested that some areas of incidental open space could be modified with fencing and direct access to provide semi-private amenity areas for residents. Whilst some adjacent areas would now be fenced, others would be only partially enclosed making their role ambiguous or only have access to them from the street. The needs of residents, which are likely to include families with small children, for a useable area of garden would not currently be met. Crime and security considerations

10.24 Officers have expressed concerns regarding areas of the layout and specific house types where garden gates and rear garden boundaries would be hidden from view, for example by a car port, or poorly overlooked but easily

27 accessible. There are particular concerns regarding the general lack of natural surveillance to the frontages, side gates and boundaries of Plot 1, 119, 143, 149, 155, 160, 272 and 273 and the extent to which residents would come into contact with neighbours. The proposed rear alleys serving a number of properties may attract crime, anti-social behaviour and dumping.

Affordable housing provision

10.26 58 affordable units are proposed over half of which are flats, the unit mix is accepted however, there is concern that the internal size of accommodation is below CBC adopted guidance and HDC should be satisfied that the size of units could attract HCA grant.

10.27 Officers consider that the layout is not tenure blind as the affordable housing units have a lower quality of architecture generally with house type A3 being particularly prominent and bland and could be improved with adjustments to the detailing.

10.28 It is considered that the layout of the some of affordable units are particularly cramped with many plots having small rear gardens which are not considered sufficient to meet the needs of future occupiers (these units being likely to be fully occupied). While it is accepted that this Council’s adopted space standards cannot be applied to this layout, it is considered that there is scope within the layout to increase the size of some of the rear gardens to address the signficant under provision to some of the plots (plots 221 –225).

Relationship of the units on the western boundary of the site with the countryside

10.29 The layout of the units adjacent to this western boundary and its relationship to the woodland beyond remain of concern. Following officer comments amendments have been made to the boundary treatment adjacent the parking courts although the introduction of gated rear courtyards is not considered an attractive environment for occupiers of the single flats located in the parking courts. The amount of natural surveillance over the parking courts that can be achieved from one small flat would be limited. The scheme would present rear garden boundaries to accessible planted areas, providing opportunities for crime and dumping which could be resolve with a taller more robust boundary treatment.

10.30 For other elements of the layout further detail would be required to be secured via condition for example, to ensure the bus stops are designed to meet the operators requirements for level pavement access and the provision of bus shelters. The open space provided in centre of the site would also require further detail on the exact layout of the space (pitches / play areas etc).

10.31 To conclude, it is considered that phase 1 with a number of relatively small adjustments would significantly improve the overall layout and scheme quality without affecting the mix, density or number of units.

Other matters

28 11.1 This report has limited its comments to Borough Council issues only and has not addressed in detail specific issues for example, highway safety, flooding, ecology, archaeology, safeguarding for which HDC has sought the advice of specialist consultees who have responded separately with detailed conditions to deal with their specific requirements.

11.2 The report has also not commented on tree protection and wider landscaping, open space, management issues or developer costing / contributions which are matters for HDC.

Conclusions

12.1 In respect of the outline element of the application, the proposed development is considered to accord with the provisions of the JAAP in that the scheme is spatially compliant with the JCM and the applicants have undertaken to provide all the necessary infrastructure to support the development. While the level of affordable housing is less than envisaged by policy WB11, it is considered that the amount proposed has been justified and is therefore not contrary to the requirements of this policy. Subject to further clarification on the outstanding detailed design points set out in paragraph 9.31 which need to be incorporated into the DAS it is considered there is no objection to this element of the application.

12.2 The remediation works and bund / footpath link have been carefully considered and provided environmental safeguards are in place to protect existing and future residents there is no objection to these elements of the application.

12.3 With the Phase 1 layout it is considered that the overall design concept and key design principles are good and work particularly well along the primary routes and fronting the key spaces. However, there are concerns with some elements of the layout and the architectural detailing which have the potential to be resolved with relatively minor changes to the scheme which would not impact on the design concept or quantum of housing. It is understood that at the time of preparing the report the applicants may be preparing further design revisions. Subject to further consultation with CBC officers it is recommended that the Head of Planning and Environmental Services be authorised to provide further comments on any amendments and a list of suggested conditions if these concerns can be satisfactorily addressed.

12.4 It is considered that the successful joint working to date on this application should continue to resolve an outstanding details with this application if HDC were minded to grant planning permission

13 Recommendation

13.1 It is recommended that HDC be advised that NO OBJECTION is raised to this application subject to the following provisos and conditions as set out below:

13.2 In relation to the outline part of the application that:

HDC seek further clarification on the outstanding detailed design issues set out in paragraph 9.31 of this report which the applicants must incorporate into the DAS.

Conditions covering the following issues are recommended: 1. Ensure a maximum of 2500 dwellings constructed as part of the outline approval – to accord with assumptions in EIA dwellings and other technical documents such as the Transport Assessment 2. Parameter plans to be agreed as basis for ARM applications 3. Ensure the development is delivered in accordance with the agreed phasing strategy. 4. As specified in the JAAP the detailed masterplans, design codes , design briefs should be in accordance with the DAS and high level design code unless otherwise agreed in writing by the LPA. 5. Each detailed residential layout shall be accompanied by detailed masterplan and design code and evidence to demonstrate that the design of the development is in accordace with the vision / design principles and high level design code agreed at the outline stage of the development. 6. Open space provision to be tied to the Submitted Open Space strategy 7. Open space managed in accordance with Open Space strategy 8. Reserved Matters for the railway station to be accompanied by a detailed transport assessment to fully justifiy the level of car parking provision. 9. Energy centre condition to control air quality emissions 10. Energy centre conditon to control noise (sound power output). 11. Further details and assessment of the noise /odour impact of proposed sewage storage and pumping station on the eastern side of the site as part of any reserved matters application and for CBC Environmental Health Division to consulted on these details. 12. No construction until a Construction Environmental Management Plan (CEMP) has been submitted to and agreed in writing by the Local Planning Authority 13. Phase 2 and 3 dwellings not constructed in noise affected parts of site (near bund / railway) unless appropriate acoustic design and mitigation measures incorporated. 14. Retail limit of 2,500 sq m floorspace net, proportion of which should be allocated to smaller units in neighbourhood centre 15. A Grampian condition be imposed (whereby development cannot commence on the proposed dwellings until the applicants can satisfy HDC as the LPA that they can deliver the required linkages). The wording to be agreed in consultation with CBC Planning Officers. 16. Condition/s to ensure linkages bus gates are safeguarded and delivered when required in line with the phasing of the development and, that the routes are designed to an appropriate specification to ensure these are safe for future users.

30 13.3 Engineering operations associated with landfill remediation and associated infrastructure including pumping station

The following conditions are recommended: 1. No remediation works to take place until a Construction Environmental Management Plan (CEMP) has been submitted to and agreed in writing by the Local Planning Authority in consultation with Crawley Borough Council – paragraph 10.9 2. Hours of work condition. 3. Condition to ensure that reserved matters applications for phases 2 and 3 of the development are accompanied by contamination report to reflect the detailed site conditions of the proposed development and the remediation measures if any required to protect future occupiers from gas and contamination 4. That the measures and safeguards set out in the submitted remediation strategy are controlled though the imposition of suitable conditions such as a Materials Management Plan to set out movement and control of soils. 5. That HDC impose all other conditions recommended by consultees such as WSCC and EA to deliver the appropriate environmental safeguards.

13.4 Construction of a 3 to 6 metre high noise attenuation landform with associated landscaping and pedestrian/cycleway link to Phase 1.

The following conditions are recommended: 1. Condition to link implementation of bund to agreed drawings and acoustic information as set out in paragraph 10.14. 2. Condition for specific landscape details of bund adjacent to Beaubush Cottage to be submitted to and agreed by the LPA paragraph 10.15. 3. No dwellings in phase 1 to be occupied until the footpath link is provided to the required standard and open as public access with all agreed elements constructed to the adopted bridlepath. 4. Grampian conditon to ensure the footpath link shall not be commenced until HDC is satisfied that applicant can demonstrate that the linkages to the pubic bridleway can be delivered. 5. Landscaping condition as per plans (to be implemented in 1st planting season after bund / link implemented) or timing to be agreed by LPA. 6. Landscaping / maintenance condition in accordance with the plans and open space strategy 7. Detail of footpath lighting / surfacing of footpath link to be agreed with LPA.

13.5 Phase 1 residential layout it

It is recommendated that: That the Head of Planning and Environmental Services be delegated to respond in writing to any further design revisions provided by the applicants which seek to address the specific concerns raised by this report (paragraphs 10.21 – 10.30 )and, provide HDC with a list of suggested conditions if these concerns can be satisfactorily addressed.

13.6 If HDC are minded to approve the application, it is recommended that :

1. CBC Officers be consulted on the precise wording of conditions 2. CBC Officers be consulted on the content of the S106 agreement/s

31 Background Papers / Background Information

Appendix 1 – Address list of CBC residents notified. Appendix 2 – Summary of CBC resident responses received. Appendix 3 – Crawley Borough LDF Core Strategy Policies. Appendix 4 – JAAP – Conceptual Masterplan (JCM) Appendix 5 - Crest Indicative Masterplan Appendix 6 - Crest Phasing plan

Contact Officer:- Jean McPherson Direct Line:- 01293 438577

Appendix 1

Neighbour notifications to the following addresses in Bewbush and Ifield West were sent by HDC.

Bewbush: 1-36 Allcot Close, 1-18 Andromeda Close, 20–26 (evens) Andromeda Close, 1-16 Aquarius Court, Bewbush Youth Centre – Barlow Road, 1-6 Basildon Way, 8–18 (evens) Basildon Way, 1-20 Berkeley Close, 1–50 Booth Road, 51–87 (odds) Booth Road, 1– 27 Bracknell Walk, 1–4 Brettingham Close, 1–18 Bunyan Close, 1–14 Callisto Close, 1-27 Calvin Walk, 1–52 Capricorn Close, 1–53 Chetwood Road, 19A Chetwood Road, 1 Collins Road, 13–18 Comper Close, 1–23 Corby Close, 1–37 Cumbernauld Walk, 1–22 Dione Walk, 1–19 Erskine Close, Bewbush Barn, Bewbush Church, Bewbush Manor, 1,2,4 Francis Edwards Way, 1–21 Ganymede Court, 1-11 Pegasus Court – Gemini Close, 1-6 Orion Court – Gemini Close, 1–12 Harmony Close, 30–34 Hatfield Walk, 39–43 Hatfield Walk, 1-37 Henty Close, Beaubush Cottage – Horsham Road, 1-5 Bewbush Manor – Horsham Road, 1-7 Horward Road, 9 Howard Road, 1-22 Hyperion Court, 1–28 Ivory Court, 1–11 Letchwork Court, 1–50 Manorfields, 1–26 Masefield Road, 1–7 Mercury Close, 1–19 Milne Close, 1–4 Miranda Walk, 6–12 (evens) Miranda Walk, 1–7 Neptune Court, 9– 29 (odds) Neptune Court, 1–12 Nesbit Court, 1–16 Norfolk Close, 1–4 Pax Close, 1– 17 Peacemaker Close, 1-20 Peterlee Walk, 1–15 Ransome Close, 1–5 Redditch Close, 2–4 Runcorn Close, 1–12 Samaritan Close, 1–12 Saturn Close, 14 Saturn Close, 1–8 Shirley Close, 11–25 Skelmersdale Walk, 1–11 St Francis Walk, 2 Stevenage Road, 1–10 Thetford Walk, 1–20 Vanbrugh Close, 1–22 Warrington Close, 1–20 Washington Road, 1–47 Waterfield Gardens, Bewbush West Sports Pavilion, Gemini Close, Waterfield Gardens, 1-8 Beech House – Waterside Close, 1- 8 Maple House – Waterside Close, 1-8 Oak House - Waterside Close, 1-19 Waterside Close, 1-23 (odds) Welwyn Close, 1-37 Wesley Close, 38-48 (evens) Wesley Close, 1-28 Wycliffe Court.

Ifield West: 1-20 Abbotsfield Road, 1-27 Ambleside Close, 28–58 (evens) Ambleside Close, 1-27 Berrymeade Walk, 30-32 Berrymeade Walk, 21–91 (odds) Birkdale Drive, 42–56 (evens) Birkdale Drive, 1–16 Bittern Close, 1–7 Bowness Close, 1–25 Coniston Close, Ifield West Community Centre Dobbins Place, 1–37 Fairway, 1-13 Fulmar Close, 1-8 Guillemot Path, 3–11 Hunstanton Close, 1–19 Keswick Close, 1– 25 Kittiwake Close, 1-16 Langdale Road, 17–49 (odds) Langdale Road, 1–29 Moor Park Crescent, 19A & 19B Moor Park Crescent, 4–14 Muirfield Close, 4–17 Prestwick Close, 1–18 Puffin Road, 1–15 Redshank Court, 1–27 Reedings, 1–9 Rydal Close, 1–16 Sandpiper Close, 1–16 Shearwater Court, 37–45 St Andrews Road, 1–10 Stackfield Road, 11–31 (odds) Stackfield Road, 1–18 Stoneycroft Walk, 1–21 Tern Road, 22–26 (evens) Tern Road, 1–25 The Orchards, 1–16 Thirlmere Road, 1–26 Tunnmeade, 1-23 Wayside, 1-5 Woodcroft Road, 1-15 Yewlands Walk.

Appendix 2

REPLIES RECEIVED:-

The following individual comments were sent to HDC by Crawley residents:

12 representations received raising the following issues:

Impacts on Bewbush / Ifield / Crawley  Increased noise (in particular at night) to nearby properties from proposed; Fastway route (Sullivan Drive) access which would operate 24 hours a day;  Fastway route a potential danger to residents using the nearby playing field;  Loss of local park to provide access to Sullivan Drive;  Concern safety of children using nearby recreational facilities due to new Sullivan Drive access;  Increase in traffic and noise;  Development would increase congestion on A264 which is already grid locked – questions how application would overcome this;  Concern regarding ‘rat running’ into Bewbush and increase in traffic;  Query links for the development into Ifield;  Noise and air pollution to nearby dwellings;  Loss of trees / hedges and wildlife and damage to landscape further into Bewbush;  Development no benefit to Crawley residents;  Impact on property price.

Site suitability  Concern about content of tip as evidence of illegal burning on site and therefore possibility of illegal dumping. The landfill site is not suitable for development, questions in the technical report regarding the content of the fill and the safe levels. Questions if the material is inert and therefore safe to construct upon or spread across the wider site;  Concern whether future residents would be advised about potential risks from landfill;  How would the tip landform be stabilised?  Ground conditions very damp and not suited to residential development;  Loss of habitat including protected species such as badgers, bats;  Site a poor housing location exposed to noise / pollution from A264, railway, potential Gatwick expansion, possible Western relief road and proposed CHP;  Decision should be made on WWR prior to allowing housing.

The application details  Concern adequacy / accuracy of supporting information relating to noise, air pollution impacts on residents in Bewbush due to the development and its construction;  Queries if sufficient water supply to support new development;  Request archaeological site investigation carried out prior to development;  No details on CHP – lack of information and concern potential visual impact and odour emissions;

34  Development does not maximise reduction of carbon footprint – missed sustainability opportunity;  Support railway station but is this deliverable?  Lack of information on the proposed employment provision;  Housing at 3.5 to 4.5 storeys would be out-of keeping;  20% Social housing proposed is inadequate to meet local need;  Does development reflect community need?

Appendix 3

Crawley Borough Local Development Framework Core Strategy 2007

Policy WB1 states: A Joint Area Action Plan for the Strategic Development Location West and North West of Crawley will be prepared jointly by Horsham District Council and Crawley Borough Council and will: • Be supported by further work, studies and consultation documents and stages; • Cover the Area of Study for the Strategic Development Location West and North West of Crawley, as defined on the Proposals Map; • Make provision for a high quality mixed-use neighbourhood development comprising of up to 2,500 dwellings (including 40% affordable housing), a new neighbourhood centre (potentially comprising shops, employment floorspace, a community hall, a primary school, a doctor’s surgery, a library, a public house, public open space); • Include the possible provision of new employment, beyond that required in a neighbourhood centre, including the possibility of a strategic employment allocation to meet the needs of the Gatwick Sub-Region; • Include consideration of other uses which may be required to meet wider community needs; • Include the provision of sufficient transport infrastructure to meet the needs of the new development while maximising the opportunities for sustainable travel, including reducing dependency on the car by providing access to local facilities and services, providing high quality passenger transport links (such as Fastway and/or a new interchange station) and ensuring safe, alternative and convenient pedestrian and cycle routes between the development and Crawley and to the countryside; • Determine whether there is a need for any relief or link road between the A264 and A23, the route for any such road, and the means of providing it; • Ensure that new development protects and where possible enhances the setting of the Ifield Conservation Area; • Translate the key principles and objectives for development into policy; • Outline the masterplanning and sustainability principles for the development.

Other relevant policies listed below:

ICS1 – Community provision ICS2 – Infrastructure provision EN1 – Nature Conservation EN2 – Neighbourhood structure EN3 – Green spaces and corridors EN4 – landscape proposals EN5 - Development context CS1 – Safety through design and operation T1 – sustainable transport E2 – employment development E3 – protection of employment space E4 – small scale provision

LAND WEST OF BEWBUSH – POLICY ANALYSIS

POLICY POLICY COMMENT DOCUMENT JAAP WB1 – Neighbourhood West of Bewbush i. Application is for approximately 2,500 dwellings – viability modelled on 2,265 units. Provides for allocation of Land West of ii. Scheme deviates from Masterplan with respect to western bridge crossing; CHP plan; employment Bewbush for 2,500 dwellings and land and buffer to countryside on western edge. associated land uses. Supporting text(3.2) requires a comprehensive devt in accordance with conceptual Masterplan. WB2 – Comprehensive Development i. Application is for a comprehensive development – para’s 3.3 -3.20 set out the requirements for each phase as follows. Ticks/crosses indicate compliance/non compliance with comments in brackets where applicable.

Core Phases 1/2 – Land East of Holmbush Farm Access and West of Landfill Site Access:

- New roundabout junction to be on land immediately north of A264 carriageway within existing poplar plantation.  - Improvement of access to Holmbush Farm Potteries.  - Land to be safeguarded for western relief road between A264 and A23. - Pontail Shaw to be retained and managed for public access including part of circular route. - Land south of access road (2.5 hectares) to be developed for playing pitches – to incorporate existing belt of trees with open space and neighbourhood play area of 1,200m². (Land provided but located further to the east that shown on conceptual Masterplan. Tree screen retained but separated from open space by built development). - Landscape buffer to be provided adjacent to the A264 which will contribute to green linkages in/around West of Bewbush.

Core Phases 1 and 2 – Land East of the Landfill Access and West of Bewbush South of the railway line

- A secondary access to be provided onto the A264 as a right and left in, left out signalised junction to be used for the first core phase of the development and provide emergency access/bus access in the longer term. x (scheme provides for a roundabout for the primary access (west side of site) and a signalised left POLICY POLICY COMMENT DOCUMENT in/left out/right out junction to form the secondary access). - The provision of a safe crossing over the A264  (Pegasus crossing provided) - The provision of east – west link road to link to neighbourhood centre and north - south route to link residential development with neighbourhood centre and railway station.  - Development to start adjacent to the western boundary and Bewbush and then move westwards towards roundabout junction x (Justification for revised approach set out within viability statement with start adjacent to western boundary allowing remediation for rest of site) - Link to existing neighbourhood at Bewbush to be provided at Sullivan Drive for use by buses, emergency vehicles, pedestrians and equestrians and cyclists but not for use by the private car. (issues with delivery given land issues with CBC) - Landscape buffer to be provided along A264 with green route  - Neighbourhood Centre – incorporating a range of uses including retail, recreation, leisure and other community uses such as a primary care centre, pre- school nursery, library and 2-3 form entry primary school adjacent to neighbourhood centre. - Employment floorspace close to neighbourhood centre. (Provided but now relocated further west close to CHP area) - CHP plant  Provided but now within Pontail Shaw). - 3 hectares of playing pitches adjacent to Bewbush - impt to circular routes and green link to Bewbush. - Neighbourhood Centre to constructed in second phase (now within Crest Core Phase 2/3 ) - Railway Station to be a landmark but if not provided a central bridge is required to be provided across the railway line for all transport modes  ( provided but separate equestrian link not included).

Core Phase 2 – Land East of the Landfill Access and West of Bewbush – North of the Railway line

- Development to take place during the second core phase of the neighbourhood development x (Proposed development phasing would depart from the 3 core phases as set out in the JAAP and would be constructed over 5 phases – refer to report Section 3.0) - Land to be developed for residential use at medium density and will include 2 hectares of playing pitches, a neighbourhood play area of 0.12ha.  (Density in the north east corner of the site would be within the range of 30 – 50dph. A area of 1.04 hectare would be allocated in the area known as ‘ The Viewpoint’ which would provide for sports pitches (0.21 to 0.42 hectares; play 0.07hactares; allotments 0.20 hectares and general amenity space of 0.56 hectares. In addition, a general amenity area which POLICY POLICY COMMENT DOCUMENT provide development stand off zones from existing planting and water attenuation features would be provided immediately to the north of the railway). - A small mixed use development to provide convenience shopping north of the railway. x ( Not provided but central spine road with crossing over railway would be provided to neighbourhood centre to south). - Pedestrian, cyclist, equestrian, public transport and emergency vehicle route to be provided adjacent to the railway line between the new neighbourhood and Ifield West into Woodcroft Road.  (Bus plus foot and cycle route provided to Woodcroft Road with and equestrian route provided to the north to Kilnwood Lane). - Landscape buffer to be provided along the railway line to provide noise attenuation and incorporate part of circular walk for pedestrians ( Landscape buffer is provided along the railway line but the primary recreational routes would be located further north running through ‘The Viewpoint’ with the equestrian route running north- south through the area linking through to Kilnwood Lane).

Core Phase 3 – Land east of Holmbush Farm Access and West of Landfill Site Access.

- Link to be provided across the railway line for pedestrians, cyclists and equestrians as part of the circular route that contributes to the green linkages. The link to provide access through Pondtail Shaw and also are area next to Capon Grove to be retained as neighbourhood play area. x (Western Crossing not provided due to impact on Ancient Woodland. Capon Grove to be retained as area of Natural Green Space. Neighbourhood play area now in north western corner of site adjacent to northern end of central spine road). - Landscape buffer to be provided on western side of the development site and no provision for vehicular access onto Kilnwood Lane. (Landscape buffer reliant upon existing hedgerow on western boundary. Pedestrian access only provided to Kilnwood Lane).

WB 3 – Neighbourhood Principle The detailed masterplanning and delivery of the development should incorporate the following neighbourhood principles:

- A neighbourhood centre to act as the focus for services, facilities, community activity and integration; - A concentrated number of formal and informal open spaces; - A legible layout, that facilitates access by all modes of transport to the Neighbourhood Centre and open spaces;  - Clear, pedestrian and cycle linkages throughout the neighbourhood for permeability and surveillance; ; POLICY POLICY COMMENT DOCUMENT - Practical and convenient sustainable transport linkages to and from the Town Centre, primary employment locations and adjacent neighbourhoods;  - Clearly defined edges and character for the area making it distinguishable from the adjacent neighbourhoods;  - The provision of green corridors throughout the neighbourhood and into adjacent neighbourhoods; ; - Distinctiveness achieved through contextual and unique architecture, urban and landscape design. ;

(The report in section 8 provides a summary of the development and explains how the proposed development would fulfil the requirements of the JAAP and the roll of the parameter plans, the Design and Access Statement (incorporating a Strategic Design Code) and Open Space Strategy in securing the vision for the development). WB 4 – Design - The design and layout of the neighbourhood should reflect the neighbourhood principle;  - Development should achieve a high quality, inclusive, mixed use, safe and integrated neighbourhood;  - Development should address the street, create streetscape variety, interest and legibility. Streets, paths, open spaces and communal areas should provide natural surveillance;  - Densities and storey heights across the neighbourhood should vary, with the higher densities and storey heights in the most sustainable locations, such as near transport nodes and the Neighbourhood Centre;  - Contextual and sensitive, but imaginative and innovative architecture, urban and landscape design to achieve a distinctive neighbourhood character;  - Good quality external facing materials, surface and boundary treatments will be required. 

(The report in section 8 explains how the proposed development would seek to satisfy the design requirements of the JAAP through the Design and Access Statement (incorporating a Strategic Design Code) and Open Space Strategy which will set the foundations for the future reserved matters applications and phases of the development ).

Policy WB 5 - Community Centre The Neighbourhood Centre should include a multi-use community centre with flexible space to facilitate a range of activities and community groups. The community centre should provide approximately 700m2 of POLICY POLICY COMMENT DOCUMENT flexible space, the exact size will be determined at the time to meet the needs of the development's population.The Neighbourhood Centre should include a multi-use community centre with flexible space to facilitate a range of activities and community groups. The community centre should provide approximately 700m2 of flexible space, the exact size will be determined at the time to meet the needs of the development's population.  (The community centre would form part of the neighbourhood centre and would be grouped together with the school and library facility. Serviced land would be provided for the development and a contribution would be secured through a legal agreement towards the delivery of the community centre).

Policy WB 6 - Healthcare The development should include a Primary Care Centre of sufficient size to accommodate a four doctor surgery of approximately 700m2, plus additional space for dental services, voluntary and social services and a pharmacy. The exact size will be determined at the time to meet the needs of the development's population. The Primary Care Centre should be located within or adjacent to the Neighbourhood Centre.  (Land would be reserved within the neighbourhood centre for the delivery of the primary care centre)

Policy WB 7 - Library 150m2 of library floorspace should be provided within the Neighbourhood Centre, preferably in conjunction with the development of the community centre.  (An area of 150m² would be allocated within the neighbourhood centre for a ‘resource centre’ which would be linked with the community centre the total floorspace allocation for the community centre being 700m² plus 150m². A financial allocation for the resource centre would be secured through the legal agreement).. WB 8 – Joint Provision of Community Consideration should be given to the provision of community facilities within a single building or a complex Facilities of buildings located within or adjacent to the Neighbourhood Centre. (Community facilities would be clustered around the neighbourhood centre) WB 9 – Retail Between 1,250m2 and 2,500m2 of retail floorspace should be provided within the Neighbourhood Centre. (Land would be allocated for the delivery of non food retails use and main food store fronting a main square with an active edge which would provide linkages to the primary street through the centre and the associated car park) WB10 – Dwelling Mix There should be a mix of dwelling sizes and types within each core phase of the development. For each Core Phase it should be demonstrated how a mix of dwelling size and type is to be delivered.  (Each phase of the development would include a mix of unit sizes and types in line with the density range for the development of approximately 42 – 47 dwellings per hectare based on a range o 2250 – 2500 units across the site. The detail for Phase 1 are set out in the report section 8 refers) POLICY POLICY COMMENT DOCUMENT Policy WB 11 - Affordable Housing Affordable housing should comprise a target 40% of the total housing provided in the neighbourhood. Each phase of the development should contain between 30% and 50% affordable housing. The precise proportion for each phase will be determined having regard to the form and nature of the development, local housing needs and objectives, the need to secure a balanced programme of affordable housing delivery and the need to ensure that different types of affordable housing are appropriately and sustainably located.

A tenure split of 70% social rented and 30% intermediate tenure should be provided across the neighbourhood, although this will be reviewed using up-to-date housing market and needs evidence throughout the implementation of the development. A range of affordable housing type and size should be delivered for each tenure type.

Developers are encouraged to design and build approximately 2% of all affordable homes to fully adapted wheelchair standard and approximately 20% of affordable homes to meet Lifetime-Homes standards.

The delivery of affordable housing will be kept under review during the course of the development. Changes in the size, type or tenure of the affordable housing may be sought to reflect changes in affordable housing need or objectives.

In the event that, for viability reasons, the developer considers the full requirement for affordable housing cannot be met, the local planning authority will need to be satisfied fully that this is the case. In those circumstances it will discuss with the developer how and to what extent those requirements might be amended. The local planning authority may request a viability appraisal be carried out to accompany a planning application.

(The development does not meet the policy target for of affordable housing as set out within this policy but the delivery of the development based upon the current application has been subject to a viability assessment and the provisions of affordable housing has been balanced against securing other benefits and the costs of infrastructure and the remediation of the site. A full consideration of the proposed affordable housing ‘package’ is set out in section 3.0 of this report) t of WB12 – Structural and Informal Structural and informal landscaping should be delivered in accordance with the Conceptual Masterplan. A Landscaping programme for the delivery of the structural and informal landscaping, including advanced planting should POLICY POLICY COMMENT DOCUMENT be agreed with the local planning authority before development commences. (The development would be supported by structural landscaping with details set out within the Design and Access Statement and Open Space Strategy. Conditions would be attached in the event of approval to secure delivery of landscaping). WB 13 – Biodiversity Capon Grove and Pondtail Shaw should be retained. For each core phase of the development, a full assessment of biodiversity should be undertaken and, if required, mitigation measures should be implemented to protect and enhance biodiversity. (Capon Grove and Pondtail Shaw would be retained and the application has been supported by and Environmental Impact Assessment which has assessed the impact on biodiversity and the proposed mitigation). WB 14 – Green Linkages Green linkages should be provided as outlined on the Conceptual Masterplan including: A circuit around the neighbourhood Links into Bewbush, Ifield West, the countryside to the north and west,and south over the A264 into the High Weald AONB A bridleway link across the railway line near to the proposed station, taking account of the need of the minimum necessary distance from the bridleway’s present route and the safety of equestrians on the bridge and its approaches, but subject to reasonable construction and visual impact issues. x (western bridge crossing no longer provided due to impact on the northerm edge of Pondtail Shaw which was designated as Ancient Woodland in 2010)

WB 15 – Noise No residential or other noise sensitive development should be located in areas where they would be exposed to noise levels of 60dBA or more. (The most sensitive parts of the site in terms of noise impact are located adjacent to the railway line and adjacent to the A264. The impact of noise from these and other sources are addressed within the Environmental Impact Assessment and the proposed mitigation measures, which includes the construction of a bund adjacent to the A264 have been examined by Environmental Services. The impact of the noise mitigation measures are addressed within the report (section 8 refers) WB 16 – Flood Risk/Management To minimise the risk from flooding, and to ensure high quality green linkages, no development should be located within Flood Zone 2. Elsewhere within the neighbourhood flood attenuation measures and, where appropriate, SuDS should be incorporated to ensure there is no increase in pre-development run-off rates. For each Core Phase of the development a Flood Risk Assessment should be undertaken and, if required, POLICY POLICY COMMENT DOCUMENT a programme of mitigation measures undertaken. (The application has been subject to a flood risk assessment and the design and location of SuDS features has been subject to consideration by the Environment Agency who raise no objections subject to conditions governing details design and implementation to be attached to the development in the event of approval). Policy 17 – Household Waste Recycling As a minimum, the development should provide index-linked contributions towards the provision of Facilities Household Waste Recycling facilities. (The JAAP explains that discussions with the County Council have indicated that additional HWR infrastructure may be needed to meet the needs of the new development West of Bewbush. Since the publication of the JAAP the County Council have advised that a new facility would not be provided but a contribution would be secured through legal agreements towards household waste recycling facilities). Policy WB 18 – Recreation and Open Open space should be provided within the neighbourhood in accordance with the following criteria: Space Approximately 15.4 hectares of open space across the neighbourhood. The specific amount of open space to be determined by up-to-date population projections for each planning application submitted; A roughly even split between formal and informal open space the exact balance to meet local needs to be determined by up-to-date population projections for each planning application submitted; A structured distribution of open space throughout the neighbourhood, to make it easily accessible by the community and to create urban parks/lungs and neighbourhood focal points; Design and layout of the open space should make it suitable for a wide range of activities for all ages and interests. (The application has been supported by a Design and Access Statement and Open Space Strategy. The JAAP requires the delivery of 15.4 ha of open space, with a broadly 50:50 split between informal and formal provision. The Open Space Strategy demonstrates how the development will provide 23.48 ha of open space with 7.73 ha of formal and 15.75 ha of informal open space which will provide the opportunity for a sport, recreation and visual amenity. The open space includes Parks (Kilnwood Vale Park and Neighbourhood Parks); Community Greens; Green Corridors; Natural Green Space; Civic Space; Green Streets and Green Courtyards) WB 19 – Education The development should include the following education facilities: Nurseries, or equivalent facilities will be provided by the development to meet the requirements of the neighbourhood, through appropriate index linked contributions at each core phase. A 2-3 form of entry primary school at the site identified on the Conceptual Masterplan. The developer will be expected to make land available for the facilities and meet the capital cost of construction. Delivery of the facilities should be phased to ensure pre-school and primary facilities are POLICY POLICY COMMENT DOCUMENT available early in the development of the neighbourhood. Additional secondary school capacity and accommodation will be provided at secondary schools in Crawley, and the development will be expected to secure the capacity through index linked contributions at each core phase. (The development would provide land and buildings for the primary school close to the Neighbourhood Centre and a contribution would be secured through a legal agreement towards secondary education).

WB 20 – Employment Approximately 8000m2 of employment floorspace should be provided in conjunction with or adjacent to the neighbourhood centre and should include space for small, start up and micro businesses. WB 21 – Sustainability/Sustainable The design and construction of the development should incorporate high standards of sustainable Construction construction and seek to exploit opportunities for the creation of a genuinely sustainable new neighbourhood. An energy strategy will be required indicating how independent and/or community approaches to renewable and/or low-carbon energy generation will be implemented to meet and preferably exceed (where feasible and viable) the national timetable for carbon emissions reductions in new homes. The energy strategy will be encouraged to show how at least 10% of the development’s annual (non-transport) energy needs could be met through decentralised renewable and low-carbon generation. A water strategy will be required to show how the development's overall water demand can be reduced in order to meet and preferably exceed (where feasible and viable) the Building Regulations. The new neighbourhood should be designed and constructed to incorporate the principle of adaptation to climate change. Developers are strongly encouraged to incorporate the sustainable construction practices and technologies required to address the full range of aspects covered by the Code for Sustainable Homes and should strive to ensure that all homes meet a minimum of Level 3 of the Code. Where feasible and viable, homes achieving higher levels of the Code will be expected, particularly within the second and third Core Phases. Developers are strongly encouraged to ensure that all non-residential development in the neighbourhood meets a BREEAM standard of at least ‘Very Good’ or its equivalent under any replacement code. An Environmental Infrastructure Area should be provided adjacent to the neighbourhood centre to include facilities that will be necessary for the development to meet the required environmental and sustainability performance standards.(The development would be constructed to a minimum of code level 3 for the residential development and BREEAM very good for the non residential element or the relevant code level required by the building regulations at the time of construction. WB 22 – Former Inert Landfill Remediation Development of the former inert landfill site is subject to: POLICY POLICY COMMENT DOCUMENT The approval and implementation of the remediation strategy; and The implementation of landform modifications linked to the remediation strategy in accordance with the Conceptual Masterplan. (The application has been accompanied by a remediation strategy and sets out through the application for the acoustic bund and accompanying reports the strategy for remediation in phases) WB 23 – Western Relief Road Land required for a Western Relief Road will be safeguarded from the neighbourhood's primary junction with the A264 through the allocated site until it has been determined whether such a route will be necessary to serve further development West of Crawley, or to meet wider sub regional objectives. WB 24 – Railway Station Land required to deliver a railway station and associated uses, including railway station parking within the neighbourhood is safeguarded in accordance with the Conceptual Masterplan pending a definitive decision by Network Rail regarding the provision of a railway station. (Land is safeguarded for the Western relied road if required)

WB 25 – Transport The following sustainable transport measures should be delivered in conjunction with the development of the neighbourhood and the appropriate core phase: - Pedestrian, cycle and equestrian access into: Ifield West Bewbush rural areas to the north and south across the A264 to the AONB Three crossings over the railway, with two capable accommodating vehicular traffic(the number of crossings over the railways has been reduced to 2 bridge crossings – refer to report, section 8 for details of pedestrian, cycle and equestrian access) - Bus and Fastway access at Sullivan Drive, Bewbush (bus gate) Bus access at: Woodcroft Road, Ifield West (bus gate) - The primary A264 junction Measures to secure and maintain suitable bus and Fastway services to the neighbourhood during construction and for the first 3 years after completion of the neighbourhood - Provision of a primary highway access onto the A264 to be provided in the form of a roundabout, potentially improving the access arrangements into Holmbush Potteries Industrial Estate Provision of a secondary left in, left out and right in access onto the A264 for emergency vehicle access only or limited access for necessary or sustainable modes of transport - Delivery of junction improvements at the A23/A2220, to mitigate the impacts of West of Bewbush or additionally utilising proportional contributions towards improvements, which take account of the traffic impacts of other developments allowed for within the Transport - Assessment of the neighbourhood to be prepared and agreed as part of the planning application process POLICY POLICY COMMENT DOCUMENT - A proportional contribution to junction improvements at Junction 11 of the M23 (discussions on going with the Highways Agency – holding direction in force at the time of writing – refer to report para 8.26 refers) - Delivery of junction improvements at the A264/A2220, to mitigate the impacts of West of Bewbush or additionally utilising proportional contributions towards improvements, which take account of the traffic impacts of other developments allowed for within the Transport - Assessment of the neighbourhood to be prepared and agreed as part of the planning application process - A Travel Plan Strategy - All transport improvements are subject to the preparation of a Transport Assessment for the neighbourhood, which will need to be agreed as part of the planning application process. This may determine other improvements are necessary or demonstrate that identified improvements are not required (Transport/Highway impacts have been assessed by WSCC)

Policy WB 26 – Utility Infrastructure The developer should demonstrate that an appropriate level of utility infrastructure will be provided to meet Provision the needs of each Core Phase, or the Neighbourhood in its entirety, for: Water Supply Waste Water (Thames Water require a Grampian condition to secure details of any on and /or off site drainage works) Gas Electricity WB 27 – Longer Term Approach The development, masterplan, design and service and infrastructure provision for the neighbourhood West of Bewbush should not prejudice the potential of longer term development elsewhere in the Area of Study outside the allocated land of Policy WB1

Horsham District Council’s and Crawley Borough Council’s Core Strategy reviews will establish whether there should be a further neighbourhood within or adjacent to Crawley WB 28 – Area of Study Outside the Within Horsham District Council’s administrative area the following policy continues to form part of the allocated land of policy WB1 Development Plan:  DC1 Countryside Protection and Enhancement – General Development Control Policy DPD (Dec 2007)

Within Crawley Borough Council’s administrative area the following policies continue to form part of the POLICY POLICY COMMENT DOCUMENT Development Plan:  C1 Development Beyond the Built-Up Area Boundary – Core Strategy (Nov 2007)  C2 Strategic Gap – Core Strategy (Nov 2007)  EN1 Nature Conservation – Core Strategy (Nov 2007)  G2 Gatwick Safeguarding – Core Strategy (Nov 2007) HDC Core Strategy CP2 – Environmental Quality The high quality management of the District’s environment will be encouraged and supported through a combination of promotional measures, including grant aid where appropriate, and careful appraisal of development proposals to ensure that they provide for enhancement by:  Minimising the emission of pollutants, including noise, odour and light pollution, into the wider environment;  Having no adverse effects on water quality, reduce water consumption, reducing flood risk to new development and ensuring that flood risk to existing development is not increased;  Minimising waste generation and the consumption and use of energy, including fossil fuels, and taking account of the potential to utilise renewable energy sources;  Utilising sustainable construction technologies; and  Incorporating facilities for recycling of water and waste. (The Environmental Statement includes a Sustainability and Climate Change Summary to demonstrate the environmental credentials of the development) CP3 – Improving the Quality of New High quality and inclusive design for all development in the District will be required in order to raise Development standards and gain community support as a beneficial addition to the local environment. A robust design process with the use of skilled designers and appropriate pre-application discussions will be promoted so that proposals can be based on a clear understanding of the local, physical, social, economic, environmental and policy context of the development. In particular, development will be expected to:  Provide an attractive, functional, accessible, safe and adaptable environment;  Complement the varying character and heritage of the District.  Contribute a sense of place both in the buildings and spaces themselves and the historic landscape they will sit;  Optimise the potential of the site to accommodate development and contribute to the support for suitable complementary facilities and uses; and  Help secure a framework of high quality open spaces which meets the identified needs of the community. (Section 8 of the report provides an assessment of the design approach in the context of the outline and POLICY POLICY COMMENT DOCUMENT detailed element of the application) CP4 – Housing Provision Provision is made for the development of at least 10,575 homes and associated infrastructure in the District within the period 2001-2018. This includes:  2,200 completions between 2001-05;  1,390homes already permitted or agreed for release;  At least a further 2,500 homes on previously developed land from 2005-2018;  The westward expansion of Crawley with 2,500 homes;  The development of land west of Horsham for 2,000 homes; and  Up to 255 homes as the small scale gradual growth of the smaller towns and villages in the District. To ensure that the strategic requirements for the District are met, additional land in the most sustainable locations will be identified through the Site Specific Allocations DPD, or a contingency DPD, to be held in reserve and for its release to be managed through Policy CP9. CP6 – Strategic Location – West of Development within the area west of Crawley north of the A264 will be permitted following the completion of Crawley studies to identify the precise form and nature of the development and in accordance with the principles of development set out below, to be defined further in the Joint Area Action Plan for Land West and North West of Crawley. Development will be programmed in order to enable the completion of 2,500 homes and other uses, including employment provision, by 2018.

The provision for development to the west of Crawley is intended to meet the growth and development needs of Crawley and is not considered to be inter-changeable with sites or locations elsewhere within Horsham District.

The development principles are:  The new development should be integrated with the physical and social infrastructure of Crawley, and with the landscape;  The development should take place on a ‘neighbourhood’ principle with the provision of a mix of uses which are likely to include shops, employment, a primary school, a library service, doctors surgery, public open space, local transport infrastructure as well as housing, including affordable homes;  New development should be located and designed in such a way that the sense of separation between Horsham and Crawley is maintained and that the impact of the development on this separation, especially on the Strategic Gap, is minimised; POLICY POLICY COMMENT DOCUMENT  The development will need to take into account the implications of relocating any existing uses and the amenities of existing residents within the area;  Sufficient transport infrastructure should be provided to meet the needs of the new development whilst maximising the opportunities for sustainable travel, including reducing the dependency on the car by providing access to local facilities and services, providing high quality passenger transport links, such as Fastway to Crawley and/or a new interchange station and ensuring safe, alternative and convenient pedestrian and cycle routes between the development and Crawley and to the countryside;  The opportunity to provide new employment, beyond that required for the neighbourhood centre, including the possibility of an employment allocation within the area covered by the Joint Area Action Plan;  The development should seek to minimise any increase in levels of traffic through the existing neighbourhoods of Crawley and where possible, relieve pressure on the existing road network;  The development should provide up to 40% affordable housing, the tenure of which should be determined through the Joint Area Action Plan taking into account the local housing needs of both Crawley Borough and Horsham District;  The western edge of the new development should provide a firm boundary which can be defended against further development;  The development of any relief or link road would need to be met, in part, on land away from the development area should the need for it (along with its form and location) be determined in the Joint Area Action Plan;  New development should protect, where possible, enhance the setting of Ifield Village Conservation Area and avoid areas of flood risk and aircraft noise contours 60dBA Leq or more (either as existing or in alignment of the potential second runway and ‘safeguarded’ area). The noise contour level is only an indication of the desirable upper limit for major new noise sensitive development, and regard will be paid to Government advice on the subject in determining the exact locations of development types;  The development should be based on maximising the opportunities for the use of sustainable construction methods. CP13 – Infrastructure requirements The release of land for development will be dependent on there being sufficient capacity in the existing local infrastructure to meet the additional local requirements arising from new development or suitable arrangements having been put in place for the improvement of the infrastructure, services and community facilities made necessary by the development. Where there is a need for extra capacity this will need to be POLICY POLICY COMMENT DOCUMENT provided in time to serve the development or the relevant phase of the development, in order to ensure that the environment and amenities of local residents are not adversely affected. Arrangements for the provision or improvement, including in terms of access to facilities, to the required standard will be secured by planning obligation, or in some cases conditions attached to a planning permission, so the appropriate improvement can be completed prior to occupation of the development, or the relevant phase of the development. Proposals by service providers for the delivery of physical infrastructure to meet the needs generated by new development and by existing communities will be permitted, subject to other relevant policies. General Development DC1 – Countryside Protection and Outside built up area boundaries, development will not be permitted unless it is considered essential to its Control Policies Enhancement countryside location and in addition meets one of the following criteria:  Supports the needs of agriculture or forestry;  Enables the extraction of minerals or the disposal of waste;  Provides for quiet informal recreational use; or,  Ensures the sustainable development of rural areas. Any development permitted must be of a scale appropriate to its countryside location and must not be lead, either individually or cumulatively, to a significant increase in the overall level of activity in the countryside. DC2 – Landscape Character Development will be permitted where it protects and/or conserves and/or enhances the key characteristics of the landscape character area in which it is located, including:  The development pattern of the area, its historical and ecological qualities, tranquillity and sensitivity to change;  The pattern of woodlands, fields, hedgerows, trees, waterbodies and other features; and  The topography of the area. DC3 – Settlement Coalescence Within Horsham District development will be permitted if it individually or cumulatively does not result in the actual or perceived coalescence of settlements, including through:  Visual intrusion which reduces the openness and ‘break’ between settlements; and,  A significant increase of activity which has an urbanising effect on the area. In addition, within areas designated as a Strategic Gap or immediately abutting the boundaries of a Strategic Gap, development will not be permitted unless it:  Makes a positive contribution to protecting, conserving or enhancing the landscape and amenity of the Gap; or,  Provides opportunities for quiet informal recreation. DC4 – Areas of Outstanding Natural Planning permission will not be granted for proposals in or near to the Sussex Downs or High Wealds POLICY POLICY COMMENT DOCUMENT Beauty AONBs that would adversely affect the character, quality, views, distinctiveness or threaten public enjoyment of these landscapes. Where exceptionally development is necessary, landscape enhancements, mitigation or compensation measures must be provided. DC5 – Biodiversity and Geology Development will not be permitted unless, where relevant, it includes measures to protect, conserve or enhance the biodiversity of the District. In addition, within areas shown on the Proposals map that are designated as being of importance for biodiversity or geology, development will not be permitted where there would be a direct or indirect adverse effect on the site unless it can be clearly demonstrated that:  The reason for the development clearly outweighs the need to protect the value of the site; and  That mitigation and compensation measures are provided. DC6 – Woodland and Trees Felling of protected trees will only be permitted in exceptional circumstances, and, where unavoidable, replacement planting with suitable species will be required. Applications for surgery to protected trees where the proposals are contrary to best arboricultural practice, and/or would detract from the amenity value of the trees in question will be refused. DC7 - Flooding Development will not be permitted where it would:  In accordance with the sequential test set out in Government guidance, be at risk from flooding;  Not incorporate appropriate mitigation measures to help limit any increase in the risk of flooding in adjacent or downstream areas; and  Not comply with the tests and recommendations set out in the Horsham District Strategic Flood Risk Assessments. DC8 – Renewable Energy and Climate Planning permission will only be granted for proposals which ensure that: Change  Measures are incorporated that reduce the impact on climate change; and  Wherever possible and certainly for any development of 10 or more dwellings and other forms of major development, sufficient on-site renewable energy equipment or other design measures are provided to achieve at least 10% reduction in the scheme’s predicted carbon dioxide emissions. DC9 – Development principles Planning permission will be granted for developments which:  Make efficient use of land whilst respecting any constraints that exist;  Do not cause unacceptable harm to the amenity of the occupiers/users of nearby property and land, for example through overlooking or noise, whilst having regard to the sensitivities of surrounding development;  Ensure that the scale, massing and appearance of the development is of a high standard of design and layout and where relevant relates sympathetically with the built surroundings, open spaces and POLICY POLICY COMMENT DOCUMENT routes within and adjoining the site, including any impact on the skyline and important views;  Are locally distinctive in character, respect the character of the surrounding area (including its overall setting, townscape features, views and green corridors) and, where available and applicable, take account of the recommendations/policies of the relevant Design Statements and Character Assessments;  Use high standards of building materials, finishes and landscaping; and include the provision of street furniture and public art were appropriate;  Presume in favour of the retention of existing important landscaping and natural features, for example trees, hedges, banks and watercourses. Development must relate sympathetically to the local landscaping and justify and mitigate against any losses that may occur through development; and,  Ensure buildings and spaces are orientated to gain maximum benefit from sunlight and passive solar energy, unless this conflicts with the character of the surrounding townscape, landscape or topography where it is of good quality.

Proposals will also need to take the following into account where relevant:  Incorporate where appropriate convenient, safe and visually attractive areas for the parking of vehicles and cycles, and the storage of bins/recycling facilities without dominating the development or its surroundings;  Incorporate measures to reduce any actual or perceived opportunities for crime or antisocial behaviour on the site and in the surrounding area; and create visually attractive frontages where adjoining streets and public spaces, including appropriate windows and doors to assit in the informal surveillance of public areas by occupants of the site  Contribution to the removal of physical barriers; and  Make a clear distinction between the public and private spaces within the site Applicants must consider the relevance of all of the criteria within this policy to their proposal, no matter how large or small, and may be asked to justify why they do not consider a specific element relevant to their application. DC10 – Archaeological Sited and Ancient Planning permission will not be granted for proposals that would cause unacceptable harm to an important Monuments archaeological sites or their setting. Where there is evidence that archaeological remains may exist on a site, the Council will require applicants to submit an archaeological assessment prior to the determination of a planning application. If, in exceptional circumstances, permission is granted on such sites, preservation in situ of important POLICY POLICY COMMENT DOCUMENT archaeological remains will be sought. If preservation of archaeological remains by record is agreed to be appropriate, the applicant will be required to arrange and fund the excavation, investigation, recording, reporting and publication of findings to an acceptable professional standard. Where practical, measures should be taken to raise awareness of any archaeological work during the construction phase. DC22 – New Open Space, Sports and New open space, sport and recreation facilities will be permitted in the following circumstances: Recreation  The lack of provision for built sports or recreation facilities has been identified in the Horsham District Council PPG17 Assessment.  The proposed enhancement of existing facilities.  The proposal is part of a development requiring provision for open space, sports and/or recreation facilities. The provision of open space, sport and recreation facilities will be required as a consequence of new development. Applicants should refer to the Horsham District Council PPG17 Assessment for the provision standards and quality of open space, sport and recreation facilities within the District. DC40 – Transport and Access Development will be permitted if:  It provides a safe and adequate means of access;  It is appropriate in scale to the transport infrastructure, including public transport;  It is integrated with the wider network of routes including public rights of way and cycle paths where appropriate;  It makes adequate provision for all users, including for car and other vehicle parking, giving priority to people with mobility difficulties, pedestrians, cyclists and equestrians;  It includes, where appropriate, provision for public transport either within the scheme or through contributions; and,  The proposal is accompanied by an agreed Green Travel Plan where it is necessary to minimise a potentially significant impact of the development on the wider area or as a result of needing to address an existing local traffic problem.

HEADS OF TERMS AND MEMBERS' ROUTE MAP TO THE PLANNING OBLIGATIONS - HORSHAM DISTRICT COUNCIL

Please note this is a general summary of the heads of terms of the planning obligations which should be read in conjunction with the comments raised in the Officers report. The details and mechanism by which they would be secured in the context of the legal agreement will be subject to further negotiations. Item (JAAP ref) Amount/Specification Timing 1. Affordable Amount Phased Provision by reference to occupations of market Dwellings within the same Housing Phase 1 20% Phase Phase 2/3 25% (WB11) Phase 4/5 36% Reserve Relief Rd Land 40% Cascade

Standard: Code 3 minimum Stage 1: no more than 75% Market Dwelling Occupations in any Phase until Tenure: Guaranteed 70% intermediate30% affordable rented - plus for invitation to purchase contracts for that Phase extended to Affordable Housing every £40,000 of HCA grant one intermediate tenure affordable flat can Provider (AHP) switch to affordable rented - if larger rented properties needed to switch grant rate requirement will be higher Stage 2: if despite offer to purchase contracts are not exchanged with AHP within 6 Cooperation: Crest and HDC to work to maximise grant - availability at months then obligation will convert into positive obligation to construct the relevant start of each Phase affordable by 90% market occupations and disposals can be either to AHPs or Occupancy: 50/50 nomination rights 50/50 HDC/CBC or zone agents directly to individuals in housing need. 2. Open Space Specification: determined through reserved matters but based on the Provided Phase by Phase in step with each of the 5 Phases of development north Biodiversity Open Space Strategy Document. and south of the railway - planning conditions to contain a programme for each Pavilion and Strategy Doc gives a firm basis but flexibility to accommodate changes in Phase and its related areas of open space green linkages local preferences and landscaping includes sports pitches pavilion play spaces allotments, community woodland, park, formal and informal recreation and related footpath cycle (WB 12 13 14 bridleway network on site 18) Commuted sums for any areas dedicated to HDC 3. Multi Use To be provided free of charge in Neighbourhood Centre (approx 700 Freehold transfer of Completed building to HDC - if County Resources Centre Community square metres as per JAAP) included then WSCC need 60 year lease at "peppercorn" rent Building With WSCC's agreement this can combined with County Council (WB 5) Resources Centre (which would add 150 sq metres approx to the building) 18 month Contract for Community Centre to be let by 150th Dwelling in Phase 3 in which case the Combined Community Centre will be designed to a combined design budget of £1,000,000 (One Million Pounds) If WSCC require separate building design budget will reduce pro rata 4. Employment Land to be reserved and set aside and subject to a Marketing Campaign Marketing Campaign starts not later than 800 Dwellings ends at 1300 Dwellings or Land 5 years from its commencement if later. If all or part not developed by the 1300th (WB 20) occupation land may be used for alternative purposes 5. Retailing Land to be reserved and set aside and subject to a Marketing Campaign Marketing Period to be agreed but if not developed by an agreed threshold land may (WB9) be used for alternative purposes 6. Primary Care Land to be reserved and set aside and subject to a Marketing Campaign Marketing Period To be agreed but if not developed by agreed threshold land may (WB6) be used for alternative purposes 7. SUDS In accordance with approvals under planning conditions In step with the progress of each Phase of the Development possible transfer to (WB 21 WB 26 HDC plus commuted sum on phased basis 8. Railway Land to be reserved and set aside for these purposes - pending final Reservation runs from Commencement but if Network Rail confirms it does not Station and decision by Network Rail - currently optimistic but too early to tell what intend to pursue or if not developed for intended purp0oses by agreed threshold Station Car Park ultimate decision may be then reservation falls away and land may be used for alternative purposes (WB 24) 9. Public Art One piece (max cost £20,000) per Phase - approved through conditions 90% of Dwelling Occupations in the relevant Phase maintained pending any transfer to HDC plus commuted sums if transferred

1014/413/6603768.3 1 03 March 2011

HEADS OF TERMS AND MEMBERS' ROUTE MAP TO THE PLANNING OBLIGATIONS - WEST SUSSEX COUNTY COUNCIL Please note this is a general summary of the heads of terms of the planning obligations which should be read in conjunction with the comments raised in the Officers report. The details and mechanism by which they would be secured in the context of the legal agreement will be subject to further negotiations. Item (JAAP Amount/Specification Timing Ref) 1. Early Yrs Land reserved set aside in Neighbourhood Centre ("NC") - a) 500 Qualifying Dwellings to procure contract with private Provision/ Developer can: a) provide privately, b) build facility and pass to operator b) 600 Qualifying Dwellings to construct and Contribution WSCC or c) Pay £950,975 Contribution to WSCC to build facility on handover to WSCC c) 500 Qualifying Dwellings (WB 19) the site 2. Primary 2.35 hectare Site plus 0.42 hectare extension area to enable Grant WSCC option to acquire for £1 at trigger point TBA - School Site extension to 3 FE to be reserved and set aside in NC if WSCC do not extend to 3 FE then School Extension Land (WB 19) becomes Reserve Land 3. Primary Amount calculated by reference to a formula (no contributions for Stage payments payable in instalments from later of: letting School affordable dwellings) of contracts for initial 1 FE and subsequent extension to 2/3 Contributions FE or 600 and 1200 Qualifying Dwellings (WB 19) 4. Secondary Amount calculated by reference to a formula (no contributions for Stage payments payable in instalments from later of letting School affordable dwellings) of contracts for extensions of existing Secondary Schools Contributions or 1600 and 2400 Qualifying Dwellings (WB 19) 5. Resources Either provided as integral part of a larger Community Building (circa Payment made on 150th Dwelling in Phase 3 or if County Centre 850sq m) and designed to a budget of £1m - located in NC or if and District agree to integrate Resources Centre in WSCC prefers then £176,470 contribution towards Resources Community building then contract for combined facility to be (WB7) Centre Provision as a part of School complex - flexible building let by 150th Dwelling in Phase 3 approx 150 sq m designed for use for a variety of County services e.g. libraries fire service community policing 6. Fire Hydrants Provision to meet requirements of WSCC in consultation with West Prior to first occupation of any Dwelling (WB 26) Sussex Fire Brigade 7. Travel Plan To be nominated and appointed by Crest and remain in post for 10 Nominated prior to first occupation of any Dwelling Co-ordinator years from Commencement (WB 25) 8. Promotional To draw Travel Plan to attention of all first purchasers tenants and Throughout marketing of development Material occupiers 9. Travel Packs Travel Pack to set out information on public transport and alternative To each new household on arrival (WB 25) modes 10. Essential e.g. establishing travel plan forum managing travel plan budget For a period starting with Commencement and ending 10 Travel Plan undertaking surveys reviewing targets preparing and distributing years later Obligations (WB travel packs installation of real time information points at bus stops 25) and NC to be performed by Crest

1014/413/6603771.3 1 03 March 2011

Item (JAAP Amount/Specification Timing Ref) 11. Cheals £1,946,902 2100 occupations if monitoring demonstrates works needed Junction Stage - any surplus to be applied to sixth form provision 2 improvement contribution (WB 25) 12. Sullivan £483,159 Contribution subject to monitoring provisions 56 days after Drive Junction completion of monitoring if conclusions of monitoring are improvement that improvement needed (WB 25) 13. Highway As per planning application/highways agreement Option (a) Main Access 1 Dwelling; Secondary Access 300 Works Main Dwellings Occupations Access and Secondary Access (WB 25) As per planning application/highways agreement Option (b) Main Access 50 Dwellings; Secondary Access 1 Dwelling Occupations 14. Footpath Temporary connection to existing footpath on boundary of site TBA Connection (WB across Sprucehill Brook - temporary surfacing 25) Permanent connection to existing footpath on boundary of site TBA across Sprucehill Brook - wearing course 15. Cheals As per planning application/highways agreement TBA Drive Stage 1 Works (WB 25) 16. Internal Link A. Completed to Base Course level. A. TBA Road (A264 to District B. Completed to Wearing Course level with all necessary lining and B. 750 Dwelling Occupations Centre) signing. 17. A264 As per planning permission and any section 38/278 agreement To be completed within 12 months of the A264 highway Highway works being completed landscaping (WB 12/25) 18. Bus Route 1 - Shuttle Bus (service level (a))...... 50 Dwellings Services/Bus Route 1 - Shuttle Bus (service level (b)) ...... 300 Dwellings Gates (WB 25) Route 2 - Extension of existing Fastway Service or similar service 900 Dwellings into Site (via Sullivan Dr bus gate) ...... 900 Dwellings Route 3 – Diversion of existing services 23/24 through Site (via 1650 Dwellings Sullivan Dr bus gate)...... 2100 Dwellings

1014/413/6603771.3 2 03 March 2011

Item (JAAP Amount/Specification Timing Ref) Route 4 - Diversion of existing service 200 (via Sullivan Dr bus gate) .. Route 5 - Extension of existing service 300 or similar into Site (via Woodford Dr bus gate)...... It is anticipated that the shuttle bus should be well subscribed from the outset. Once the first shuttle bus becomes self-funding then further additions to the service can be made. The standard of service and specification of vehicles is contained in the schedules to the County Agreement - subject to grant of all necessary rights and approvals by CBC diversions of services 3, 4 and 5 will use the Sullivan Drive bus gate and service 5 will use the Woodford Drive bus gate Diversion of existing services in to the Site will be subject to the agreement of the existing operating companies - a degree of subsidy (this being limited to a maximum of 5 years for each relevant service as per the JAAP) may be required to encourage bus operators to extend existing services into the site during the early years 19 Junction 11 Improvements to safety and capacity of Junction 11 - to be dealt with Stage 1 Lights 350 Dwellings Stage 2 Widening 800 of M23 by condition and 278 agreement Dwellings

1014/413/6603771.3 3 03 March 2011

APPENDIX A/ 1 - 1.

DEVELOPMENT abcd CONTROL REPORT

TO: Development Management North

BY: Head of Strategic Planning and Performance and Head of Planning and Environmental Services

DATE: 15 March 2010

DEVELOPMENT: a) Outline approval for the development of approximately 2500 dwellings, new access from A264 and a secondary access from A264, neighbourhood centre, comprising retail, community building with library facility, public house, primary care centre and care home, main pumping station, land for primary school and nursery, land for employment uses, new rail station, energy centre and associated amenity space. b) Full planning permission for engineering operations associated with landfill remediation and associated infrastructure including pumping station. c) Full permission for the construction of a 3 to 6 metre high (above ground level) noise attenuation landform for approximately 700 metres, associated landscaping, pedestrian/cycleway and service provision (land known as Kilnwood Vale) d) Full permission for the development of Phase 1 of 291 dwellings, internal roads, garages, driveways 757 parking spaces, pathways, sub-station, floor attenuation ponds and associated amenity space.

SITE: Holmbush Farm Landfill Site Crawley Road Faygate West Sussex

WARD: Rusper & Colgate

APPLICATION: DC/10/1612

APPLICANT: Crest Strategic Projects Limited

REASON FOR INCLUSION ON AGENDA: Category of development

RECOMMENDATION:

1. Subject to the removal of the ‘holding direction’ from the Highways Agency that Planning Permission for a) b) and c) be granted subject to:

Contact: Hilary Coplestone Extension: 5451 APPENDIX A/ 1 - 2.

I. the prior completion of a Legal Agreement with Horsham District Council within 6 months of the date of this Committee (pursuant to Section 106 of the Town and Country Planning Act 1990 as amended and all other relevant statutory powers, the content of the Legal Agreement being subject to continued joint working between officers at this Council and Crawley Borough in consultation with WSCC regarding Highway/Community/Education matters);

II. the content of the s106 agreement and that the details of the agreement be agreed with the Chairman, Vice Chairman and the Horsham Members of the Joint Member Steering Group;

III. the prior completion of a Legal Agreement with WSCC within 6 months of the date of this Committee (pursuant to Section 106 of the Town and Country Planning Act 1990 as amended and all other statutory powers, the content of the Legal Agreement being subject to continued joint working between officers at this Council and Crawley Borough Council and ESCC regarding Highways/ Community/Education matters);

2. the decision in respect of d) be deferred to enable officers from both this Council and Crawley Borough Council to resolve outstanding issues in respect of the layout and that the decisions on this element of the scheme be delegated to officers in consultation with the Chairman, Vice Chairman and the Horsham Members of the Joint Member Steering Group;

3. the schedule of conditions to be subject to further joint working between officers at this Council and Crawley Borough Council and that the conditions be agreed with the Chairman, Vice Chairman and the Horsham Members of the Joint Member Steering Group.

1. THE PURPOSE OF THIS REPORT

DESCRIPTION OF THE APPLICATION

1.1. This report provides an assessment of the hybrid planning application by Crest Strategic Projects for the development of 132 hectares of land to the West of Bewbush (Refer to site plan Appendix 1). The land forms part of the allocation identified in the adopted West of Bewbush Joint Area Action Plan (JAAP) (July 2009). The JAAP forms part of the Local Development Frameworks for Horsham and Crawley. The delivery of the planning application has been subject to a Planning Performance Agreement (PPA) which sets out joint working arrangements between this Council, Crawley Borough Council and the developer Crest Nicholson. The application site is wholly within the district of Horsham but Crawley Borough Council is a statutory consultee. Crawley also has a land interest adjacent to the eastern boundary of the site, where land would be required to provide the sustainable transport measures and integration with the existing neighbourhood of Bewbush through bus, pedestrian and cycle links as set out within the JAAP.

1.2. The application comprises four elements:

APPENDIX A/ 1 - 3.

a) Outline approval for the development of approximately 2500 dwellings, new access from A264 and a secondary access from A264, neighbourhood centre, comprising retail, community building with library facility, public house, primary care centre and care home, main pumping station, land for primary school and nursery, land for employment uses, new rail station, energy centre and associated amenity space.

b) Full planning permission for engineering operations associated with landfill remediation and associated infrastructure including pumping station.

c) Full permission for the construction of a 3 to 6 metre high (above ground level) noise attenuation landform for approximately 700 metres, associated landscaping, pedestrian/cycleway and service provision (land known as Kilnwood Vale)

d) Full permission for the development of Phase 1 of 291 dwellings, internal roads, garages, driveways, 672 parking spaces, pathways, sub-station, floor attenuation ponds and associated amenity space.

1.3. The four elements of the application are interrelated with the broad principles of the application being set out in the outline application, where the curtilage of the application site extends to the whole land holding. Within this area the detailed elements of the application include the land to be to be remediated; the area subject to the Phase 1 application and the area along the front boundary of the site for the construction of the landscaped bund to provide the noise attenuation landform.

1.4. The application has been accompanied by an Environmental Impact Assessment (EIA) which includes a series of parameter plans which model the maximum impact of the development and a Design and Access Statement (DAS), with a series of parameter plans which reflect the development proposal. In the event of approval any decision would be linked to the following parameter plans within the DAS:

Land Use Plan

Illustrative Density Plan

Building Heights Plan

Pedestrian and Cycle Movement Plan

Vehicular Movement Plan

Landscape Open Space Plan

1.5. At subsequent reserved matters phases the applicant would be required to submit a statement of conformity to demonstrate compliance with the EIA but this would not preclude the Council seeking a further EIA in the event that the predicted impacts were likely to be greater/different than those modelled in the outline scheme.

APPENDIX A/ 1 - 4.

1.6. Additional supporting documents submitted at the time of the registration of the application and post submission includes the Planning Statement (including draft Unilateral Agreement to WSCC and HDC for infrastructure provision), Design Statement for the A264 Accesses; the Strategic Design Code (as part of the DAS); the Open Space Strategy; Street Lighting report; Site Waste Management Plan; Utilities report; Arboricultural Survey; Sustainability statements plus additional reports/responses to address questions relating to the acoustic data and an analysis of the car parking provision for the development as a whole and for the Phase 1 element of the scheme.

1.7. The disposition of land uses is shown on the Land Use parameter plan which illustrates:

- The location of residential development – this would comprise a mix of unit types with densities ranging from 30 – 40 dph north of the railway line separated by a ‘pocket’ of higher density 40 – 50 dph to the north of the proposed station/station crossing; 45 – 45 dph within the core of the development around the neighbourhood centre dropping to 40 – 50 dwellings per acre either side of this central area and to the south adjacent to the A264. (The density range is illustrated on the Illustrative Density Parameter Plan). The overall anticipated mix for dwellings is as follows:

1 & 2 bed flats 25% 2 bed houses 17% 3 bed houses 32% 4/5 bed houses 26% Within this mix the affordable housing provision would be as follows:

1 bed flats – 25% 2 bed flats – 25% 2 bed house – 25% 3 bed house – 15% 4 bed house – 10%

Based upon current market assumptions of mix, density, market conditions and without more detailed layouts, it is estimated that the site would deliver a range of between 2250 and 2500 units.

Building heights (residential and non residential development) would range from 2 - 2.5 storeys north of the railway line and between Bewbush Brook and the railway to 2- 4 storey adjacent to the neighbourhood centre and the station/station crossing and 2 – 3 storeys either side of the core of the neighbourhood and to the south adjacent to the A264.

- The location of the points of access to the site from the A264 which would comprise:

i) A primary access to the development, served by a roundabout junction which would also provide access to the Holmbush Potteries Industrial Estate to the south. The primary access road exit lanes to the main roundabout from the APPENDIX A/ 1 - 5.

development would include traffic signals to manage traffic flows from the site and encourage the use of public transport. The signals would operate in conjunction with a bus lane to provide an advanced priority for bus services. ii) A secondary left in, left out and right out access on the A264 located at the point of access to the existing landfill site. This would be signalised to encourage use of the primary access over the secondary access. The existing access would be used as the construction access for the first phase and the access for vehicles associated with the remediation of the site in the short term. The provision of the secondary access is linked to the provision of a Toucan crossing for pedestrians and cyclists, and Pegasus crossing for equestrians. This would provide a safe crossing point across the A264 replacing the existing crossing point from the public bridleway which runs north-south along the eastern boundary of the site. The primary access would be provided prior to the first occupation of the Phase 1 development and the secondary access prior to the completion of the 300th residential unit.

The A264 would continue to be subject to the 70mph speed limit but it is anticipated that measured speeds on the A264 will be reduced due to the introduction of the new roundabout junction at the primary access. On completion of the highway works, speed monitoring will be undertaken to inform whether there is a need for further measures to reduce speed or if a reduced speed limit could be put in place.

The primary and secondary access points to the development are linked to a broader access strategy with a network of primary and access streets running through the development with the street hierarchy based upon prioritising the following modes: pedestrians; cyclists; public transport; service vehicle and other vehicles. Vehicular modes of transport are a key function of street hierarchy. However it is pedestrian and cycle movement both within the site and to destinations outside which has shaped the Masterplan and has been given high priority. A central north - south access spine would be provided through the development linking homes to the key destinations including the neighbourhood centre, railway station and Fastway terminus and development to the south of the site and the countryside beyond. This north – south access spine would provide a wide segregated route, along which buildings and houses will be orientated to provide passive surveillance. Primary and secondary routes would link to and or bisect the north south access spine which would also be linked to recreational and equestrian routes to provide connections between the recreational areas, open space and woodland.

Two bridges would cross the railway to accommodate foot and cycleways, with the eastern route also providing the equestrian route.

Integration with the existing neighbourhood of Bewbush would be provided by the delivery of bus gates to the north of the railway line to Woodcroft Road, Ifield West and to the south of the railway line at Sullivan Drive. Both access points would be restricted to bus/ pedestrian/cyclist/ equestrian/emergency use. An additional pedestrian/cycle access would be provided at Chetwood Road to APPENDIX A/ 1 - 6.

serve the first phase of the development and this would also be retained in the longer term.

The western boundary of the application site to the south of the railway is currently shown as open space however this land is reserved for a western relief road. The reservation of this land is a requirement of the JAAP Policy WB23 which states that ‘Land required for a Western Relief Road will be safeguarded from the neighbourhood’s primary junction with the A264 through the allocated site until it has been determined whether such a route will be necessary to serve further development West of Crawley, or to meet wider sub regional objectives’. The JAAP requires the land to be safeguarded for a period of 5 years from May 2009 or up to the date of adoption of the two Core Strategy Reviews. The proposed design of the primary junction would not prejudice the delivery of the western relief road if required. ii) A neighbourhood centre which would include the following facilities to serve the community which the DAS describes as including the following:

- A new 2 form entry 420 space primary school and nursery on 2 hectares on land with a further 1 hectare of land reserved for the extension of the school to provide 3 forms of entry if required.

- A food retail store of 2,100m² net sales space with a car park and potential petrol filling station occupying a site area of 2.05 hectares (5.07 acres) with potential office and residential space above (para 15.12 of the DAS refers).

- Four small shops with a total of 400m² net floor space and 16 residential units above.

- Land for a primary care facility of 700m²; including space to accommodate a four doctor surgery;

- A 60 – 80 bed elderly care home facility;

- A community building comprising 700m² of flexible space including a library;

- A ‘food based’ public house of 525m². iii) A main pumping station located to the eastern side of the site on edge of Kilnwood Vale Park to serve the development v) Employment land – the proposal would provide serviced land for the development of 8,000m² of employment floorspace adjacent to the neighbourhood centre within the vicinity of the station and the neighbourhood centre. An area of 0.77 hectares (1.90 acres) would be provided to the north of the food retail store and adjacent to the neighbourhood centre and 1.28 hectares would be located adjacent to the location of the new station. APPENDIX A/ 1 - 7.

vi) Railway Station – this would be located to the south of the railway line and would provide a central point along the north south axis. The station would include passenger facilities, a transport interchange (being on the Fastway bus route) and a 200 space car park for rail users. The applicant has established rights to cross the railway and a Basic Services Agreement has been agreed between Network Rail’s outside parties department and the applicant as a precursor to final contractual arrangements.

vii) Energy Centre – an area of 1.04 hectares has been identified for an energy centre to serve the development.

viii)Amenity Space – 47.6 hectares (116.78 acres) would be allocated as open space and this would comprise formal open space (including sports facilities and play areas) and informal open space (including allotments and general amenity space). Details of the proposed provision are set out within the Open Space Strategy but the three key areas of open space illustrated on the Open Space Masterplan include:

- North of the railway line, known as The Viewpoint - Neighbourhood Park located in the centre of Phase 1 residential area - Kilnwood Vale Town Park to the east of the site adjacent to Bewbush

1.8. The area of land allocated to the respective land uses is summarised in Schedule 1 below:

Area Ha Ac (net) Residential(including local access) 53.38 131.90 Neighbourhood Centre 3.60 8.90 Employment 2.04 5.04 School (inc land reserved) 2.08 (3.1) 5.14 (7.66) Main infrastructure 8.02 19.82 Other roads 1.06 2.62 Energy Centre Area 1.04 2.57 Reserve Land 9.51 23.50 Open Space 47.26 116.78 Station, Railway Line and Car Parks 3.06 7.56 TOTAL 132.07 326.35

Schedule 1 – Land Use Schedule

1.9. Whilst the submitted information supports the outline application it also relates to the detailed elements of the scheme. The key information submitted in respect of the three detailed elements of the application (paragraph 1.1 refers) is set out below:

1.10 Full planning permission for engineering operations associated with landfill remediation and associated infrastructure including pumping station.

APPENDIX A/ 1 - 8.

The details of the proposed remediation strategy is set out within the EIA supplemented by the Planning Statement; the site contour plans (both existing and proposed) which illustrate the strategy for earthworks movements across the site by phases and the proposed noise attenuation bund along the A264 frontage of the site.

The provision of associated infrastructure to serve the development is set out within the utilities report and supporting plans which explain that suitable infrastructure including electricity, gas, telecommunications, foul water and portable water will be in place in a phased manner to meet the needs of the development. A key element of the associated infrastructure includes the provision of a pumping station on the eastern side of the development on the edge of the proposed park (Kilnwood Vale Park) which would provide the ability to control the discharge of sewage generated by the development at a rate which is acceptable by Thames Water.

1.11 Full permission for the construction of a 3 to 6 metre high (above ground level) noise attenuation landform for approximately 700 metres, associated landscaping, pedestrian/cycleway and service provision (land known as Kilnwood Vale

The noise attenuation landform with the details of the pedestrian and cycleway including the connectivity with Bewbush through a link into Chetwood Road forms part of the detailed application for Phase 1 but also links to the development of the later phases to the east which are subject to the outline application.

1.12 Full permission for the development of Phase 1 of 291 dwellings, internal roads, garages, driveways, 757 parking spaces, pathways, sub-station, floor attenuation ponds and associated amenity space

This element of the application includes the proposed site layout showing the relationship of the first phase of the development to:

- the western boundary (land reserved for a potential western by pass); - the environmental infrastructure area (combined heat and power plant) to the north within Pondtail Shaw); - the front boundary along the A264, the proposed acoustic bund (included within the engineering operations as part of (b) above and the pedestrian and cycle link to Bewbush; - the eastern boundary and the area of existing woodland and hedgerow.

The application provides details of the primary access onto the A264 with the secondary access, a left – in/ left out/ right-out junction forming part of the outline application. The roundabout junction which forms part of the primary access would also provide access to the Holmbush Potteries to the south of the A264. The proposed layout is accompanied by plans and elevations of the individual unit types along with street scene views supported by a proposed materials plan. Additional plans illustrate car parking, servicing details and landscaping proposals. The landscaping plans not only show proposed planting within the site area but also at the Phase 1 site boundaries.

The Phase 1 housing mix would comprise: APPENDIX A/ 1 - 9.

1 / 2 bed flat – 23% 2 bed house – 17% 3 bed house – 33% 4/5 bed house – 27%

1.13 The paragraphs above provide a broad overview of the individual elements which comprise this outline application but further details are set out within the attached report prepared by Crawley Borough Council (Appendix 3) which provides, in Section 6, a detailed description of the development proposal as a whole. Section 5 of the report and Section 7.0 also provides a description of the site and a summary of the planning history, in particular the relationship to the landfill operation which has taken place on the site and the more recent planning policy history. The joint working between this Council and Crawley Borough Council in the delivery of the JAAP is set out in Section 4.

2.0 THE PHASING OF THE DEVELOPMENT

2.1 The JAAP breaks down the development into three phases to reflect ‘the level and type of the development they are anticipated to accommodate, the infrastructure provision that is required to facilitate development of the core phase, and if required the land remediation and landform remodelling that is required’. (Paragraph 8.35 refers).

2.2 The application now provides for five phases and the provision of infrastructure that relates to these phases is set out below:

Phase 1 – development would commence in the south west corner of the site. A footpath/cycle link linking to Bewbush at Chetwood Road and shuttle bus service would provide linkages to the Crawley in the early phases.

Phase 2 – the neighbourhood centre would be commenced in phase 2 and completed in Phase 3. The bus gate at Sullivan Drive would be provided at this stage.

Phase 4 and 5 – the station, bridge crossing and Woodcroft Road bus gate would be delivered as part of stages 4 and 5.

3.0 PLANNING OBLIGATIONS

3.1 The Community Infrastructure Levy (CIL) came into force on 6th April 2010. CIL is a new charge which local authorities are empowered, but not required, to levy on most types of new development in their areas. The proceeds of the levy will provide new local and sub-regional infrastructure to support the development of an area in line with the prevailing development plan.

3.2 The Council is currently reviewing the Community Infrastructure Levy Regulations 2010, updates and the associated guidance before making a decision whether to apply the charging regime to new development in the District.

APPENDIX A/ 1 - 10.

3.3 The guidance note produced by the Communities and Local Government – ‘Community Infrastructure Levy – An Overview’ states:

‘From 6th April 2010 it will be unlawful for a planning obligation to be taken into account when determining a planning application for development: or any part of a development, that is capable of being charged, whether there is a local CIL in operation or not, if the obligation does not meet all the following tests:

a) necessary to make the development acceptable in planning terms; b) directly related to the development; and c) fairly and reasonably related in scale and kind to the development’

3.4 Appendix 5 identifies that the following matters need to be provided in order to make the development acceptable in planning terms: Horsham District Council Heads of Terms  Affordable housing  Open space, biodiversity, pavilion, green linkages and landscaping  Community building  Employment land  Retailing  Primary care  SUDS  Railway station and station car park  Public art West Sussex County Council  Early years provision/contribution  Primary school site  Secondary school contributions  Resources centre  Fire hydrants  Travel plan  Promotional material  Travel packs  Essential travel plan obligations  Cheals junction and Drive  Sullivan drive junction  Main access and secondary access  Footpath connection  Internal link road (to District Centre)  Highway landscaping  Bus service/gates The precise details are subject to current and continued negotiation.

Affordable housing would be delivered in the following phases:

Phase 1 (291 dwellings) 20% of which would be affordable

Phases 2 and 3 (between 874 and 1100 dwellings) 25% of which would be affordable

APPENDIX A/ 1 - 11.

Phase 4 and 5 (up to 1100 dwellings) 36% of which would be affordable.

In addition to the above a further 40% of affordable units would be provided on the land reserved for the western relief road if this is not required.

3.5 In summary the affordable housing package (excluding the reserve land) would equate to an overall provision of 29.7% across the site. If you take into consideration the provision of 40% affordable units on the land reserved for the western relief road (if the land is not required for that purpose) the total across the whole site including this land would be 30.7% affordable. The offer is subject to:

- no retrospective test, recalculation or reassessment with regard to the percentage of overall units to be provided;

- a tenure split of 30% social rented and 70% intermediate tenure based upon nil grant, with a provision to increase the amount of social rented up to 70% with 30% as intermediate subject to the availability of grant or other funding.

3.6 The package of benefits offered in connection with the development is designed to secure the comprehensive development of the site with the delivery of key infrastructure and facilities in line with the JAAP and the Horsham District Supplementary Planning Document on Planning Obligations. It is considered that the obligations offered do meet the test as set out in paragraph 3.3 above and also the tests set out in Circular 05/05 Planning Obligations.

4.0 PLANNING POLICY FRAMEWORK

STATUTORY BACKGROUND

4.1 The Town and Country Planning Act 1990 (As Amended)

RELEVANT GOVERNMENT POLICY

4.2 The following planning guidance is relevant in the assessment: PPS1 - Delivering Sustainable Development; PPS3 - Housing; PPS7 - Sustainable Development in Rural Areas; PPS 9 - Biodiversity and Geological Conservation; PPG13 - Transport; PPG17 - Planning for Open Space, Sport and Recreation; PPG24 – Noise; PPS25 - Development and Flood Risk and the South East Plan (May 2009).

RELEVANT COUNCIL POLICY

4.3 Paragraph 1.2 of the JAAP sets out the following policy framework for the development. This states:

‘The adopted Horsham District Council and Crawley Borough Council Core Strategies set out the key principles for the development of 2,500 homes and other uses in the Area of Study;West and North West of Crawley. The Joint Area Action Plan expands these principles to provide a more detailed planning framework for the development of land West of Bewbush. The Joint Area Action Plan does not repeat the policies in either Core or the adopted Horsham District General Development Control Policies document but the Plans should be read together to aid decision making and will be material considerations APPENDIX A/ 1 - 12.

in the determination of any planning applications, together with the adopted Horsham District Planning Obligations Supplementary Planning Document. ‘

4.4 The application has been screened for compliance with the policies within the JAAP as set out in Appendix 4. However, it is important to note that this schedule should not be read in isolation from the prevailing policies of the Horsham District Council Core Strategy (which sets out the principle of a neighbourhood West of Bewbush) or the detailed development control policies (along with the Supplementary Planning Document on Planning Obligations) which are a material consideration in the assessment of the application and are set.

OUTCOME OF CONSULTATIONS

5.0 The consultation responses in respect of the application are set out in Appendix 2.

6.0 HOW THE PROPOSED COURSE OF ACTION WILL PROMOTE HUMAN RIGHTS

Article 8 (right to respect of a private and family life) and Article 1 of the First Protocol (protection of property) of the Human Rights Act 1998 are relevant to the application. Consideration of Human Rights forms part of the planning assessment below.

7.0 HOW THE PROPOSAL WILL HELP TO REDUCE CRIME AND DISORDER

It is not considered that the proposed development would have any impact on crime and disorder.

8.0 PLANNING ASSESSMENT

8.1 There is no objection in principle to the development of the site given its designation as a site for a high quality mixed use development within both this Council’s and Crawley Borough Council’s Core Strategies and the specific policy framework provided by the Joint Area Action Plan.

8.2 This planning assessment addresses the four elements of this hybrid planning application and by reference to the Policy Analysis Schedule within Appendix 4 and the Consultation Summary Schedule with Appendix 2 key outstanding issues have been identified. In this section of the report, the key issues are identified within each element of the application which form the basis for the planning assessment and recommendations for action and or the decision making process.

8.3 a)Outline approval for the development of approximately 2500 dwellings, new access from A264 and a secondary access from A264, neighbourhood centre comprising retail, community building with library facility, public house, primary care centre and care home, main pumping station, land for primary school and nursery, land for employment uses, new rail station, energy centre and associated amenity space.

The key issues are: APPENDIX A/ 1 - 13.

i) Compliance with the Conceptual Masterplan within the JAPP; ii) The Phasing of the development iii) Planning Obligations including the delivery of Affordable Housing iv) The connections between the development to the existing neighbourhoods of Crawley, countryside, public rights of way and cycle routes v) The delivery and impact of the on site/off site highway infrastructure associated with the development vi) The delivery of the Design Quality and the Design and Access Statement vii) The landscape impacts of the development

Each issue is addressed below:

i) Compliance with the Conceptual Masterplan

8.4 Policy WB1 of the JAAP provides for the development of 2,500 dwellings and associated land uses and the supporting text requires a comprehensive development in accordance with the Conceptual Masterplan (CM) which illustrates the intended location of specific land uses.

8.5 The proposed disposition of uses is illustrated on the Land Use Plan within the Design and Access Statement which sets the parameters for the development. These plans illustrate that the differences between the proposed development and the CM relate to:

ii) the location of the neighbourhood centre which has moved 100m south from the railway line and the railway station further west to align which a north south axis route through the development; (The CM shows the neighbourhood centre and railway station/station car park being separated by Bewbush Brook. The relocation of the railway station arose from discussions between the applicant and Network Rail regarding the best location for operational reasons given the potential closure of Faygate Station and the decision of the applicant to see the realignment of Bewbush Brook as an opportunity to create a feature in the neighbourhood park (‘Kilnwood Park’) between the neighbourhood centre and the site boundary. The repositioning of these uses is acceptable subject to the design strategy demonstrating linkages between the station; the brook; the neighbourhood centre and uses further south).

iii) the location of the employment land which is shown on the edge of the neighbourhood centre and within the vicinity of the railway station;(The CM shows the employment land within the neighbourhood centre. The proposed split is however attractive given an employment use would be located at a transport hub which would be served by the railway and Fastway bus service.

iv) the location of the environmental infrastructure area i.e. proposed combined heat and power plant (CHP) plant within Pondtail Shaw; (The location was selected to minimise the impact of the facility by the screening provided by the surrounding woodland. The alternative location is considered acceptable in principle subject to safeguarding the residential development to the south and the Ancient Woodland are on the edge of Pondtail Shaw). APPENDIX A/ 1 - 14.

v) removal of the western bridge crossing from Pondtail Shaw to the north (due to the physical and visual impact of the crossing on an area of Ancient Woodland within Pondtail Shaw which was designated post the adoption of the JAAP); (The number of bridge crossings over the railway has been reduced from 3 to 2 and the central bridge crossing which would form part of the secondary street network now being realigned between Pondtail Shaw and Capon Grove in a position that would avoid the 15m buffer zone at the woodland edges. The reduction in bridge crossings is acceptable subject to design detail and ensuring that a crossing facility is provided with the station design to ensure access to the station from the north and south of the site); vi) the pedestrian, cycle and equestrian route which is shown running around the perimeter of the development; (The constraints imposed by the crossing point within Pondtail Shaw has impacted upon the ability to provide the green linkages as shown on the CM but the application is supported by a movement strategy which demonstrates the opportunity for pedestrian; equestrian and cycle movement throughout the development); vii) the encroachment of the primary access road into the eastern edge of the reserve land and the redesign of the secondary access (located at the point of the existing landfill access) which would be used for cars in addition to emergency vehicles and has been redesigned to provide a ‘right out’ rather than ‘right in’ junction ;(The proposed encroachment of the primary access road into the reserve land is acceptable subject to landscaping details whilst the proposed changes to the secondary access would be acceptable in highway terms and potentially assist in slowing traffic speeds (along with the roundabout junction serving the primary access) on the A264. viii)the provision of a pedestrian and cycle access to link the first phase of the development into Chetwood Road; (The inclusion of this additional route is desirable given the need to ensure integration between the development from the first phase of the development and in the longer term). ix) the relocation of the proposed playing pitches on the western edge of the site (now within Phase 1) adjacent to the indicative line of the primary access further east and the removal of Poplar Copse. (This would facilitate development either side of the access road and improve accessibility to the playing pitches/open space whilst the trees with Poplar Copse are not of good quality and these would be provided within the wider site layout). x) the relocation of open space shown on the CM as being located north of the railway line to a position north of the railway at the end of a north south axis spine.(The revised location is acceptable being in line with the proposed north movement access; providing a transitional route through a park to the countryside beyond and forming part of a recreational route through the development) xi) the provision of an additional area of open space to the south between the proposed secondary access and the eastern boundary of the site known as ‘The Knoll’. (This would form a landscaped feature and a viewpoint within the APPENDIX A/ 1 - 15.

development and would be acceptable in principle subject to acceptable landscaping/management details).

xii) the proposed location of a sewage pumping station on the eastern edge of ‘Kilnwood Vale Park’(The facility is required to serve the development and whilst there is no objection in principle this would be subject to conditions governing the design, external appearance, screening and technical specification).

8.6 The CM was intended to provide an indicative distribution of land uses to ensure the delivery of the new neighbourhood whilst recognising that the detailed form and layout of the neighbourhood will be determined through a planning application or applications. The CM was shaped by the topography and the environmental constraints on the site but also by the advice received from key consultees arising during the preparation of the JAAP. The consultation summary in Appendix 2 sets out the response to consultation which includes the response from Gatwick Airport. Gatwick Airport does not object to the principle of the development but this is subject to a condition being attached to limit building heights along a section of the northern boundary of the site with Kilnwood Lane. Such a condition would have the effect of reducing the quantum of residential development north of the railway line and thereby the ability to deliver the distribution of land uses as set out on the CM. The applicant has sought the removal of such a condition and is currently is dialogue with Gatwick Airport. If agreement cannot be reached the applicant would have the right to seek to submit an appeal against the condition. At this stage the condition sought by Gatwick Airport is not seen as a reason to delay determination of the planning application.

8.7 Additional concerns have been raised regarding the density of the development north of the railway line by a residential occupier in Kilnwood Lane who is of the view that the density range now proposed exceed that subject to discussion at the Public Examination into the JAAP. The JAAP itself seeks to deliver 2,500 units on this site but does not specifically make reference to density requirements. Density ranges will be dependent on site constraints, for instance the density proposed for the north of the railway line is illustrative and will be governed by other factors not least the potential Gatwick safeguarding area set out in paragraph 8.6 above.

8.8 To conclude, whilst there is no objection in principle to the proposed changes to the Conceptual Masterplan in land use terms, the following sections of the report will highlight issues arising from the disposition of uses shown in the current planning application, in particular relating to the CHP plant and the Phase 1 application.

ii) The Phasing of the development

8.9 The phasing strategy for the site is set out in Section 2.0 above which explains the move from three core phases as set out in the JAAP to five core phases. The shift in the phasing strategy for the site is related to the viability of the development and the remediation strategy for the site to ensure that residential units could be constructed in Phase 1 to secure an early receipt whilst the remediation takes place on the land within Phases 2 and 3. Whilst there is no objection in principle to the revised phasing strategy, this would be an important element of the legal agreement attached to the development in the event of approval since it will be APPENDIX A/ 1 - 16.

necessary to ensure that triggers are set for the delivery of the key infrastructure in line with unit completions.

iii) Planning Obligations including the delivery of Affordable Housing

8.10 The JAAP not only sets out the phasing strategy for the development but also the key requirements of the developer in terms of infrastructure provision and affordable housing. The applicant has provided a schedule setting out the planning obligations that would be secured in connection with the development which is attached as Appendix 5 with the key elements including the provision of affordable housing summarised in Section 3 above.

8.11 The level of affordable housing has been central to the discussions on viability of this site. The JAAP (Policy WB11 refers) requires:

- a target level of affordable housing of 40% - each phase of the development to contain between 30% and 50% affordable housing - a tenure split of 70% social rented and 30% intermediate tenure to be provided across the neighbourhood, although this will be reviewed using up to date housing market needs evidence throughout the implementation of the development; - a range of affordable housing type and size to be delivered for each tenure type; - 2% of all affordable homes to be fully adapted wheelchair standard and approximately 20% of homes to meet Lifetime – Homes standards.

8.12 Policy WB 11 provides for a viability appraisal to be carried out to accompany the planning application if the developer considers that the full requirement for affordable housing cannot be met.

8.13 The developer submitted a viability appraisal which was subject to independent scrutiny by the District Valuer and as a result of negotiation the applicant has agreed to provide the affordable housing package as set out in Section 3 above. CBC (report dated 7th March refers – Appendix 3) concludes that since it has been demonstrated, in the light of a viability appraisal, that the site could not deliver 40% affordable housing, the proposed package of 29% of affordable housing across the whole of the development is acceptable, subject to agreement to a tenure mechanism being agreed in the context of the legal agreement. The Housing Development and Strategy Manager at this Council states that the Housing Officers both at this Council and Crawley feel that the affordable housing offer (which has been subject to comprehensive and rigorous negotiations with the applicant) is acceptable. The development would therefore secure affordable housing to a level which would deliver a balanced community whilst the details of the agreement would allow tenure mix to be adjusted to reflect changing circumstances and local need as the development progresses.

iv) The connections between the development to the existing neighbourhoods of Crawley, countryside, public rights of way and cycle routes

APPENDIX A/ 1 - 17.

8.14 Policy WB25 of the JAAP relates to the transport strategy for the development. This policy sets out the sustainable transport measures which should be delivered in conjunction with the development and the appropriate core phase. This builds upon one of the key elements of the development vision for the West of Bewbush with the emphasis upon integration as set out in paragraph 2.2 of the JAAP i.e.

“A sustainably built and located development, based on the neighbourhood principle, where residents can become involved in their community and share the benefits of a high quality of life. A wide range of local services will be accessible to local residents and there will be strong and sustainable links, with Crawley. The neighbourhood will be served by excellent public transport opportunities, which will give access to a wide range of services and facilities, Crawley town centre and employment opportunities. There will be high quality open spaces and informal leisure facilities but there will also be links into the surrounding countryside, the character of which will be respected.

8.15 The Policy Analysis Schedule in Appendix 4 shows how the development would fulfil the objectives of the JAAP in terms of the integration with the existing neighbourhoods of Crawley and the wider countryside. The development would include the additional linkage to Chetwood Road to provide integration between Phase 1 of the development and Bewbush by foot and cycle. The link would be provided to serve Phase 1 but would also be retained in the longer term. The details of this link are considered alongside the detailed elements of the application for the Phase 1 development and the noise attenuation bund. The footpath and cycle link would be supplemented by the following bus service improvements:

- Fastway service 10 extended into the site. - Extension of service 200 into the site. - Extension of service 300 into the site. - Service 23/24 diverted through the site.

8.16 At this point, it is important to emphasise that the provision of linkages to the neighbourhood of Crawley would be facilitated by the acquisition, by the applicant, of land owned by Crawley Borough Council. The ‘land deal’ is a matter which falls outside the assessment of the planning application but is a matter which has been identified as a cost by the applicant impacting upon the viability of the scheme and the planning obligation package including the delivery of affordable housing. The summary of the planning obligation package to be secured in connection with the development is set out in Section 3.0 above.

8.17 Concerns to the degree of connectivity between the development and the wider countryside have been raised by the Countryside Access Forum and the National Cycling Organisation.

8.18 The concerns of the Countryside Access Forum for West Sussex which also includes the British Horse Society specifically relate to the loss of the multi use circular route; the need for a grade separated crossing on the A264; the linkages with existing routes on the southern side of the A264 i.e. the need to provide for a route going east as a dedicated bridleway to link to the existing line of bridleway 1550/1 and the need for multi-use links on the eastern side of the development. APPENDIX A/ 1 - 18.

8.19 The removal of the western bridge crossing from Pondtail Shaw and the location of the new central bridge crossing between Pondtail Shaw and Capon Grove have impacted upon the provision of equestrian crossing points to the northern half of the development, Kilnwood Lane and the countryside beyond. The impact of the western bridge crossing on Pondtail Shaw is explained above (paragraph 8.5 iv) but it is also important to note the design constraints relating to the new bridge crossing which needs to be outside the 15m safeguarding zone for the Ancient Woodland within Pondtail Shaw and Capon Grove; to provide for its use by buses; cars; pedestrians and cyclists and to be of a design which meets the technical and safety requirements of Network Rail whilst being of an external appearance which is commensurate with the design quality required for the development. The length and the angle of the bridge between the two areas of Ancient Woodland present specific design challenges and restrict the width of the bridge and thereby the accommodation of a route for equestrians.

8.20 Whilst equestrians would not be able to use the central bridge crossing to the west of the station they could use the shorter and more direct crossing to the east of the railway line where the design and technical constraints would not be as challenging. This route would provide linkages to Kilnwood Lane to the north and Ifield West to the east and along the existing public right of way running along the eastern boundary of the site.

8.21 With respect to access to the south of the A264 the provision of a grade separated crossing is not a requirement of the JAAP and the proposed Pegasus crossing over the A264 would facilitate a safe route to the south. Although the feasibility of a grade separated crossing was explored, technical constraints; land ownership issues (relating to land to the south) and costs prohibited its inclusion as part of the scheme. The need to provide a dedicated route linking to existing routes on the A264 is not specifically proposed as part of this scheme but the development would not preclude its provision in the future subject to landownership issues being resolved .

8.22 The National Cycle Forum shares the concerns of the Countryside Access Forum regarding the safe crossing over the A264. The proposed crossing would include a Toucan Crossing for pedestrians and cyclists which would be delivered by the 300th dwelling. The street hierarchy of the development prioritises modes as follows pedestrians; cyclists; public transport; service vehicles and other vehicles with the street design providing for a maximum speed of 20mph within the development. This would meet the requirements of the National Cycle Forum with additional benefits for cyclists being secured through improvements to existing Public Bridlepath 1550 which will be improved to cyclepath standards from the Horsham – Crawley cyclepath link to Ifield West Southwards to the proposed Sullivan Drive Bus gate. The details of this improvement to be secured by a condition attached to the development in the event of approval.

v) The delivery and impact of the on site/off site highway infrastructure associated with the development

APPENDIX A/ 1 - 19.

8.23 The Policy Analysis Schedule indicates that the development would fulfil the requirements of the JAAP in terms of the provision of a primary and secondary highway access to the A264. Whilst there have been changes to the design and in the case of the secondary access, use of the access, WSCC has confirmed that the technical design detail is acceptable (subject to further road safety auditing at detailed design stage). Post completion of the highway works speed monitoring will take place to inform whether there is a need to introduce measures to reduce speed or if a reduced speed limit could be put in place.

8.24 The integration of the development with the existing neighbourhoods of Crawley is a central requirement of the JAAP and the proposed linkages at Woodcroft Road, Sullivan Drive and Chetwood Road are fundamental elements of the sustainable transport strategy for the site. The land required for the linkages is within Crawley and the applicant would be required to submit separate planning applications to Crawley. The applications would be considered on their own merits having regard to the JAAP and prevailing planning policy within Crawley but this Council would be a consultee. In the event of the approval of the current application it is recommended (as advocated within the report by CBC to its own Development Control Committee on 7th March 2011 – Appendix 3 paragraph 9.27 refers) that a Grampian condition be imposed (whereby the development cannot commence the proposed dwellings until the applicants can satisfy this Council that they can deliver the required linkages). The wording of the condition would be agreed with planning officers at CBC.

8.25 The following off site highway works are proposed to mitigate the impact of the development :

- Two stages of works to the A2220/A23 (Cheals Roundabout) - comprising slip road improvements and full signalisation of the junction. An early contribution (by the completion of Phase 1) would enable the delivery of an improved slip road an additional traffic at the A264 east bound approach to Cheals Roundabout to increase capacity. Further contributions would be made towards the full signalisation of Cheals Roundabout;

- Contributions towards improvements to the M23 and Junction 11;

- Possible signalised gyratory at Sullivan Drive/A264 junction if monitoring proves it necessary.

8.26 WSCC and the Highways Agency raises no objection in principle to the technical/design details of the proposed measures and at the time of writing the Highways Agency have advised that they are currently reviewing the developers proposals against their design standards and Safety Audit procedures to ensure that there is a reasonable prospect that the works could be delivered. At the present time the Highways Agency has placed a ‘holding direction’ which expires on 24th March 2011 requesting that the application is not granted until their full assessment has been undertaken. The Highways Agency has advised that it is expecting the ‘holding direction’ to be removed shortly i.e. before the 15th March 2011. The Highways Agency has advised that in the event of the scheme being acceptable it would expect it to be secured through a Grampian condition. APPENDIX A/ 1 - 20.

Members will be updated on this matter through late material presented at Committee.

iv) The delivery of the Design Quality and the Design and Access Statement

8.27 WB3 of the JAAP sets out the neighbourhood principles which are required to be reflected in the masterplanning and the delivery of the development with the design principles set out within policy WB4. These key principles (as set out in the policy analysis schedule attached as Appendix 4) are supported by supporting text (paragraphs 4.4 – 4.8 of the JAPP which emphasises the importance of:

- Good design as a key element in securing sustainable development through the creation of an attractive, legible, safe and accessible environment. - The linkages between buildings, the streetscape, urban and green landscaping, the orientation of buildings, the scale of buildings and use of appropriate materials. - Environments and spaces with natural surveillance, which should reduce the likelihood and fear of crime. - Sensitive and considered integration with the urban and rural edge.

8.28 The importance of a ‘good, well reasoned, consistent and thorough Design and Access Statement (DAS)’ which includes a Phasing Strategy at outline planning stage is set out in paragraph 4.6 of the JAAP. Key elements of the advice set out in paragraph 4.6 and the related paragraphs 4.7 – 4.8 include:

- The need for the DAS to demonstrate an overall vision and overarching design principles; - The need for the design principles to provide a solid foundation for a high quality development; - The need for the DAS to demonstrate with the necessary clarity and consistency, and in accordance with best practice, how the vision and principles would inform the detailed design and ensure a high quality development. - The need for the DAS to include a strategic, site-wide masterplan which shows the different land use elements and the broad urban form, including the block structure and street pattern, etc. - The need for the DAS to include sample layouts to demonstrate how the vision would work and how the desired level of quality would be achieved. - The need for the DAS to include a high level Design Code which should be of high quality and provide clarity and the right balance between prescription and flexibility. - The need for a detailed masterplan and design code for each phase, graphically illustrating the layout and built form and designed to accord with the principles in the DAS, is a necessary precursor to the submission of reserved matters applications in order to clearly establish the relationship of each development parcel to the scheme as a whole.

8.29 The specific advice regarding content of the DAS is to ensure that the document will form a solid foundation for the subsequent reserved matters applications and APPENDIX A/ 1 - 21.

establish design quality whilst allowing the masterplan to respond to changing circumstances as the site develops whilst still being guided by the overarching principles set out in the DAS. Paragraph 4.8 of the JAAP makes it clear that ‘ Planning permission would include a condition requiring that the detailed masterplans, design codes and reserved matters applications should be in accordance with the DAS unless otherwise agreed in writing by the LPA’.

8.30 The DAS is a comprehensive document and has been subject to discussion throughout the application process to ensure that the document will secure the design quality required by the JAAP. As a result of this process an addendum has been provided by the applicant to address specific issues raised by officers relating to the following:

- The Neighbourhood Centre to include reference to residential uses above the ground floor of the non food retail uses and smaller independent uses that from the main square; the requirement for the food retail store to have an active edge to the primary street; the requirement for the non food retail uses and smaller independent uses to ‘turn the corner’ to provide an active edge to the pedestrian connection between the neighbourhood centre and the car park and the food store to be articulated so that it can be secured outside of operational periods to function as part of the larger perimeter block. - The Knoll to include examples of sculptured land forms. - The Circus to include a greater area of green space and a potential design solution based upon this. - Design detail for bridge structures. - Reference to the need for the communal open space to be overlooked from neighbouring residential development to ensure that secure and subject to surveillance. - Reference to ensure that all the faces of buildings relating to the public realm having opening to habitable rooms. - Clarification of views which would be provided from the view point in the northern part of the site. - Additional information relating to the landscaping principles and tree species. - Additional information relating to the provision of informal play opportunities for children.

8.31 Whilst the addendum has addressed a number of key points, the Urban Design Manager at Crawley Borough Council identifies three remaining areas of concern with the content of the DAS. As set out in the report to Development Control Committee at Crawley dated 7th March 2011 these relate to:

- The need for a commitment to provide residential above the neighbourhood food store to create more vitality and surveillance of the area. - The location of the school and the potential for congestion and traffic conflicts due to the access of the school being from the primary street running through the neighbourhood centre. - The design detail and quality fix for the Brook Crossing and Station Square. Whilst there are no fundamental concerns about the design principles a APPENDIX A/ 1 - 22.

greater level of detail is required on the perspective drawing to demonstrate design quality. - The need for the addendum to be updated regarding the delivery of the bus gates.

8.32 The Design and Conservation Officer at Horsham does not disagree in principle with the points which have been raised but is of the view that the Neighbourhood Centre along with the Station and the Brook Crossing would be subject to a design brief.

8.33 Subject to a condition which requires future applications to be in accordance with the DAS (as required by paragraph 4.8 of the JAAP as discussed above) with the exception of the Neighbourhood Centre, the Brook Crossing and the Station where further information in the form of a planning brief would be required, it is considered that the DAS would meet the requirements of WB4.

vii) The landscape impacts of the development

8.34 High quality landscaping is central to the vision for the development and policy WB 12 of the JAAP requires structural and informal landscaping to be delivered in accordance with the Conceptual Masterplan. Landscaping has been central in the assessment of the scheme and in discussions with the developer, involving officers at this Council, CBC and WSCC. The addendum to the DAS has addressed a number of issues emerging for the discussions and the consultation summary document (Appendix 2) identifies the following outstanding concerns raised by this Council’s Landscape Architect:

- The height of the chimney to the Combined Heat and Power Plant which is shown as being up to 60m in height and the impact upon the skyline of the Kilnwood Ridge and wider countryside and the Strategic Gap and the potential impact of a building of up to 25m in height adjacent to housing within Phase 1. (Whilst the concerns are acknowledged the detailed design of the building and chimney could be addressed at the detailed design stage).

- The lack of illustrative information regarding the CHP plant (It is recommended that in the event of approval a condition be attached to require the submission of a technical and design brief for this building prior to commencement of the northern section of Phase 1 north of the watercourse).

- The Landscape and Open Space Parameter Plan fails to demonstrate that the 15m standoff zones around the areas of ancient woodland would be achieved (A condition is recommended in the event of approval to ensure that the standoff distance would be complied with).

- The loss of tree group W15 i.e. Poplar Copse. (A condition to require the large semi – mature replacement trees within the nearest open spaces closest to the loss is recommended).

- The need for a Design Brief for the Neighbourhood Centre (agreed – refer to paragraph 8.32 above) APPENDIX A/ 1 - 23.

- The hard landscaping pallet is not agreed and should be subject to condition (Agreed whilst the pallet sets the quality the specific selection of materials will be subject to condition at each phase).

8.35 Subject to the additional matters identified above it is considered that the outline application fulfils the requirements of WB12.

b) Full planning permission for engineering operations associated with landfill remediation and associated infrastructure including pumping station.

The key issues are:

i) The remediation strategy and the impact of the remediation works on landscape character ii) The impact on neighbouring residential occupiers on the eastern boundary of the site iii) The environmental safeguards associated with the remediation strategy

i) The remediation strategy and the impact of the remediation works on landscape character

8.36 Policy WB22 of the JAAP relates to the remediation of the former inert landfill site. The policy comprises two parts i.e. i) the approval and implementation of the remediation strategy and ii) the implementation of landform modifications linked to the remediation strategy in accordance with the Conceptual Masterplan.

8.37 Paragraphs 6.20 - 6.24 (page 9) of the report to CBC provides an explanation of the remediation strategy for the site. In summary, the remediation works would be carried out in 3 broad phases as set out below:

Phase 1 – this would involve the excavation of the SuDs feature in Phase 1, the removal of topsoil from this area, ground levelling in phase 1 and initial works to the bund along the A264 at its western end;

Phase 2 – this would involve the formation of the A264 bund and works towards the southern end of the landfill;

Phase 3 – this would involve works to the northern end of the landfill including works to Bewbush Brook and the railway bridge crossings.

8.38 The proposal would result in the remodelling of the existing landfill material to create a development platform for the neighbourhood. The Environmental Statement states that around 480,000 m3 of inert fill will be excavated during the remediation works as part of the cut and fill for the site. The viability report submitted in connection with the application allows for the removal of material off site as part of the remediation programme although it is not known if/how much would be required to be removed from the site. The Planning Statement submitted in respect of the application states at paragraph 2.116:

APPENDIX A/ 1 - 24.

‘The Remediation Strategy and the landform modelling at this stage have achieved a materials balance and do not require the off site disposal of soils. Nevertheless, in the event that any unsuitable materials that cannot be suitably processed on site need to be removed, discussions with major waste management operators in the region indicate that there are no problems with these materials being accepted for recycling or landfill disposal’.

8.39 The remodelling of the existing landform would result in the provision of a flat and more even gradient than that which appears at present but in order to achieve technical/design specifications for the road over the railway and the re-alignment of Bewbush Brook the level of the land would be raised to provide a platform for the bridging of the railway.

8.40 The Knoll feature at the end of the central axis spine through the development would be positioned behind the acoustic bund and would be on an area of land which is already above the existing natural ground level. The existing level would be increased by 12m to create a viewpoint. The feature would be visible from the A264 from the acoustic bund but it is considered that it would be an integral element of the landscape strategy for the site and contribute to the existing landscape character of the area.

ii) The impact on neighbouring residential occupiers on the eastern boundary of the site

8.41 The impact on the residential occupiers on the eastern boundary of the site in terms of visual amenity and the environmental impact of the proposed remediation work is set out the in the CBC report dated 7th March 2010 (page 24) (refer to Appendix 3). Whilst the report concludes that the remediation works are not considered to have a detrimental impact on views into or out of Crawley it recommends conditions in the event of approval relating to:

- the monitoring of gas concentrations during and after the proposed remediation works; - the submission of a Environmental Management Plan (EMP) - the submission of a Construction Environmental Management Plan before the commencement of the remediation works.

8.42 This Councils Public Health and Licensing Officer supports the approach and the use of conditions as recommended by CBC to ensure that environmental safeguards are in place.

8.43 c) Full permission for the construction of a 3 to 6 metre high (above ground level) noise attenuation landform for approximately 700 metres, associated landscaping, pedestrian/cycleway and service provision (land known as Kilnwood Vale).

8.44 The key issues are:

i) The landscape impact of the noise attenuation bund APPENDIX A/ 1 - 25.

ii) The effectiveness of the noise attenuation bund in safeguarding the living conditions of future residents iii) The relationship between the noise attenuation bund and cycle link

i) The Landscape impact of the noise attenuation bund

8.45 The bund would be linked to the remediation strategy set out in paragraphs 8.36 – 8.40 above. A description of the landscape bund is set out in paragraphs 6.27 – 6.29 (page 9/10) of the CBC report dated 7th March 2011. In summary the bund would take the following form from west to east:

- West of the secondary access the bund would be 3m above road level. This section would include an acoustic wall which would also be incorporated into the design detail of the proposed roundabout. The bund would be landscaped and this landscaping would provide a green edge to the footpath/cycle way and continue to the west of the roundabout entrance into the Phase 1 of the development to provide an entrance ‘Gateway’.

- To the east of the secondary access, the bund would start adjacent to Beaubush Cottage and extend to a height of 4m above the current ground level. It would rise to a height of 6m midway along this section before dropping to 4m at the secondary access.

8.46 The creation of the bund would serve to screen the development from the A264 and through landscaping would provide a green edge to the development when viewed from the road. From within the site the development would provide a buffer to the road and a landscaped edge to the proposed footpath and cycleway running along the southern boundary. The landscape and screening benefits are accepted and the relationship to Beaubush Cottage on the eastern boundary would be acceptable.

ii) The effectiveness of the noise attenuation bund in safeguarding the living conditions of future residents

8.47 The bund is designed to provide the necessary acoustic protection for future residents of the development. The key issue is whether the height and design of the bund is acceptable having regard to the alignment of proposed residential development, within the first and later phases of the development along the front boundary of the site. Any increase in the height of the bund would not be acceptable in landscape terms, therefore it is necessary to ensure that the bund is fit for purpose and provides the protection required to the adjacent residential properties.

8.48 The effectiveness of the bund in providing the acoustic protection to residential properties along the southern boundary, in particular Phase 1, has been raised by the relevant officers at both Councils and additional information has been submitted by the applicant in response to concerns relating to noise modelling to verify the conclusions drawn in the initial assessment. Whilst this information has helped to allay some of the concerns of the environmental health officers at Crawley and Horsham, outstanding issues relate to the i) construction details of the bund to APPENDIX A/ 1 - 26.

ensure that it will conform to the measures as modelled in the acoustic report and ii) the measurement of the performance of the barrier at night. The Public Health and Licensing Officer at Horsham is also of the view that the concerns relating to acoustic protection could be addressed through internal alterations to the residential units to remove noise sensitive rooms from the front boundary.

8.49 Whilst the internal arrangement of rooms is an option that the applicant could explore, the key element is to ensure that the acoustic bund would be able to perform effectively and therefore a condition is recommended to require the precise location, height, design specification to be submitted for approval and strategy for measuring the effectiveness of the performance of the barrier at night.

iii) The relationship between the noise attenuation bund and cycle/pedestrian link

8.50 The cycle/pedestrian link separates the boundary of residential development and the acoustic bund. The design detail of the link is important to ensure that it provides a safe and accessible link to the eastern boundary of the site. The landscape treatment of the bund and the protection of existing trees and hedgerow along the route have been raised by the landscape officer whilst the detailed treatment of the route has also been raised by WSCC Highways. In the event of approval it is recommended that a condition be attached to ensure that the precise alignment, surface treatment and lighting of the route be subject to approval to ensure a satisfactory relationship with existing landscape features and the bund.

d) Full permission for the development of Phase 1 of 291 dwellings, internal roads, garages, driveways, 672 parking spaces, pathways, sub-station, flood attenuation ponds and associated amenity space.

8.51 The policy framework for the detailed design principles for the development are set out in Policy WB4 as summarised in the Policy Analysis Schedule attached as Appendix 4 along with more specific advice of Development Principles as set out in Policy DC9 of the Horsham District Council General Development Control Policies (also summarised in Appendix 4).

8.52 A detailed description of the proposed layout and composition in terms of unit mix (including affordable housing), design, height , open space and connectivity to Bewbush is set out in the attached report dated 7th March to the Development Control Committee at Crawley Borough Council (Appendix 3 refers).

8.53 The design of the Phase 1 layout has been subject to discussion throughout the application process to ensure that that this first phase would secure the scheme quality required by the JAAP. The discussions have been informed by policy considerations both from this Council and from CBC. Although it has been acknowledged that specific advice on minimum residential space standards (which are adopted policy within Crawley) do not apply within Horsham, the applicant has sought to amend the scheme to bring the scheme closer to the CBC requirements.

8.54 Crawley Borough Council has raised the following concerns in respect of the development as set out in paragraphs 10.24 – 10.31 of the report attached as Appendix 3: APPENDIX A/ 1 - 27.

- the design approach adopted to the rear of the properties aligning the key frontage routes and the smaller side streets;

- the usability and accessibility of some of the car parking spaces (examples quoted plots 5 – 7; plots 28; plots 166 -171 and plot 197);

- the fitness for purpose of some of the rear garden areas (a number of plots are identified but it would be possible to improve the size of the gardens without affecting the mix, density and number of units);

- the little or lack of private amenity space provision for the flats (it would be possible to modify some of the incidental areas of open space with fencing to provide semi- private amenity areas for residents);

- the lack of natural surveillance where garden gates and rear garden boundaries would be hidden from view;

- the potential for rear alleyways which serve a number of properties to attract crime, anti social behaviour and dumping;

- the size of the affordable housing units and whether these would attract grant;

- the lower quality of architecture for the affordable housing units i.e. the scheme would not be tenure blind;

- the cramped layout of the affordable housing units with small garden sizes which will not meet the requirements of future occupiers;

- the layout of the units adjacent to the western boundary and the relationship to the woodland beyond creating problems in terms of the isolation of the flats over garages (FOGS); natural surveillance; the boundary treatment (concerns have been raised about the potential for crime and dumping which is a design point relating to the proximity of properties wooded boundaries which has also been raised by a resident of Kilnwood Lane);

- the details of the bus stop location to ensure that the stops would accessible and designed to meet the requirements of the bus operators;

- the design of the open space and exact layout of the space in terms of sports pitches etc.

8.55 The key issues identified by CBC largely reflect concerns expressed by officers at this Council and whilst space standards do not exist, the policy framework provided by policy DC9 provides a benchmark to assess the application along with the JAAP and government guidance including PPS 1 – Delivery Sustainable Development and Department for Transport Guidance Manual for Streets.

APPENDIX A/ 1 - 28.

8.56 Key principles within policy DC9 of the Horsham District Council General Development Control Policies relevant to the assessment of the Phase 1 layout are:

- the need to ensure a high standard of design and layout and where relevant relates sympathetically with the built surroundings, open spaces and routes within and adjoining the site;

- the need for development to relate sympathetically to the local landscape;

- the need to incorporate where appropriate, safe and visually attractive areas for the parking of vehicles and cycles, and the storage of bins/recycling facilities without dominating the development or its surroundings;

- the need to incorporate measures to reduce and actual or perceived opportunities for crime or antisocial behaviour on site and in the surrounding area; and create visually attractive frontages where adjoining streets and public spaces, including appropriate windows assist in the informal surveillance of public areas by occupants of the site.

8.57 The need to reconcile detailed design elements is recognised in Manual for Streets and PPS 1 which recognises the importance of securing well designed accessible car parking spaces and safe and accessible environments. Having regard to the comments received from Crawley and this Councils own policy guidance, along with government guidance, the key issues to resolve with the Phase 1 layout are:

- the isolated location of some of the FOG’s – plots 149; 191 and 194; - the outlook of the FOG’s onto car parking areas rather than an area of active space and character and the impact of this on the western boundary and the countryside beyond; - the lack of connectivity and isolation of the FOG’s to the wider community network which would be exacerbated by the gates to the courtyards. - the need to re-organise gates and alleyways to the rear of plots 132 -140; - the removal of car ports to plots 156-7 and 162-3; - the repositioning of the door to unit 67 and the addition of a porch; - the architectural detail of units 55-66 which is not tenure blind.

8.58 The key points identified above and by officers at Crawley Borough Council clearly relate to the policy set out in Policy DC9 and are matters which require further discussion. Whilst the revised drawings have been received, these do not as yet address the detailed design issues raised by officers at this Council and CBC and it is therefore recommended that a decision on this element of the scheme be deferred to officers at this Council in consultation with the Chairman, Vice Chairman, the Cabinet Member for Strategic Planning and the relevant Horsham Members of the Joint Member Steering Group for the site.

8.59 Some of the key issues arising from the Phase 1 layout relate to the relationship of the development to the boundaries of the site area. The issues with respect to the western boundary are identified above and landscaping condition would address issues on the eastern boundary. The issues relating to the southern edge of the APPENDIX A/ 1 - 29.

development and the level of acoustic protection provided by this have been addressed in paragraph 8.49 above where a condition is recommended. With respect the northern boundary of Phase 1, the key issue relates to relationship of the development to the proposed CHP plant. The design and specification of this building is not known at this stage and this could potentially impact upon the northern edge of the Phase 1 scheme and this may (subject to the impacts arising from the proposed plant) have implications for the final layout of the northern part of the scheme if environmental safeguards are required.

8.60 Whilst it is considered that the Phase 1 layout is capable of resolution, conditions would be required in the event of approval, which would include conditions to enable further consideration of the details of the landscaping scheme and the other elements as outlined in paragraph 8.5 xii above.

9.0 Third Party and Neighbour Consultations

9.1 The consultation summary in Appendix 2 highlights all the responses received in respect of the application. The summary indicates where no objections have been received or where conditions are recommended. Key consultees include the Environment Agency who, whilst raising no objection require a number of conditions to be attached in the event of approval in respect of the outline, along with Thames Water who require a ‘Grampian condition’ relating to any on and/or off site drainage works and Gatwick Airport and the Highways Agency as discussed in paragraph 8.26 above.

9.2 With respect to neighbour consultations, key issues relate to: pollution; land contamination; landscaping, ecology and archaeology; the design of the scheme and its compliance with the JAAP (including affordable housing); and highway infrastructure including road safety. All comments received are summarised in Appendix 2. It is considered that the consultation responses received and the Officer report addresses these issues.

10.0 Planning Obligations

10.1 The Planning Obligations be to secured in respect of the development are set out in paragraph 3.0 above with the principal heads summarised in the schedule attached as Appendix 5. The planning obligations would be secured pursuant to a Section 106 Agreements with Horsham District Council and West Sussex County Council.

APPENDIX A/ 1 - 30.

10.2 A key issue in the resolution of the planning obligation package for the development has been the affordable housing to be provided as set out in paragraphs 8.11 – 8.13 of this report. It is considered by both officers at HDC and CBC that subject to the applicant agreeing appropriate clauses for inclusion within the Section 106 Agreement that the proposed affordable housing can be recommended to the Committee as acceptable.

10.3 Initial discussion have taken place with the applicant in connection with planning obligations associated with the development, which the applicant is proposing to deliver through agreements with both WSCC and this Council. In the event of a resolution to grant planning permission for the development, it is recommended that joint working continues with CBC in respect of the content of the s106 agreement and that the details of the agreement be agreed with the Chairman, Vice Chairman and the Horsham Members of the Joint Member Steering Group.

11.0 RECOMMENDATIONS

1. Subject to the removal of the ‘holding direction’ from the Highways Agency that Planning Permission for a) b) and c) be granted subject to:

IV. the prior completion of a Legal Agreement with Horsham District Council within 6 months of the date of this Committee (pursuant to Section 106 of the Town and Country Planning Act 1990 as amended and all other relevant statutory powers, the content of the Legal Agreement being subject to continued joint working between officers at this Council and Crawley Borough in consultation with WSCC regarding Highway/Community/Education matters);

V. the content of the s106 agreement and that the details of the agreement be agreed with the Chairman, Vice Chairman and the Horsham Members of the Joint Member Steering Group;

VI. the prior completion of a Legal Agreement with WSCC within 6 months of the date of this Committee (pursuant to Section 106 of the Town and Country Planning Act 1990 as amended and all other statutory powers, the content of the Legal Agreement being subject to continued joint working between officers at this Council and Crawley Borough Council and ESCC regarding Highways/ Community/Education matters);

APPENDIX A/ 1 - 31.

Background Papers: DC/10/1612 Contact Officers: Hilary Coplestone/Emma Parkes