11 August 2020
Neighbourhood Planning Officer Horsham District Council Parkside Chart Way Charles Collins North Street E: CCollins@savills.com DL: +44 (0) 1483 796 837 Horsham RH12 1RL 244 - 246 High Street Guildford GU1 3JF T: +44 (0) 1483 796 800 F: +44 (0) 1483 796 801 savills.com
Dear Sirs
Billingshurst Neighbourhood Plan Regulation 16 Consultation Consultation Representation in relation to Land East of Billingshurst, Little Daux.
Introduction 1.1 This representation is submitted to the Horsham District Council (HDC), on behalf of Bellway Homes Ltd (“Bellway”) and Crest Strategic Projects (“Crest”), in relation to the Billingshurst Neighbourhood Plan Regulation 16 Consultation.
1.2 This representation specifically relates to the key aspects of the Billingshurst Neighbourhood Plan (BNP) that are relevant to the Land East of Billingshurst, Little Daux (the Site). It follows the representation made to the previous consultation on the Regulation 14 Draft BNP, and seeks to highlight any comments or concerns to help ensure full consideration and enable the basic conditions to be met.
1.3 Significantly, it is highlighted that the summary of representations to the Regulation 14 consultation, as contained in the Consultation Statement (February 2020), does not refer to our previous correspondence with Billingshurst Parish Council (BPC) or our submitted representations made on behalf of Bellway and Crest. Clarification is therefore sought as to the reason why this representation is not acknowledged and whether the details and comments raised were in fact taken into consideration in preparing the Regulation 16 BNP. For ease of reference, the Regulation 14 Representation, dated 25 September 2019, is appended to this letter (Appendix A).
1.4 The BNP is now at the final consultation stage before being taken to Examination. As such it is essential that the plan meets the Basic Conditions, as confirmed in paragraph 37 of the National Planning Policy Framework (NPPF). This states:
“Neighbourhood plans must meet certain ‘basic conditions’ and other legal requirements before they can come into force. These are tested through an independent examination before the neighbourhood plan may proceed to referendum.”
1.5 The Basic Conditions set out within the Planning Practice Guidance (PPG), the Localism Act (2011) and paragraph 8 of Schedule 4B of the Town and Country Planning Act 1990 (as amended), are as follows:
a) “having regard to national policies and advice contained in guidance issued by the Secretary of State, it is appropriate to make the order or neighbourhood plan;
b) the making of the order or neighbourhood plan contributes to the achievement of sustainable development;
Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East.
Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD
c) the making of the order or neighbourhood plan is in general conformity with the strategic policies contained in the development plan for the area of the authority (or any part of that area);
d) the making of the order or neighbourhood plan does not breach, and is otherwise compatible with, EU obligations;
e) prescribed conditions are met in relation to the order or plan and prescribed matters have been complied with in connection with the proposal for the order or neighbourhood plan;”
1.6 The NPPF also makes clear the importance of the hierarchy of Plans. For Horsham, the BNP must therefore be in general conformity with the adopted Local Plan – the Horsham District Planning Framework (HDPF). It is relevant that HDC is progressing the emerging Local Plan Review which will replace the HDPF in approximately 18-24 months. Therefore it is important to ensure that the emerging BNP will not conflict with the emerging Local Plan Review, if it is to avoid future conflict and the possibility of becoming quickly out of date.
1.7 In this regard, the NPPF paragraph 29 makes clear that Neighbourhood Plans must not undermine strategic policies. There is no expectation for any strategic decisions to be made by Neighbourhood Plans and as NPPF paragraph 69 highlights, Neighbourhood Plans which make allocations should consider opportunities for small and medium sized sites. In this case, the BNP does not allocate sites for development, instead focusing on the sites that have already gained planning permission since 2011 or been allocated by HDC in the HDPF.
1.8 For the avoidance of doubt, this representation makes reference to S106 contributions and Community Infrastructure Levy (CIL). However, as BPC will be aware, the Planning White Paper consultation (August 2020) proposes to replace these levies with a new post development tax (‘Infrastructure Levy’). Therefore, where this representation refers to S106 and/or CIL, this should also be interpreted to mean any alternative that may supersede them as a result of the White Paper recommendations.
The Site
2.1 The site is being actively promoted through Horsham’s Local Plan Review for a residential led development. It is identified by HDC as one of the strategic housing options that may come forward in the emerging Local Plan Review (part of Site SA118). It lies to the east of Billingshurst and is outside of, but immediately adjacent to, the existing settlement boundary.
2.2 The site has an area of circa 37 hectares and comprises a number of agricultural land parcels located to the north of the railway line, albeit land to the south of the railway line has also been promoted for a longer term strategic development on behalf of Bellway only.
2.3 The Rosier Business Park is adjacent to but outside of the site and forms an existing business centre. There are two listed buildings adjacent to the site, comprising the Grade II Listed farmhouse at Little Daux Farm (listing ID: 1354140) and the Grade II Listed Rosier Farmhouse (listing ID: 1027129). Approximately 3.2 hectares of the site is designated as a Site of Nature Conservation Importance (SNCI), this will be enhanced as part of the development proposals.
2.4 The site’s western boundary abuts the existing settlement and is demarcated by trees, and the rear gardens of properties fronting Broomfield Drive and Brookers Road. There is an existing access into the site from Brookers Road and a footpath link from Broomfield Drive. Further access points are provided off Coneyhurst Road (A272) to the east and off the A272 to the north. This currently serves Little Daux Farm.
Strategic Development Opportunity at Little Daux
2.5 Representations sent to HDC in March 2020 indicated that the site (north of the railway), known as Little Daux, has capacity for delivery of 650 homes, including 35% affordable housing provision (circa 228 affordable homes). In addition to much needed housing, the proposed development at Little Daux will also deliver:
2
A new community hub with the potential to offer a café, community hall, co-working space and an Ambulance Community Response Post;
Land for a new primary school at the heart of the development;
Dual-use playing fields as part of the primary school for use by the wider community;
An outdoor adult gym, park with a equipped play and recreation space, as well as links to a circular trim trail;
Enhancements to green infrastructure, including improvements to the SNCI on the site;
Additional Station Parking; and
Land for additional commercial floorspace at the southern gateway to the site.
2.6 In total, the site will deliver circa 18 hectares of green space, in addition to open space provision, ecological enhancements to Wilden’s Meadow SNCI and biodiversity net gains of 17.12% habitat units and 12.10% hedgerow units.
2.7 Notably, the development at Little Daux makes provision for all relevant infrastructure, including the provision of a new primary school, as part of the strategic allocation. As such, there is less uncertainty surrounding the delivery of this infrastructure in Billingshurst.
2.8 The site would be accessed from a new access onto the A272 to the east.
Representations to the Regulation 16 Neighbourhood Plan
3.1 The Regulation 16 BNP was published for consultation on 17 June 2020 and invites comments until 12 August 2020. Where relevant to the site, the following provides comments, concerns and areas of support for the Plan to help inform the final stages of the Neighbourhood Plan process.
Objectives
3.2 The BNP has not allocated sites for development. However, it remains prudent for the Parish to facilitate the development at Little Daux to safeguard the vitality of the village. Notwithstanding this, the benefits of the site should be highlighted, particularly in relation to the 6 identified objectives on page 9 of the BNP:
Objective 1: The site will deliver high quality, sustainable, new housing that reflects the existing village vernacular and respects the character of the wider locality.
Objective 2: The development will provide new infrastructure to support the community, including a new primary school, central hub, with provision for flexible office space for home working, and the potential for medical facilities on the site. This is in addition to the various area of public realm set out above all of which will be available for use by the existing and new community of Billingshurst.
Objectives 3: New connections will be provided to the railway station and towards the centre of the village, to ensure that the development provides a safe environment for all road users. The proposed scheme will emphasise the benefits of sustainable transport modes, providing legible and attractive pedestrian and cycling routes connecting the site with the village.
Objective 4: Crest and Bellway are committed to creating a sustainable extension to the village, ensuring that this development will complement, support and enhance the local economic activity in the Parish. Benefitting from to its proximity to the High Street, this development will reinforce the vitality of the existing
3
services and facilities in Billingshurst. Notwithstanding this, additional complementary employment or community facilities will be provided as set out in relation to Objective 2 above, benefiting the village overall.
Objective 5: Little Daux will incorporate appropriate mitigation to ensure that there is no increased risk of flooding in the area resulting from this scheme. In addition, biodiversity enhancement and net gain will also be delivered (exceeding the 10% recommendation of the NPPF As set out above). The development parcels proposed have been informed by the native hedgerows and trees on the site, which will be enhanced as part of the green infrastructure proposals. In addition, the development will provide new walking routes that connect to Wilden’s Meadow SCNI, promoting wildlife and access to nature. With provision of new employment space and public amenities on site, as well as greater access to the train station, residents and visitors will not need to use private vehicles to travel. These factors, in combination with Crest and Bellway’s commitment to the high standard of Building Regulations, will ensure that the development minimises and mitigates impact on climate change.
Objective 6: This development will be sensitively designed to reflect the location of Little Daux. The scheme will be landscape led in its overall layout and design, including extensive areas of public open space and new landscaping, to create a high quality environment throughout. This was demonstrated in the representations to HDC in March 2020, through the vision document and illustrative masterplan, both of which can be forwarded to BPC if requested and are provided at Appendix B to this representation along with the remainder of that representation (dated March 2020).
Key Issues
3.3 The BNP identifies a number of key issues for Billingshurst on page 10. In relation to these, the benefits of Little Daux should also be highlighted as follows:
Road Congestion: Little Daux will provide all necessary infrastructure to accommodate the development itself, and in particular with regards to traffic. This includes a new roundabout to access to the site from the A272, which will also offer the benefit of traffic control along this main road. Elsewhere around the general area, traffic modelling has and will be undertaken to ensure that any further improvements required to accommodate the development are delivered. This will ensure that the scheme has no greater impact on existing issues, and in the longer term, is capable of supporting road improvements that will be of benefit to the wider area more generally.
Car Parking: Parking will be provided at Little Daux for all proposed uses, ensuring that there is no greater pressure on the village arising from visitors, occupiers or employees at the site. In addition, land is proposed for an extension to the station car park. This will help to reduce the existing pressures in this location.
Retail Experience and High Street Improvements: Development at Little Daux will support the growth, vitality and viability of the High Street. It will improve the permeability of the village, with new connections between the station and village centre, and increasing footfall to local services to help support them in the long term. This is intended to help increase footfall and encourage other businesses into the High Street, improving its retail offer and the overall experience for the local and wider community.
Improved Public Transport: The Development at Little Daux provides an opportunity to help enhance the local public transport facilities in the area. In particular, the availability of land for a station car park extension is a key aspect of this, as it may help to make the facility more attractive to those living in the wider area or far side of the village who cannot walk to the station. Equally, the greater population in the village resulting from the development will also increase pressure for improved and more regular services from the public transport service providers operating in this area.
Education and Medical Facilities: A new primary school is being provided at Little Daux. It will serve the existing community and proposed development. Where required, contributions would be made for improvements to the existing medical facilities in the village and there is an opportunity to provide an Ambulance Community Response Post within the site, enabling faster access to emergency care. However, whilst the need for access to high quality primary care is understood, it is acknowledged that the
4
ratio of patients to doctors in Billingshurst is lower than the District and national average so advice would be taken from HDC on this matter.
Maintaining a ‘Village Feel’: The masterplan that has been prepared for Little Daux specifically seeks to ensure that the development integrates and contributes to the quality and character of Billingshurst. It will be a spacious, landscape led development, which aims to add positively to the existing village feel.
Workspace Provision: In addition to providing a community hub with local facilities such as a new community hall, café and meeting space, all of which could be used by local business persons working from home, the site will also deliver an area of commercial space adjacent to the main site entrance. This offers village residents an opportunity for access to further local employment space potentially for smaller businesses, start-ups and training. This will complement existing services and encourage new businesses to trade in the area. Equally, this provision will reduce the need for travel to places of work, helping to improve the long term sustainability of the village and helping to increase the footfall and patronage to local shops, services and public transport.
Housing Needs: In terms of providing a range of homes to address specific needs, Little Daux has the ability to provide a range of Starter Homes, Family Homes and Life-Cycle Homes to cater for various needs in Billingshurst.
Aim 1: Prepare for early review of the BNP
3.4 Object: As previously noted, the BNP is based on the HDPF which was adopted in 2015 and will become out of date in December 2020. As such, the BNP acts as an interim policy document to guide development in the Parish up until the adoption of the emerging Local Plan Review. Whilst the intent of this aim is supported, the commitment to an early review of the BNP should be elevated to the first strategic policy within the BNP. This would underline the importance of a review in the immediate future to account for changes in local and national policy.
3.5 As a result of Covid-19, HDC has also outlined that it has had to undertake a review of the Local Development Scheme, and the timetable for progress of the Local Plan Review. As a result, HDC currently anticipates that the Regulation 19 Consultation on the Local Plan Review will not take place until early 2021 (originally intended for September / October 2020).
Aim 2: Work with key stakeholders to deliver improved health and education facilities
3.6 Support: As noted in the response to objective 2 and paragraph 3.3, the development at Little Daux will help to achieve this aim through the provision of a new primary school and the potential for Ambulance Community Response Post on the site. Crest and Bellway are committed to delivering educational facilities as part of the development and have spoken with HDC and West Sussex County Council (WSCC) to achieve this.
Aim 4: Footpath and Cycle Route Infrastructure
3.7 Support: Bellway and Crest share BPC’s ambitions for attractive and usable footpaths and cycle route infrastructure in the Parish. As a sustainable urban extension, Little Daux will be able to provide clear and legible routes through the site, to provide sustainable transport options throughout Billingshurst to connect existing and proposed services and facilities in the village.
Spatial Strategy and policy BILL1: Billingshurst Built-Up Area Boundary
3.8 Object: This representation principally objects to the built up area boundary (BUAB) set out in BNP Policy BILL1. As the BNP has not allocated sites for development, the settlement boundary for the Parish should be left for HDC to determine. This is linked to the comments above in relation to Aim 1.
3.9 In this regard, Policy 15 of the HDPF identified that Neighbourhood Plans should bring forward 1,500 homes. BPC has made a decision not to allocate any sites (small or large) for housing development. Therefore it is not necessary for the BNP to definite a BUAB as this is already covered by the HDPF. Furthermore, as BPC is
5
aware, the HDPF is presently being reviewed through the Local Plan Review Process, and this will make any further allocations for housing in the village and wider Parish, also outlining any proposed amendments to the settlement boundary to align with this.
Policy BILL2: Housing Design and Character
3.10 Comments: Earlier representations raised an objection to this policy, on the basis that part A was unclear with regards to requirements for good design. The policy now included a list of expectations for good quality design. Whilst this is clearer, there are some concepts that may be difficult to implement together. Before progressing to examination, it is necessary to ensure that the BNP includes sufficient flexibility to allow a development to have its own identity whilst also respecting the qualities of the area.
3.11 It remains the case that there is some overlap between Policy BILL2 and Policy 33 of the HDPF and arguably some conflict arises between competing interests of delivering a locally distinctive development (Policy 33) and delivering specific features in a scheme that may not reflect existing character. Overall it remains important for the policy to convey the importance of high quality design, ensured by evolution of proposals and supported by design strategies secured at the planning application stage. These requirements in BILL2 are capable of being secured in this manner as applicable to individual sites.
Policy BILL3: Energy Efficiency and Design
3.12 Support: The attached representations submitted to HDC’s Regulation 18 Local Plan Review in March 2020 (Appendix B) attest to Bellway and Crest’s commitment to the development of a high-quality and sustainable new development. The scheme is intended to meet and exceed the sustainable design interventions outlined in the emerging BNP.
3.13 Little Daux benefits from a genuine choice of transport modes, providing opportunities for electric vehicle charging points, car clubs, ready access to an established train station and the prioritisation of pedestrian and cycling routes across the site. In addition, the new dwellings will be constructed in accordance with the necessary energy efficiency requirements to mitigate against climate change.
3.14 To facilitate this, Bellway and Crest are open to positive engagement with BPC to promote sustainable development at Little Daux wherever it is viable to do so.
Policy BILL 4: Provision of Leisure and Recreation Facilities
3.15 Support: Little Daux covers circa 37 hectares; a large proportion of which will be dedicated to open space and infrastructure, including extensive amenity and open space, a potential trim trail, wildlife corridors, ecological enhancements, play areas and SUDs. In addition the proposals include dual use playing fields for the new primary school that would be available for community use. This commitment to green space and recreational facilities within the development demonstrates the site’s compliance with Policy BILL 4 and its compatibility with the wider objectives of the BNP.
Policy BILL 6: Integrated Infrastructure
3.16 Support: The text associated with this policy refers to education and health improvements. As set out above, Little Daux will be providing a new primary school and this provision will support the objectives of this policy. As applicable, S106 contributions or CIL will be provided that can also support improvements to primary care in the village where this is required by the CCG and local primary care providers.
Policy BILL 7: Retaining and Enhancing the Vitality and Viability of Billingshurst Village Centre
3.17 Comments: Whilst this emerging policy predominantly relates to development in the village centre, the sentiment is pertinent, specifically its ambitions to support the vitality and viability of town centres. The proposed development at Little Daux will promote the economic viability and vitality of Billingshurst village centre by providing new homes with direct links to the High Street. This will provide additional patronage and increase footfall along the High Street to encourage vitality in this area.
6
Policy BILL 10: Flexible Workspaces
3.18 Comments: The general aims of this policy are supported, as Little Daux has the potential to deliver some flexible workspace. However, the policy limits development to existing buildings and areas within the BUAB. The limited space within the settlement for development is evident, and there is a potential conflict with the HDPF. This is particularly the case in the High Street where HDPF Policy 12 identifies that there is a balance to be made between maintaining a diverse range and choice of suitable uses which would include retail and other businesses, whilst ensuring that in these locations there remains a convenient, cohesive and concentrated primary area with a high proportion of retail (A1) uses and proposed Class E uses. Therefore whilst BILL 10 refers to Policy 9 of the HDPF, it should also refer to Policy 12, which is clearly applicable to central areas including the High Street. BILL 10, or its preamble should be re-worded to ensure that the HDPF is appropriately reflected, that is assuming that BNP is progressed now rather than waiting to align with the emerging Local Plan Review.
Policy BILL12: Protection and Enhancement of key movement routes
3.19 Support: Little Daux will enable the retention and enhancement of key public rights of way, ensuring additional north-south and east-west corridors, including to key locations such as the station and village centre. Future residents at Little Daux will benefit from a comprehensive and legible development that actively encourages increased footfall in Billingshurst.
3.20 Bellway and Crest have committed to providing direct access at the north of the development to Amblehurst Green to facilitate movement between the two developments and the village. In addition, the proposals at Little Daux will provide vehicular access to the A272, and cycling and pedestrian routes throughout the site, improving permeability and encouraging thoroughfare throughout.
Policy BILL13: Public Car parking
3.21 Support: This policy seeks to encourage new and retained parking areas in the village, including at the station. Although the policy wording need not be changed, it is highlighted that Little Daux will provide an opportunity for an additional station car park, with land being set aside specifically for this purpose in the illustrative masterplan. This proposal fulfils the non-policy action identified on page 73 of the BNP.
Policy BILL14: Residential Parking Provision
3.22 Objects: Policy BILL 14 should be informed by the latest evidence provided in the Horsham Local Plan Review and the parking standards set out by the West Sussex County Council (WSCC).
3.23 HDC has adopted the WSCC parking standards and hence this should be explicitly stated that developments should accord with these countywide parking standards. It is essential to ensure that requirements for on-site parking provision does not conflict with that guidance.
Policy BILL15: Local Green Spaces
3.24 Comments: The BNP does not allocate Local Green Space on the site. This will be considered in the design evolution of Little Daux and will account for the emerging policies set out in BNP and Horsham’s Local Plan Review.
Policy BILL16: Multi-Value Sustainable Drainage Systems
3.25 Comments: Little Daux will incorporate SUDs which have been designed into the scheme from the outset and with input from both an Ecological and Drainage consultant. A significant proportion of the site is in flood zone 1 and so has the lowest risk of flooding. The current strategy limits peak flows from the development to existing greenfield rates and provides long term storage, ultimately resulting in no negative offsite impacts.
3.26 Whilst there are no objections to this policy, the wording of Part C should make an allowance for the fact that long term maintenance strategies are often not provided at the planning application stage but are secured either
7
by way of a planning condition or through a S106 obligation. This is because the degree of detail stated in the BNP is not often known at the application stage and, in instances where it is, it can change before a development is occupied. This degree of flexibility is essential to ensuring that development is not unduly restricted and can come forward quickly and efficiently in any given location.
Policy BILL17: Views to St Mary’s Church
3.27 Comments: Bellway and Crest support the emphasis made in the BNP to uphold the integrity of St Mary’s Church in the village. A full heritage assessment will be undertaken to inform the design evolution of Little Daux. This will be provided as part of any future planning application and ensure that the requirements of this policy are met.
Supporting Documents
Density Topic Paper
3.28 Comments: It is assumed that the Density Topic Paper is relevant to development within the existing built environment and will not be applied to urban extensions. In accordance with local and national policy, the density of all new development in the District should be designed in response to the emerging policies of the Local Plan Review and guidance within the Planning White Paper (August 2020) and National Design Guidance.
Housing Need Paper
3.29 Comments: The Housing Need Paper was drafted in April 2018 to identify the types of housing required by the existing and future populations in Billingshurst. This paper is based on policies in the adopted HDPF and does not consider the latest evidence which is informing HDC’s Local Plan Review. This paper has recommended that BPC defer to the policies set out in the HDPF to inform housing mix and is, therefore, arguably not up to date.
3.30 In this regard, HDC is developing District Wide evidence base with Crawley Borough Council and Mid Sussex District Council which will account for the density, mix and tenure of housing to ensure needs are appropriately met. The primary driver for housing need will therefore be governed by the new Planning White Paper and revisions to the Standardised Methodology for Calculating Housing Need.
Summary
4.1 Little Daux is the most sustainable greenfield site in the District. This proposal represents the most logical extension for the village, enabling comprehensive plan-led development which can provide real and positive benefits for the village in the short and long term. The site is therefore being promoted to HDC as a strategic housing led development opportunity, which incorporates a range of other facilities including a primary school, community spaces, employment and a car park extension for the village train station.
4.2 Whilst the BNP could allocated sites for development, it is clear that the aspiration remains to support HDC in allocation through the Local Plan Review. It remains that there are no objections to this approach but it is felt that this should be appropriately reflected in the BNP with the removal of the settlement boundary policy (BILL 1). This would also avoid the need for later amendments to the BNP to ensure that it is capable of aligning with the emerging Local Plan Review.
4.3 This is pertinent to the other emerging policies within the BNP as the adopted Development Plan in Horsham will become out of date at the end of 2020. The adoption of the policies within the BNP is therefore only currently capable of serving as an interim measure to cover and address development in the Parish between the end of
8
this year and adoption of the Local Plan Review. At this point, the BNP will require further updates and reviews if it is to form a functional part of the Development Plan.
4.4 It is hoped that this representation helps to further inform the final stages of the BNP process, prior to Examination commencing. If taken on board, these comments will help to ensure that the BNP can pass Examination and proceed to Referendum. We also want it acknowledged that we submitted duly made representations at the Regulation 14 stage (Appendix A), and for these to be referred to in the Evidence Base.
4.5 Should you have any queries in relation to the details of my letter, please do let me know.
Yours Faithfully,
Charles Collins
Director
Encl:
Appendix A - Regulation 14 Representation (September 2019)
Appendix B – Representations to HDC’s Local Plan Review (March 2020)
9 Representation Form
Billingshurst Neighbourhood Plan 2019-2031
The Neighbourhood Planning (General) Regulations 2012 (as amended) - Regulation 16
Billingshurst Neighbourhood Development Plan
In light of recent announcements regarding COVID-19, Horsham District Council to reviewed its protocols regarding the consultation process for neighbourhood plans, a number of which were published for public consultation shortly before the government imposed the nationwide lockdown.
In order to continue to progress neighbourhood plans, we have made a decision to continue with the consultation process with measures we feel are in accordance to the government guidelines.
Billingshurst Parish Council has prepared a Neighbourhood Development Plan (BNP). The Plan sets out a vision for the future of the parish and planning policies which will be used to determine planning applications locally. In accordance with Regulation 16 of the Neighbourhood Planning Regulations 2012 (as amended), the BNP and associated documents will go out to consultation:
Wednesday 17 June to Wednesday 12 August 2020 for 8 weeks inviting representations on the draft submission plan, basic conditions statement, consultation statement and the Strategic Environmental Assessment (SEA) screening opinion. Supporting Background Papers are for information purposes only.
Copies of the BNP Neighbourhood Plan and supporting documents are available to view on the Horsham District Council’s website: https://www.horsham.gov.uk/planningpolicy/planning-policy/currentconsultations
Documents will not be made available in deposit locations due to the current COVID-19 pandemic. If local residents have difficulty in engaging online we have provided a telephone number and email address below. Members of the public are encouraged to leave their details for an officer to contact them back if they need further information.
Email: [email protected] – [email protected]
Telephone: 01403 215398
All comments must be received by Midnight on Wednesday 12 August 2020
There are a number of ways to make your comments:
1. Please use the above web address above to make your representation online ; or
2. Complete this form and email it to: [email protected] ; or
3. Print this form and post it to: Neighbourhood Planning Officer, Horsham Council, Parkside, Chart Way, North Street, Horsham, RH12 1RL
All comments will be publicly available, and identifiable by name and (where applicable) organisation. Please note that any other personal information provided will be processed by Horsham District Council in line the Data Protection Act 1998 and General Data Protection Regulations. Horsham District Council will process your details in relation to this preparation of this document only. For further information please see the Council’s privacy policy: https://www.horsham.gov.uk/privacy-policy
How to use this form
Please complete Part A in full, in order for your representation to be taken into account at the Neighbourhood Plan examination.
Please complete Part B overleaf, identifying which paragraph your comment relates to by completing the appropriate box.
PART A Your Details Full Name Charlie Collins (on behalf of Bellway Homes and Crest Strategic Projects) Address Savills, 244 - 246 High Street , Guildford Postcode GU1 3JF Telephone +44 (0) 1483 796 837 / +44 (0) 7870 999 596 Email [email protected] Organisation (if applicable) Savills Position (if applicable) Director Date 11/08/2020
PART B
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: AIM 1
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object
Comment x
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: AIM 2
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support x
Support with Modifications
Object
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: AIM 3
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support x
Support with Modifications
Object
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL1
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object x
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL2
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object
Comment x
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL3
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support x
Support with Modifications
Object
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL4
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support x
Support with Modifications
Object
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL5
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support x
Support with Modifications
Object
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: Policy BILL6
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support x
Support with Modifications
Object
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL7
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object
Comment x
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL10
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object
Comment x
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL12
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support x
Support with Modifications
Object
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL13
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support x
Support with Modifications
Object
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL14
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object x
Comment
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL15
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object
Comment x
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL16
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object
Comment x
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Paragraph Number: Policy Reference: POLICY BILL17
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object
Comment x
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
To which part in the plan does your representation relate?
Density Topic Paper
Do you support, oppose, or wish to comment on this plan? (Please tick one answer)
Support
Support with Modifications
Object
Comment x
Please give details of your reasons for support/opposition, or make other comments here:
Please refer to appended representation letter.
What improvements or modifications would you suggest?
Please refer to appended representation letter.
Please make sure any additional pages are clearly labelled/ addressed or attached.
Do you wish to be notified of the local planning authority’s decision under Regulation 19 of the Neighbourhood Plan (General) Regulations 2012 in relation to the Billingshurst Neighbourhood Development plan?
Please tick here if you wish to be to be notified: x
25 September 2019
Charles Collins E: [email protected] DL: +44 (0) 1483 796 837
244 - 246 Billingshurst Parish Council High Street Guildford GU1 3JF Billingshurst Centre T: +44 (0) 1483 796 800 Roman Way F: +44 (0) 1483 796 801 Billingshurst savills.com West Sussex RH14 9QW
Dear Sirs
Billingshurst Neighbourhood Plan Regulation 14 Consultation – Consultation Representation in relation to Land East of Billingshurst, Little Daux.
Introduction
1.1 This representation is submitted to the Billingshurst Neighbourhood Plan Regulation 14 Consultation, on behalf of Crest Strategic Projects (“Crest”) and Bellway Homes Ltd. (“Bellway”). This representation specifically relates to the key aspects of the Neighbourhood Plan that are relevant to the Land East of Billingshurst, Little Daux (“the site”).
1.2 It is understood that prior to 31 May 2019, the Billingshurst Neighbourhood Plan Working Group (BNPWG) resolved to advance their Neighbourhood Plan without allocating sites. In lieu of this, the Parish has committed to working with Horsham District Council (HDC) throughout their Local Plan Review to allocate sites within the Neighbourhood Plan Area.
1.3 The site is being actively promoted through Horsham’s Local Plan Review for the development of circa 700- 800 homes; 1.1Ha of employment space; provision of children’s play spaces; the protection and enhancement of Wilden’s Meadow SCNI; and, improved permeability across the site, with potential for improved wayfinding throughout Billingshurst.
1.4 This proposal provides an exciting opportunity to promote plan-led development in Billingshurst and secure wider community benefits through open and proactive discussions with Billingshurst Parish Council and the local community.
Billingshurst
2.1 Since the mid-1990s, the Village has witnessed substantial growth, including the expansion of the local road network and the provision of additional amenities. This is largely due to Billingshurst’s attractive location combining rural living with commutable links to Horsham and London.
2.2 As a result of the increasing pressure on Local Planning Authorities to deliver housing, growth in Billingshurst is projected to increase as it establishes itself as one of the most sustainable settlements in the District. This emphasises the need for plan-led development, to maintain Billingshurst’s village character, feel and aesthetics.
Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East..
Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD
The Site
3.1 The site lies to the east of Billingshurst and is outside of the existing settlement boundary. It has a collective area of 40.14 hectares and comprises a number of agricultural land parcels in addition to the Rosier Business Park which is an existing, unallocated employment site.
3.2 Elsewhere within the site there are also two listed buildings, comprising the Grade II Listed farmhouse at Little Daux Farm (listing ID: 1354140) and the Grade II Listed Rosier Farmhouse (listing ID: 1027129). There is also a small area of woodland and some ponds.
3.3 The site’s western boundary abuts the existing settlement boundary and is demarcated by tree planting and the rear gardens of properties fronting Broomfield Drive and Brookers Road. There is an existing access into the site from Brookers Road. The Principal access point into the site is off Coneyhurst Road (A272) to the east.
3.4 A site plan showing land ownership is attached in Appendix A.
Background
3.5 In the 2016 Strategic Housing and Economic Land Availability Assessment (SHELAA) the site was identified as SA049 and SA569; albeit it was also assessed by HDC as part of a wider site – SA118. This area as a whole was considered as a potential strategic option for 1,750 dwellings (north and south of A272, including land south of the railway).
3.6 Following the grant of planning applications north of Billingshurst, within the SA118 site allocation, HDC sought to expand the settlement boundary to include the new developments. The SHELAA 2016 recognised that up to 1,200 dwellings could be provided across the remaining potential allocation (all south of the A272 and hence north and south of the railway) and concluded that SA118 is a suitable, available and viable development option. It should be noted that SA118 did not simply apply to the Site (SA049 and SA569) but also included other land parcels, namely SA028, SA116, and SA637. This letter provides a representation related to the promotion of Little Daux.
Strategic Development Opportunity at Little Daux
3.7 The site has capacity for circa 700-800 homes. The main residential areas are to be formed in small parcels, each defined by retained and enhanced landscape features. This strategy responds to Crest and Bellway’s aspiration to put sustainability and good place making at the heart of the proposals. Little Daux provides the opportunity for a cohesive and comprehensive development focused on high-quality housing in Billingshurst.
3.8 The site will deliver circa. 1.1Ha of employment space concentrated towards the proposed entrance north of the railway to complement the mix of employment uses at Rosier Business Park. It is currently anticipated that this could be in the form of B1 or A1-A5 use classes, the final land use for this employment area will be confirmed as the scheme is progressed. The delivery of the site will also accelerate the delivery of the second primary school for the village. Further employment will be considered where appropriate.
3.9 Primary access to the site will be provided directly off of the A272, with further accesses from Broomfield Drive and T-Junction at the north of the site. The development seeks to emphasise opportunities for sustainable travel. Aided by its proximity to the train station, the site will promote active transport through the provision of attractive cycle lanes and streets. The development will be designed to promote high levels of sustainable transport modes, reducing reliance on private cars wherever possible.
3.10 In addition, the masterplan utilises the existing landscape features to provide attractive formal and informal open space, including: children’s play areas; trim trails; nature corridors and a sports pitch. Moreover, the proposed ecological enhancements at Wilden’s Meadow SCNI, demonstrates the site’s commitment to creating a sense of place, simpatico with the wider village environment.
2
Draft Neighbourhood Plan
4.1 The Draft Neighbourhood Plan for Billingshurst was published for Regulation 14 consultation on 1 August 2019. The consultation invites comments from interested parties until 29 September 2019.
4.2 The Parish covers 32.19km², comprising Billingshurst, Adversane, Coneyhurst and Five Oaks. The Parish became designated as a Neighbourhood Plan Area in December 2015 and the BNPWG has been responsible for the production of the Plan since.
4.3 Through a series of public consultations, the BNPWG identified 11 issues presently facing the Parish, notably: road congestion; insufficient levels of car parking; need to improve the high street; infrequent bus and train services; limited educational facilities; threats to natural and historic environment; demand for employment space; need for continued provision of small, affordable, starter homes; and the need for housing provisions for aging population.
4.4 Rapid expansion in the Village since the 1990s has substantially increased the population of Billingshurst. Whilst the approved development at Amblehurst Green will deliver an additional 475 homes, extend the medical centre and provide land for a new primary school, there are concerns that there is still not the necessary quantum of development in Billingshurst to demonstrate the viability of a new primary school in this area; let alone provide the necessary infrastructural improvements or payments to address other concerns in the Village. Further development is therefore required to ensure that Billingshurst is adequately resourced to enable the delivery of the primary school and provide funding for other infrastructural projects in the area.
4.5 As previously mentioned, Billingshurst Neighbourhood Plan has not allocated sites for development. However, we consider it prudent for the Parish to facilitate the development at Little Daux to safeguard the vitality of the Village. Albeit, through vocal or written support for the development and expanding the settlement boundary to include the site rather than specifically allocating the site in the emerging Neighbourhood Plan. Due to the size of the site, this should be left for HDC through the Local Plan process.
4.6 Notwithstanding this, the benefits of the site should be highlighted, particularly in relation to the 6 identified objectives as set out on page 6 of the Draft Neighbourhood Plan.
Objective 1: The site is capable of delivering high quality new housing that reflects the existing village vernacular and respecting the character of the wider locality. Objective 2: The development of the site would provide the additional demand to support the opening of a new primary school in the village. The development can also assist with the funding of this school as will be discussed and agreed with both HDC and WSCC as the site is progressed. Objectives 3 and 4: New connections can be provided to the railway station and towards the centre of the village. Not only will this benefit future occupiers, but it may also provide improved connections for existing residents that will further support the growth and viability of the village centre. Furthermore additional complementary employment or community facilities will be provided on this site, serving the existing and future residents of the village and to improve its overall sustainability and attractiveness. Objective 5: Appropriate flood mitigation will be provided at this site. Biodiversity enhancement and net gains will also be delivered, in addition to walking routes that connect Wilden’s Meadow SCNI, promoting wildlife and access to nature through this development. Finally in respect of Objective 6, the development of this site will be sensitively designed to reflect the location of the site adjacent to the open countryside, and adjacent to heritage assets. The scheme will be landscape led in its overall layout and design, including extensive areas of public open space and new landscaping that creates a very high quality natural and built environment throughout.
4.7 Equally within the plan are a number of key aims for the village. The development proposal will certainly provide some added value in respect of a number of those aims, most notably:
3
Aim 2: Work with key stakeholders to deliver improved health and education facilities
4.8 There are two key points to note here. firstly, the delivery of the site as a strategic development will result in Section 106 contributions or CIL. Funding from either of these sources will be able to assist in delivery of the primary school on land to the north, which was consented as part of the earlier consortium strategic development.
4.9 With regards to health facilities, it is currently understood that the ratio of patients to doctors in Billingshurst is lower than the district and national average. However, the need for high quality and accessible health care is fully understood. A financial contribution would therefore be considered towards health facilities in the village which can assist in providing greater levels of service to the community to meet aim 2.
Aim 4: Identify buildings suitable for co-working/start-up space
4.10 Whilst this aim specifically relates to the use and reuse of existing buildings within the village, the strategic development at Little Daux does provide the opportunity for new business and start up space. The intention is to provide an area for new employment which correlates with the existing development at the Rosier Business Park, and this may offer space for small businesses, in addition to local training opportunities.
4.11 Whilst this may not directly result in an outcome that the aim is seeking to achieve, it will provide high quality employment benefits to the village, which will complement existing services and encourage new business and trade into the area. This will assist in making the village more sustainable, more accessible, and ultimately reduce the need for long distance traveling to places of work. Furthermore, the strategic development of this site will assist in increasing the patronage of local services, public transport and increase consumer spend which will encourage and support the use of existing buildings in the village centre for start-up business space as new businesses become more viable in this location.
Aim 5: Footpath and cycle route infrastructure
4.12 New cycle and footway connections will be provided throughout the site. these routes will not only serve the new community but also provide improved links and connectivity for the existing population. These connections will not only link to existing facilities and routes, but will provide new links to open space, play space and amenity walks that will assist in promoting the health and wellbeing of the wider community.
4.13 Paragraph 10.3 of the draft Neighbourhood Plan notes that with a ‘made’ Neighbourhood Plan, the Parish will receive an uplift in the amount of funding received from Community Infrastructure Levy (CIL). At present, the Parish receive a capped share of 15% of the CIL received, this will increase to an uncapped share of 25% of CIL receipts from development in Billingshurst.
Community Infrastructure Levy (CIL)
4.14 From our initial calculations, we have estimated that the District would receive a total of circa. £6.14m - £7.02m from development in Little Daux (arising from the residential provision). Pertinently, this income can be used to achieve some of the aims set out in the Neighbourhood Plan. This estimate is based on the April 2017 CIL Charging Schedule, and is un-indexed (in reality four years of indexation would be applied, assuming and estimated site delivery from April 2021). It is based on the application of 35% affordable housing and an average dwelling size of 100 sq m. On the making of the BNP, the Parish can claim 25% of the CIL receipts. In addition, the development will provide reasonable and necessary Section 106 Obligations and Contributions.
4.15 With regards to specific policies, we set out below our comments that may be of assistance in the progression of the draft plan.
Policy BILL1: Billingshurst Built-Up Area Boundary
4
4.16 Comment: At this time, given the intention of the Neighbourhood Plan not to allocate any new development sites, and leave this for HDC, it is considered that the proposed settlement boundary plan is sufficient to reflect the Plan’s aspirations. We would not therefore comment any further at this time. However, if this site is allocated through the Local Plan process, we would urge the BNPWG to update the site boundary plan to respond to this. In this regard it is acknowledged that the Neighbourhood Plan is clear that an early review will be undertaken once the Local Plan Review has been completed by HDC (page 15). Further comments may therefore be provided at the relevant future stage. Alternatively, the BNPWG might decide to link the NP production timeframes with the Local Plan Review.
Policy BILL2: Housing Design and Character
4.17 Object: Understandably, the Neighbourhood Plan demonstrates the need for well-designed, user-friendly and resilient developments in Billingshurst. Whilst no specific design proposals have been progressed for Little Daux yet, Crest and Bellway have every intention of ensuring that this policy requirement is met as part of the development of the site. However, to ensure that there is no conflict with the HDPF or any subsequent policy on design, we would suggest some amendments to the wording of the policy as follows:
4.18 Policy BILL2, part A - The wording of this paragraph is not overly clear and currently implies that there is a list of requirements that need to be complied with, whereas the actual policy only includes 1 requirement. It also appears that parts A and B are duplicated, although this may be as a result of the wording used rather than the intent of the policy itself.
4.19 In addition, there is significant overlap with Policy BILL2 and Policy 33 of the HDPF, the Parish should seek to remove any onerous or repetitive policy wording. We would recommend that this is reviewed and clarified before the next stage of consultation.
4.20 It is important that the policy conveys the importance of quality design, ensured via appropriate analysis and design evolution of development proposals, in character, as supported by relevant Design Frameworks or Codes, secured through the grant of planning permission.
Policy BILL4: Provision of Leisure and Recreation Facilities
4.21 Support: Little Daux covers 40.14Ha, of which approximately 20.26Ha will be dedicated to Strategic Open Space and Infrastructure, including amenity space; wildlife corridors; sports pitch; ecological enhancements; open spaces; play areas and SuDs. The proposals are still evolving and may be able to accommodate the provision of a multi-use games area or alternative leisure facilities following discussions with the Parish Council.
4.22 The commitment for circa. 50% of the land use budget to open space and infrastructure demonstrates the site’s compliance with Policy BILL4 and its compatibility with the wider objectives as set out in the Neighbourhood Plan. The proposal would therefore act to support the objectives of this policy.
Policy BILL10: Protection and enhancement of key movement routes
4.23 Support: As outlined, the delivery of the site will enable the retention and positive enhancement of key public rights of way, ensuring additional north / south and east/ west movement, including to key village locations such as the station, The Weald and village centre. There is an opportunity to consider further deliverable enhancements to off-site linkages in selected locations in the village.
Policy BILL11: Public Car parking
4.24 Support: This policy seeks to encourage new and retained parking areas in the village, including at the station. Whilst this would not require a change in the policy, it is highlighted that there are opportunities for the delivery of an additional station car park at this site. Crest and Bellway would be pleased to discuss the opportunity with the BNPWG should this be considered necessary.
5
Policy BILL14: Multi-Value Sustainable Drainage Systems
4.25 Comment: As mentioned, the land-use budget for the site commits approximately 50% of the site to open space and infrastructure, including the use of SUDS. A significant proportion of the site is in Flood Risk Zone 1 (lowest risk of flooding); the current drainage strategy limits peak proposed flows to the existing greenfield rates and provides long term storage, ultimately resulting in no negative offsite impacts from development. The proposal will enable a site sufficient drainage system, which will be based on ensuring no adverse impacts off- site and ensuring a 40% allowance for climate change. In this regard, we have no objection to the proposed policy.
Summary
5.1 The Land East of Billingshurst, Little Daux, is the most sustainable greenfield site in Horsham District. The proposal represents the most logical extension for the Village, enabling cohesive and comprehensive plan-led development which reinforces the nucleated settlement pattern in the District. It is therefore being promoted to HDC as a strategic development opportunity for circa 700-800 homes, with 1.1 Ha of much-needed employment space, the enabling of a second primary school for the village and extensive open space representing 48% of the whole site.
5.2 Whilst the Neighbourhood Plan could allocated sites for development, it is clear that the aspiration is to support allocations in this area made by HDC through the emerging Local Plan Review. We do not object to this approach and have therefore made relevant comments on the draft policies to help inform the process and highlight where this development is able to help meet the needs and aims identified by the Neighbourhood Plan Working Group.
5.3 The Neighbourhood Plan has the potential to act to support and compliment the Local Plan Review, and need not make unnecessary allocations over and above those being proposed by HDC.
5.4 We do hope that the comments provided are of some assistance to you and we would be pleased to meet with you and discuss these matters in more detail. Otherwise do let me know if you have any queries on the comments provided.
Yours Faithfully,
Charles Collins Director
6 LITTLE DAUX, EAST BILLINGSHURST LANDSCAPE AND VISUAL REPRESENATION TO HORSHAM DISTRICT COUNCIL LOCAL PLAN REVIEW (A3 DOUBLESIDED) MARCH 2020
ISSUE SHEET
JOB NAME: LAND EAST OF BILLINGSHURST, WEST SUSSEX JOB NUMBER: D2720 CLIENT: BELLWAY AND CREST NICHOLSON
REVISION DATE REVISION DETAILS PREPARED BY CHECKED BY APPROVED BY DRAFT 25.03.2020 FOR INTERNAL REVIEW LS LS AS DRAFT 26.03.2020 FOR CLIENT TEAM REVIEW LS LS LS FINAL 30.03.2020 CLIENT AND TEAM COMMENTS ADDRESSED LS LS LS
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 3 4 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS CONTENTS
1.0 Introduction 7 1.1 Introduction 7 1.2 Desktop research and field work 7
2.0 Landscape and Visual Critique of Proposed Local Plan 2019-2036 Allocations Around Billingshurst 8 2.1 Introduction and landscape planning context 8 2.2 Site suitability and red / amber / green (RAG) rating 8 2.3 Landscape setting to Billingshurst 8 2.4 Land east of Billingshurst (Little Daux) 10 2.5 Land west of Billingshurst (Newbridge Park) 14 2.6 Landscape setting to Adversane 18 2.7 Land at Adversane (Kingswood) 18
3.0 Landscape and Visual Critique of New Local Plan Evidence Base 22 3.1 Landscape Capacity Study, Rev B February 2020 22
4.0 Review of Proposed Policies 24 4.1 Introduction 24 4.2 Strategic Policy SP27 - Natural Environment and Landscape Character 24 4.3 Strategic Policy SP31 - Green Infrastructure and Biodiversity 25
PROJECT NUMBER: D2720 VERSION: 3 VERSION DATE: 26 MARCH 2020 COMMENT: FINAL REPORT
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 5 Site Boundary 40.21ha Primary Access Secondary Access Points / Connections Public Rights of Way & Connections into the Village Potential Leisure Routes (to Include Trim Trail ) Community Hub [Total - 0.19ha] (Community, Local Retail, Business Space & Residential) Residential Area [Total - 15.86ha] Amenity Green Space (20.55ha) Primary School (2.20ha) Alternative Locations for Potential N L LEAPs & NEAPs Employment / Commercial Opportunity Site [Total - 0.74ha] SNCI (3.20ha) SNCI Buffer (min 15m)
U11-U12 (OA - 79mx56m) Retained Hedgerows / Vegetation (TBC) N Retained Trees (TBC) Root Protection Zones Potential SuDS Locations (TBC) * Potential Structural Landscaping R1 Intermediate Pressure Gas Main (12.2m Easement TBC) Potential Noise Impacts (TBC) L P Potential for Railway Station Car Park (up to circa 90 spaces) L RC Existing Railway Crossing R5 Ambulance Community Response Post R7 R8
R2 H Minor changes to Key 30.03.20 G Changes to residential parcels 26.03.20 MU1 F Changes to residential parcels 20.03.20 E Change to R2 & R5. MU1 added 12.02.20 N D Changes to Residential Parcels R1 & R5 06.01.20 C Site Boundary update 15.08.19 B SuDS feature added, minor style changes 13.06.19 L A Minor adjustments to parcel accesses 13.06.19
* Rev Description Date R9
© R3 R6 P R4
C1
Little Daux, East Billingshurst Framework Plan *RC * Scale@ A2 : Drawn: Designed: Approved: * DG SG SJP * 1:2,500 0m 100m Drawing Number: Revision: Date: CSP003/008.01 H 30.03.20 50 North Thirteenth Street, Central Milton Keynes, MK9 3BP
01908 666276 [email protected] www. davidlock.com
FIGURE 1.1 - FRAMEWORK PLAN (DAVID LOCK ASSOCIATES, 2020)
6 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS 1.0 INTRODUCTION
1.1 INTRODUCTION 1.2 DESKTOP RESEARCH AND FIELD WORK fabrik Chartered Landscape Architects have been appointed by Bellway and Crest The following documents have been reviewed in preparation of this representation: Nicholson to prepare this landscape and visual representation to the Horsham District Council Local Plan 2019-36, Public Consultation (Regulation 18) February 2020. This • Horsham District Council Local Plan 2019-36, Public Consultation (Regulation 18) document forms a technical appendix to the main representation prepared by Savills. February 2020; • Horsham District Council Regulation 18 Site Assessment Report, February 2020; A review of the landscape setting to Billingshurst and Adversane has been carried out, • Horsham District Council Landscape Capacity Study, Rev B February 2020; and together with a review of landscape and visual conditions specifically for the following • Horsham District Council Landscape Character Assessment, Final Report, October larger sites which are presented in the emerging Local Plan: 2003.
• Land East of Billingshurst (Little Daux) SHELAA Reference SA118 (our clients site); • Land West of Billingshurst (Newbridge Park) SHELAA Reference SA744, SA642 In addition, the desktop survey included a review of Ordnance Survey maps, (includes SA225), SA688; and interactive maps (including magic.gov.uk), aerial photography and the emerging • Land at Adversane, West Chiltington Parish (Kingswood), SHELAA Reference development proposals (associated with our clients site only). SA597. The desktop and field work associated with the preparation of this representation has been carried out in accordance with the Guidelines for Landscape and a Visual Impact Assessment, Third Edition (GLVIA3).
The field survey was carried out on 20 March 2020 when leaf cover was still limited and reflects a winter assessment and therefore the worst-case scenario. The field work for the Kingswood and Newbridge Park sites were carried out from Public Rights of Way that cross the sites and the public highway.
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 7
2.0 LANDSCAPE AND VISUAL CRITIQUEAppendix A) Site Suitability OF CriteriaPROPOSED (in order to deliver LOCAL Sustainable Development) PLAN This guidance note should be read in conjunction with the Site Assessment Criteria Questionnaire. The tables below provide guidance is to help inform landowners / developers 2019-2036 ALLOCATIONS AROUNDabout issues on which BILLINGSHURST the Council will be taking into account – where information is not Regulation 18 Site Assessment Report. The key considerations as part of this process available information about how this may be addressed will be beneficial. The full criteria are are summarised in the following paragraphs. set out in the questionnaire which accompanies this document.
Site Suitability 1) Environmental Considerations 2.16.21 Paragraph 8 of the National Planning Policy Framework (NPPF) sets out the definition INTRODUCTION AND LANDSCAPE PLANNINGLandscape NPPF Chapter 15 – Conserving and enhancing the Natural 2.3 LANDSCAPE SETTING TO BILLINGSHURST of sustainable development in relation to the planning system. It makes clear that CONTEXT Environment development should pursue economic, social and environmental objectives in mutually Broadly, the existing and currently emerging settlement edges of Billingshurst are well supportive ways and that opportunities should be taken to secure net gains in each defined and constrained east by the alignment of the A29 to the west; to the north by None ofarea. the sites Sites were therefore assessed against fourteen criteria considered in this representation lie within or adjacentderived from these NPPF to a Considers that authorities should allocate land with the least New Road; the combination of topography, the railway line and Rosier Wood (Ancient designatedcriteria in order to attain an overall assessment of site sui landscape at the national or local level (such as thetability. South Downs National environmental or amenity value and plan for an enhancement of Woodland) to the south; and the A272 to the east. The landscape beyond these Park, Area of Outstanding Natural Beauty or Area of Attractive Landscape). natural capital. Great weight should be given to conserving and 6.22 The NPPF states that certain assets, including Areas of Outstanding Natural Beauty, defining features and existing and emerging settlement edges (at Amblehurst Green) enhancing landscape and scenic beauty in National Parks AONBs is undulating and predominantly rural and well treed. Rosier Business Park to the east Furthermore,Sites of Special Scientific Interest and irreplaceable habitats such as none of these sites are readily perceived from elevated locations ancient woodland which should be protected. Sites located fully within such areas were therefore considered and the scale of development in these designated areas should be of Billingshurst sits within this landscape. are publicly accessible within the South Downs National Park, due primarily to the not to be suitable and were excluded from further assessment. layers of intervening vegetation. limited. Development on land in or impacting a SSSI / ancient woodland or veteran trees should not normally be permitted. In particular, existing and proposed land uses (relating to the consented petrol filling 6.23 The NPPF is also clear that planning policies which lead to isolated developments in station, the location of which is shown as a * on the plan opposite) west of the A29 are 2.2 the countryside should be avoided. SITE SUITABILITY AND RED The Council is of the view that development on / AMBER / GREEN Assessment criteria Assessment guidance typically urban fringe, with sports uses and a household recycling centre (HHR) set land which does not adjoin existing built-up area boundaries and is not of a sufficient within a well treed landscape, but providing a transitional landscape between town and scale to bring forward new services and facilities on site, (RAG) RATING would lead to isolated rural Is the site in or adjoining a In general terms sites which development which perpetuates unsustainable lifestyle patterns. These sites were also the rural countryside beyond to the west. The combination of ridgelines to the west of protected landscape (AONB / are in / adjoining protected the A29 provides the rural landscape setting to this side of the village. Horshamexcluded from District Councilfurther assessment. have applied the The suitability of sites was assessed using a Red/ above in assessing the suitability of sites as National Park)? landscapes are likely to set out Amber/ Green rating as follows:in the extract below (p57). Are there any other landscape perform poorly against the The east to west railway line dissects the village on its southern edge. Very Positive Impacts constraints (e.g. topography, criteria, particularly taking prominent features) which may be account of footnote 6 of the The visual envelope associated with Billingshurst is heavily influenced by the Favourable Impacts sensitive to development? NPPF. Sites which are combination of topography and layers of vegetation present beyond the village. As proposed in locations with a such, the visual envelope associated with Billingshurst is limited to the immediate local Neutral Impact What is the capacity of the landscape (and considering the completion of Amblehurst Green). landscape to accommodate the low landscape capacity will Unfavourable Impacts (where there is potential for mitigation) scale of development proposed also generally perform less (this should refer to the HDC well against the criteria. Very Negative Impacts (impacts unlikely / unable to be mitigated) Landscape Capacity Study where Conversely sites which can Impact unknown / no information possible)? bring about landscape Does the site offer opportunities for enhancements or regeneration / landscape regeneration are likely to
This RAGSite rating Availability has been taken from the Horsham District Council Regulation 18 Site enhancement? perform better against the Assessment Report, February 2020. Appendix A to that document sets out the criteria criteria. 6.24 The vast majority of sites that have been proposed to the Council can be considered If known, what mitigation is used in assessing the landscape (as shown opposite). This does not cross refer to the Many sites proposed for Council’s‘available’ own Landscape for development Character during the plan period. Assessment (2003)There are however a small number in the assessment criteria or proposed to minimise or reduce guidance,of sites nor hasthat itare considered held on the its Council’s own Planning SHELAA and database Land Management that have not Guidelines been actively any potential landscape impacts? development are greenfield promoted for a number of years and for which the Council has not been able to obtain as part of the assessment. Will this be incorporated into any sites and would require up to date information. These sites have therefore been considered not to be available some mitigation to enable over the Plan period and were excluded from further assessment. masterplanning? Landscape and its character is the combination of both natural / physical, cultural / Do the proposals contribute to the them to be satisfactorily social and perceptual / aesthetic influences, which give rise to a distinct, recognisable assimilated into the local and consistent pattern of elements in the landscape that makes one landscape provision of new or improved green different from another, rather than better or worse and which define the ‘sense infrastructure? landscape – some change
of place’. The landscape is not therefore simply a physical matter, but influences will be permanent and any perceptual qualities (including tranquillity and remoteness) and the experience of the residual impacts will need to
landscape in visual terms. be acceptable after any mitigation. The application of the RAG rating to the sites has briefly described landscape Sites which can contribute matters, under environmental considerations,55 however, it has not considered visual matters such as the visual envelope associated with the proposed site; the scale of to new strategic green LEGEND development proposed; or predicted the range of visual receptors and the value of infrastructure provision and particular views. provide the mechanism to SITE BOUNDARIES TO LAND WEST AND EAST OF BILLINGSHURST (NEWBRIDGE PARK AND maintain this going forward LITTLE DAUX) AS REPRESENTED IN THE REG 18 LOCAL PLAN The RAG assessment in landscape and visual terms requires further refinement.
Furthermore, there is no matrix setting out how the RAG scores have been reached. 398
8 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS A29 NEW ROAD
SPORTS FIELDS
HHR
A272 AMBLEHURST GREEN AND LINK ROAD UNDER CONSTRUCTION A272 * BILLINGSHURST
A29
ROSIER BUSINESS PARK RAILWAY LINE
RAILWAY LINE ROSIER WOOD A272 (ANCIENT WOODLAND)
A29
FIGURE 2.1 – AERIAL PHOTO ILLUSTRATING LANDSCAPE SETTING (FABRIK, 2020)
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 9 2.0 LANDSCAPE AND VISUAL CRITIQUE OF PROPOSED LOCAL PLAN 2019-2036 ALLOCATIONS AROUND BILLINGSHURST
2.4 LAND EAST OF BILLINGSHURST (LITTLE DAUX)
In terms of the Site Description included in the Local Plan, the following are to be acknowledged in addition to that included in the Local Plan, as they influence the perception of the site:
• that there are open views of the existing 2 and 3 storey settlement edge of Billingshurst over and through the boundary vegetation; • there are built form influences immediate to the west and north, with the latter under construction and having already extended the physical and perceptual edge of 4 Billingshurst to the east; and • that the range of built form associated with Rosiers Business Park is evident from within the southern section of site and from land south of the railway line..
The plan opposite shows a reduced red line area relative to land north of the railway 5 only at this stage.
In terms of the RAG Rating we note that landscape is scored as having a neutral impact (yellow) consistent with the assessment of Land at Adversane. However, 5 6 it should be acknowledged that unlike the Adversane site, there are no Ancient Woodlands present within the site.
With regard to the Site Suitability Summary, this is to be amended to reflect that there is no designation for informal recreation within the site. The informal paths created across the site are not permissive and are therefore have no legal status. These, in any event, would be included in the open space proposals across the site.
In terms of the visual envelope, it is predicted that visual effects of developing this site would be limited to the immediate local landscape due to the combination of topography and vegetation and would not significantly alter the existing perception or FIGURE 2.2 – PLAN ILLUSTRATING PHOTOGRAPH LOCATION POINTS (FABRIK, 2020) visual envelope associated with Billingshurst. LEGEND Furthermore, with regard to compliance with sub-section 5 of Strategic Policy 3: Settlement Expansion, the site and the emerging development proposals are: “... contained within an existing defensible boundary and the landscape and townscape SITE BOUNDARY character features are maintained and enhanced”. 21 VIEWPOINT LOCATION In conclusion, out of the three sites considered around Billingshurst, the site at Little Daux has a strong relationship with the existing settlement edges of Billingshurst and where the A272 provides a defensible eastern boundary to the new settlement boundary, in a consistent way to the A29 to the west.
10 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS PAGE LEFT DELIBERATELY BLANK
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 11 2.0 LANDSCAPE AND VISUAL CRITIQUE OF PROPOSED LOCAL PLAN 2019-2036 ALLOCATIONS AROUND BILLINGSHURST
LITTLE DAUX
PHOTOGRAPH – VIEWPOINT 4 VIEW LOOKING SOUTH ACROSS THE WESTERN PART OF THE SITE FROM THE WESTERN FOOTPATH AND TRACK, ADJACENT TO THE VILLAGE EDGE WHICH IS APPARENT THROUGH AND BETWEEN THE BOUNDARY TREES. LITTLE DAUX FARMHOUSE IS EVIDENT ON THE RIDGELINE.
PHOTOGRAPH – VIEWPOINT 5 VIEW LOOKING SOUTHWEST ACROSS THE WESTERN PART OF THE SITE FROM THE WESTERN FOOTPATH TOWARDS THE VILLAGE EDGE, THE THREE STOREY APARTMENTS AND COMMERCIAL BUILDINGS AROUND THE STATION ARE READILY APPARENT OVER THE BOUNDARY VEGETATION.
12 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS ROSIER WOOD ROSIER HOUSE
PHOTOGRAPH – VIEWPOINT 5 VIEW LOOKING WEST ACROSS THE EASTERN PART OF THE SITE FROM THE EASTERN FOOTPATH CLOSE TO THE A272.
ROSIER WOOD
PHOTOGRAPH – VIEWPOINT 6 VIEW LOOKING WEST ACROSS THE SOUTH-EASTERN PART OF THE SITE FROM THE ENTRANCE TO ROSIER BUSINESS PARK.
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 13 2.0 LANDSCAPE AND VISUAL CRITIQUE OF PROPOSED LOCAL PLAN 2019-2036 ALLOCATIONS AROUND BILLINGSHURST
2.5 LAND WEST OF BILLINGSHURST (NEWBRIDGE PARK)
In terms of the Site Description included in the Local Plan, it should also be acknowledged that land to the east of the site, between the A29 and the site, is used for a range of outdoor sport and for household recycling. A footbridge over the A29 8 provides access from Billingshurst. This section should also acknowledge that land generally slopes east to west towards the River Arun and slopes northwards and southwards from the A272 boundary.
With regard to the Site Suitability Summary, in landscape terms the statements made are correct, however, it states that “Although geographically close to Billingshurst, its separated from the village by the A272 limits its relationship with the existing built form, and this relative isolation contributes to the very strong rural character.” Emphasis added. The collection of parcels that make up the site are all separated from 7 Billingshurst by the A29, not the A272. Furthermore, due to the topographic profile of the main parcel, which predominantly slopes away from Billingshurst, development on this site has the potential to tip the currently well contained and well defined western edge of Billingshurst into the rural landscape beyond and thus significantly extending the visual envelope associated with the village to the west by approximately 1km.
With the exception of the A29 to the east, robust and defensible boundaries are limited. The development of this site therefore would not comply with sub-section 5 of Strategic Policy 3: Settlement Expansion.
The land parcel to the south of the A272 has the potential to result in the subsuming of the hamlet around the B2133 and A272 junction, altering the sense of separation from Billingshurst. FIGURE 2.3 – PLAN ILLUSTRATING PHOTOGRAPH LOCATION POINTS (FABRIK, 2020) The site includes the land parcel at Platts Roundabout which is already consented for a petrol filling station and some commercial units. This typical urban fringe consent, LEGEND whilst extending built form beyond the defined settlement boundary, does not justify SITE BOUNDARY (AS REPRESENTED IN THE REG 18 LOCAL PLAN) the proposal for the development of wider land parcels.
In terms of the RAG Rating for landscape, development of the collection of parcels 21 VIEWPOINT LOCATION would actually result in red RAG rating: ‘Very Negative Impacts (impacts unlikely / unable to be mitigated)’ rather than the ‘Unfavourable Impacts (where there is potential for mitigation)’.
In conclusion, the development of this parcel would result in urban sprawl beyond the existing defensible settlement edge into an area that has a very strong rural character; does not have any due to defensible boundaries; and would significantly extend the existing visual envelope associated with Billingshurst. The RAG rating should therefore be amended to red: Very Negative Impacts (impacts unlikely / unable to be mitigated).
14 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS CHURCH SPIRE BARN A272
PHOTOGRAPH – VIEWPOINT 7 VIEW LOOKING EAST ACROSS THE SITE TOWARDS BILLINGSHURST FROM THE WEY SOUTH PATH LONG DISTANCE ROUTE. THE CHURCH SPIRE IS APPARENT ABOVE THE INTERVENING TOPOGRAPHY OF THE SITE AND VEGETATION BEYOND.
A29
PHOTOGRAPH – VIEWPOINT 8 VIEW LOOKING WEST ACROSS THE EASTERN SITE PARCEL FROM THE BUS STOP ON THE A29. THE EMERGING BUILT FORM TO THE EAST OF THE A29 IS EVIDENT, HOWEVER, VIEWS ACROSS THE SITE ARE PREDOMINANTLY RURAL.
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 15 2.0 LANDSCAPE AND VISUAL CRITIQUE OF PROPOSED LOCAL PLAN 2019-2036 ALLOCATIONS AROUND BILLINGSHURST
BILLINGSHURST DWELLINGS ON NEWBRIDGE ROAD CUT LINE
PHOTOGRAPH – VIEWPOINT 9 PANORAMIC VIEW LOOKING SOUTH FROM THE FOOTPATH CROSSING THE SITE. THE WESTERN VILLAGE EDGE OF BILLINGSHURST IS APPARENT BEYOND AND OVER THE INTERVENING VEGETATION.
9
LEGEND 10 SITE BOUNDARY
21 VIEWPOINT LOCATION FIGURE 2.4 – PLAN ILLUSTRATING PHOTOGRAPH LOCATION POINTS (FABRIK, 2020)
16 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS ROWNER ROAD CUT LINE
BARN DWELLINGS ON NEWBRIDGE ROAD
PHOTOGRAPH – VIEWPOINT 9 VIEW LOOKING NORTH-EAST FROM THE FOOTPATH CROSSING THE SITE. THE WESTERN VILLAGE EDGE IS PREDOMINANTLY OBSCURED BY THE INTERVENING LAYERS OF VEGETATION.
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 17 2.0 LANDSCAPE AND VISUAL CRITIQUE OF PROPOSED LOCAL PLAN 2019-2036 ALLOCATIONS AROUND BILLINGSHURST
2.6 LANDSCAPE SETTING TO ADVERSANE 2.7 LAND AT ADVERSANE (KINGSWOOD)
The hamlet of Adversane is centred around a cross road junction and sits within a In terms of the Site Description included in the Local Plan, it states that this site “is predominantly flat landscape associated with minor watercourses north and south. open in nature on the west of the proposed site close to the A29”. However, whilst roadside vegetation obscures views of the groundplane of the site from the north, The landscape around the hamlet rises gently to series of minor ridgelines, which its openness is nevertheless perceived from Adversane Lane and the neighbouring are not readily perceived in the landscape due to the combination of intervening properties to the north. Furthermore, it is experienced as an open site from the field boundary vegetation and woodland blocks. Field boundary vegetation and residential visual receptors both within and immediate adjacent to the site and for small woodland blocks are more prevalent to the north and west of the hamlet. The those visual receptors using the Public Rights of Way (PRoW) that cross or run along landscape to the south-eastern side of the hamlet is more open, allowing longer views the edge of the Site. Overall, the built form influences are intermittent and often relate 3 across the landscape to the ridgeline at Steepwood Farm and where trees form part of to individual isolated dwellings, farmsteads or commercial premises. the backdrop to the view and visual horizon. Whilst parameter plans and / or masterplans at this stage are not available to The landscape setting to this hamlet is predominantly pastoral and provides the review, in terms of the RAG Rating, the landscape is scored as having a neutral landscape separation with the collection of buildings around Chichester College impact (yellow). Under the Site Suitability Summary section, it states that: “Although (Brinsbury campus) to the south. Some of these buildings are commercial (such as attractive, the landscape in the area has not been designate as being of importance. the Hepworth and Co Brewery) and comprise of large sheds, as illustrated in the aerial Nevertheless, it is recognised that a development of this scale will have significant changes on the settlement pattern and wider rural character in this area. The potential photo below. 2 for coalescence of the development between Billingshurst and Pulborough has been identified as a particular concern.” We concur with this statement, especially as there are no readily defensible boundaries to the south, nor to the east, but would also 1 add that due to the limited influence of built form beyond the isolated dwellings and farmsteads, combined with the number of Ancient Woodland blocks and field boundary vegetation, there is a sense of remoteness experienced within the site. However, this statement does not correlate with the neutral scoring and considering the above statement, should be attributed an orange score where: Unfavourable impact (where ADVERSANE there is potential for mitigation).
ADVERSANE LANE Furthermore, these proposals are likely to result in the perceived coalescence with Chichester College to the south, which currently forms an isolated cluster of buildings FIGURE 2.7 – PLAN ILLUSTRATING PHOTOGRAPH LOCATION POINTS (FABRIK, 2020) in the landscape.
Notwithstanding the above, the RAG does not identify the existing Ancient Woodlands, LEGEND which are a key component of the site and are likely to relied upon for visual mitigation A29 purposes. SITE BOUNDARY (AS REPRESENTED IN THE REG 18 LOCAL PLAN)
Whilst not covered in the RAG assessment, following the field work and in terms of CHICHESTER the visual envelope, it is predicted that visual effects of developing this site would be 21 VIEWPOINT LOCATION COLLEGE STEEPWOOD limited to the site level and local landscape, due primarily to the layers of vegetation FARM both within and beyond the site.
With regard to compliance with sub-section 5 of Strategic Policy 3: Settlement Expansion, the site does is not fully: “... contained within an existing defensible boundary...”
BEEDINGS In conclusion, due to the lack of defensible boundaries, the potential for COPSE coalescence and sense of remoteness, the RAG rating should be revised to orange: Unfavourable impact (where there is potential for mitigation).
FIGURE 2.6 – AERIAL PHOTO ILLUSTRATING LANDSCAPE SETTING
18 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS PAGE LEFT DELIBERATELY BLANK
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 19 CUT LINE
PHOTOGRAPH – VIEWPOINT 1 PANORAMIC VIEW LOOKING EAST ACROSS THE WESTERN PART OF THE SITE FROM THE BRIDLEWAY THAT FOLLOWS THE EASTERN SITE BOUNDARY. VIEWS OF STEEPWOOD FARM AND ASSOCIATED BARNS AND DWELLINGS TO THE WEST AND FARM BARNS TO THE EAST ARE PERCEIVED FROM THIS ROUTEWAY.
DWELLING AT STEEPWOOD
PHOTOGRAPH – VIEWPOINT 2A VIEW LOOKING NORTH ACROSS THE CENTRE OF THE SITE FROM STEEPWOOD LANE BRIDLEWAY. THE INDIVIDUAL DWELLING OF STEEPWOOD AND STEEPWOOD FARM BUILDINGS (SEE PHOTOGRAPH 2B) ARE PERCEIVED FROM THIS LOCATION. CUT LINE
PHOTOGRAPH – VIEWPOINT 3 VIEW LOOKING EAST ACROSS THE WESTERN PART OF THE SITE FROM THE LAYBY ON THE A29 STANE STREET. TREES FORM THE VISUAL HORIZON.
20 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS DWELLING AT STEEPWOOD FARM CUT LINE
STEEPWOOD FARM BARNS
PHOTOGRAPH – VIEWPOINT 2B VIEW LOOKING EAST FROM STEEPWOOD LANE BRIDLEWAY. THE BARNS OF STEEPWOOD FARM ARE VISIBLE IN ITS RURAL CONTEXT. CUT LINE
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 21 3.0 LANDSCAPE AND VISUAL CRITIQUE OF NEW LOCAL PLAN EVIDENCE BASE
3.1 LANDSCAPE CAPACITY STUDY, REV B FEBRUARY to the visual envelope associated with Billingshurst, overall, the site has a No/Low capacity overall and should therefore be excluded from the consideration of future 2020 development sites.
This section reviews the above document following a smaller scale review of the The current Low-Moderate capacity judgement should be amended to No/Low individual sites at Kingswood, Little Daux and Newbridge Park. capacity.
The purpose of the Landscape Capacity Study (LCS) is to provide an overarching Land at Adversane, West Chiltington Parish (Kingswood) strategic level assessment of potential development sites without the benefit of the The majority of this site lies within area 45 which is defined as having moderate parameter plans or masterplan proposals. It is noted, as set out in para 1.8 that this capacity overall, which is defined as where: “This area has an ability to accommodate Study is ‘generalised’ and provides: “a pointer to detailed landscape and visual issues development in some parts without unacceptable adverse landscape and visual that would need to be addressed in a site allocation or development management impacts or compromising the values attached to it, taking account of any appropriate context”. It goes on to state that: “Landscape sensitivity and capacity levels are mitigation. There is a need for each proposal to be considered on its individual merits indicative, and it is expected that further analysis at a smaller scale and more detailed to ensure that there are no unacceptable adverse impacts”. assessments of the area would be carried out in relation to specific applications to determine the actual capacity of the site.” Emphasis added. The north-western outer corner broadly at the junction of the A29, B2133 Adversane Lane and the railway line forming part of area 46; and the south-eastern woodland The following sections sets out the findings of the Capacity Study and provides further edge relative to Beeding’s Copse and adjacent Ancient Woodland forming part of area level of assessment relative to each of the sites following more detailed desktop and 44 which are both defined has having No/Low capacity for large scale housing, which field assessment work. is defined as where: “The area is unable to only has very limited potential to be able to accommodate the specified type and scale of development without unacceptable All of the above sites lie within Zone 4: Pulborough to Billingshurst. All of these sites adverse landscape and visual effect or compromising the values attached to it, taking are proposed for large scale housing development of 500 or more dwellings. The account of any appropriate mitigation”. landscape capacity assessment does not take into account the boundaries of the three sites. The following paragraphs set out the findings of the LCS and then following on A couple of comparisons can be made between the assessment of area 46 and 44 with a more detailed assessment and commentary. which are not included in the assessment of area 45. The majority of the site 45 shares some of the qualities of the neighbouring areas in that this tract of land is Land East of Billingshurst (Little Daux) also ‘enclosed by wooded shaws and hedgerows’ and is ‘unspoilt in character and The majority of the site lies within area 48 which is defined has having Moderate where the landscape is generally in good condition’ (albeit that, as with any large tract capacity, with the northern and north-eastern part of the site forming the southern of land, some parts are of lower quality). Furthermore, the assessment of area 45 section of a wider area 49 which is defined as having No/Low capacity. states that there is a limited footpath network, however the site actually contains two bridleways in the eastern part of the site and is therefore accessible. Furthermore, the However, considering the strong relationship that this site has with the existing and development of this land may result in the perceived coalescence of Adversane with emerging settlement edges and whereby development can sit within the retained the isolated collection of buildings associated with Chichester College. framework of trees and hedgerows, the capacity of area 48 should be elevated to Moderate - High capacity, which is defined as where: “The area is likely to be able to Overall, considering these additional points would reduce its capacity to Low- accommodate a significant proportion of development without unacceptable adverse Moderate, where: “The area only has potential to be able to accommodate landscape and visual impacts or compromising the values attached to it, taking development in limited locations without unacceptable adverse landscape and visual account of any appropriate mitigation.” impacts or compromising the values attached to it, taking account of any appropriate mitigation.” In conclusion, the current Moderate capacity judgement should be amended to be Moderate - High. In conclusion, the current Moderate capacity judgement should be amended to be Low-Moderate. Land West of Billingshurst (Newbridge Park) The landscape to the west of Rowner Road is excluded from the assessment which is questioned and assumed therefore that there is No/Low capacity for the land west of Rowner Road accordingly.
Land to the north of the A272 lies within area 51, defined as having Low-Moderate capacity; with land to the south of the A272 being within area 52, which also is defined as having Low-Moderate capacity. Considering the physical landscape attributes, its physical separation from the village edge and the predicted changes
22 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS ´ 1 49
2 48
47
46
4
43 44
42
40
41 39
38 C3 C1
LEGEND 3 C2
ed sca e e sca e
B one 4a u borou h to i in shurst orsha istrict Counci o o capacit andscape capacit of oca andscape ar side Chart a orsha o oderate capacit character areas for ar e and ediu est usse 12 1 oderate capacit arbara Chi ds irector of ace housin de e op ent oderate i h capacit eproduced b per ission of rdnance ur e ap on beha f i h capacit of . Cro n cop ri ht and database ri hts 2 2 . ra in C 4 ate 1 2 11 ca e 1 2 at 3 B rdnance ur e icence.1 23 6 and co itted for de e op ent e isions 26 2 2 13 1 1 2 2 B LOCAL PLAN SITE BOUNDARIES:
A A LAND TO THE EAST OF BILLINGSHURST (LITTLE DAUX) B
B LAND TO THE WEST OF BILLINGSHURST (NEWBRIDGE PARK)
A C LAND AT ADVERSANE (KINGSWOOD)
C
C
FIGURE 3.1 – EXTRACT FROM HORSHAM DISTRICT COUNCIL LANDSCAPE CAPACITY ASSESSMENT MAP (HDC, 2020)
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 23 4.0 REVIEW OF PROPOSED POLICIES
4.1 INTRODUCTION LCA G3 Planning and Land Management Guidelines Land East of Billingshurst (Little Daux) Proposals and Response Conserve rural undeveloped character. Any large scale housing and commercial The development of any green field site in this character area will alter the character of This section of the representation provides a commentary on the landscape related development is likely to damage character, e.g. through loss of small scale field patterns the landscape, however, the proposals will retain the field pattern through the retention emerging Strategic Policies 27 and 31, with the overall comments provided in the and loss of woodlands. of existing boundary hedgerows and trees; and will retain existing wooded areas as part Regulation 18 Local Plan. It also sets out how the proposed development on land of the Site of Nature Conservation Importance (SNCI). to the East of Billingshurst (Little Daux) responds and addresses landscape related policy. Consider the cumulative impact of small scale change, e.g. suburbanisation along In terms of cumulative impact, the proposed development would see the continuation roads. of built form further southwards to the character area boundary along the railway line. There is already a perception of built form to the north of railway line due to the presence of Rosier Business Park, the nursery and the adjacent residential 4.2 STRATEGIC POLICY SP27 - NATURAL park, along with individual dwellings. In essence, there would be a change to the ENVIRONMENT AND LANDSCAPE CHARACTER landscape character map, where the land to the north (currently under construction and which straddles the A272) and the site itself would form part of the area defined as The site is not subject to any landscape designations. Therefore, in relation to Para’s Billingshurst. The existing planting along the eastern boundary of the Site along the 170 and 171 of the NPPF the site is therefore ‘off the bottom’ of the landscape A272 will be retained and replanted; the sense of separation to and around existing value hierarchy. For the purposes of Para 170a of the NPPF the Site is not a valued dwellings would be retained; and the entrance into Rosier Business Park will be landscape. reconfigured to accommodate a new roundabout. The cumulative effect on landscape character arising through the land currently being built out and the proposed site is that The proposed development has been landscape led, keeping development away the perception of Billingshurst, will extend south-eastwards to the railway line. However, from the more sensitive areas of the Site. However, as with the development of any these effects will be moderated with the implementation of the landscape measures greenfield parcel, there will be an ultimate change in the character of that landscape defined above. from green field to built form and associated green infrastructure, creating a high Ensure any appropriate new development responds to historic settlement pattern, local The proposed development framework plan shows the intended development zones quality environment with a sense of place. Therefore, in relation to landscape related design and building material and is well integrated into the existing landscape pattern of which are integrated into the existing landscape pattern, retaining existing wooded bullet points of Policy SP27, the site and proposed development: woodland, hedgerows and shaws. areas, hedgerows and trees. The design intent is that the proposed development will be high quality and reflect local vernacular. 1. Will protect, conserve and enhance the key characteristic landscape features of Manage coppice woodlands where appropriate. If appropriate, this will be implemented as part of the co-ordinated landscape and the site, namely the topographic profile, the existing landscape structure relative to ecological management plan submitted as part of a future planning application and as the existing wooded areas, treebelts, high quality trees and hedgerows (the latter of part of the site wide biodiversity proposals. which defines the existing field parcels). The existing vegetation framework will be supplemented with new planting as part of the site wide enhancement proposals. Restore native species in conifer plantations All new planting across the site will be native. The expansion of the village to the east will maintain settlement separation between Restore where possible arable fields to pasture With the exception of the SNCI area, which will be retained, the proposed Green Billingshurst and Southwater to the north-east. Infrastructure network will alter the use of some of the green field parcels. Manage isolated field trees Isolated field trees within the site are limited and where they are present, they are 2 and 4. Will provide an accessible and co-ordinated high quality response to the proposed to be retained as part of the Green Infrastructure network. The management provision of Green Infrastructure and SUDs across the site. The Green Infrastructure of trees across the site will be subject to measures set out in a landscape and is proposed to be accessible to the existing and new community alike and which ecological management plan submitted as part of a future planning application. addresses the public open space policy requirements; which provides a multifunctional landscape design response; and provides alternative recreation opportunities and Encourage landowners to adopt better management of horse paddocks There are no horse paddocks present within the site and therefore this guideline is not opportunities for learning through nature. applicable.
5. Does not sit within, or perform a role in the setting to, a designated landscape either nationally or locally.
In terms of landscape character, the site lies at the southern end of Landscape Character Area G3 Slinfold and Five Oaks Wooded Farmland, as defined in the Horsham District Council Landscape Character Assessment (2003). The railway line forms the boundary of this LCA with J1 to the south – Billingshurst and North Heath Farmlands.
A response to each of the Planning and Land Management Guidelines for LCA G3 is set out in the following table.
24 LAND EAST OF BILLINGSHURST | LANDSCAPE AND VISUAL REPRESENTATIONS 4.3 STRATEGIC POLICY SP31 - GREEN INFRASTRUCTURE AND BIODIVERSITY
The proposed development will provide a multi-functional and connected network of green spaces in the form of trees, informal park, road verges, woodland and wetland. The range of spaces will provide for flood protection in the form of SUDs, formal and informal recreation, landscape and nature conservation. As such, the proposed development will, in relation to the landscape specific bullet points of the policy:
1. Maintains and enhances the existing network of green infrastructure across the site in the form of the green corridors associated with the existing vegetation pattern, predominantly relating to field boundaries.
2. As set out above, will retain existing water features, hedgerows, trees and deciduous woodland and provides for additional planting as part of the landscape enhancement measures proposed in relation to Policy SP27.
3. Replacement planting for trees proposed to be removed is embedded within the landscape principles and compensation strategy. The overarching tree strategy is that there will be net gain to tree planting.
LAND EAST OF BILLINGSHURST| LANDSCAPE AND VISUAL REPRESENTATIONS 25 LENTEN HOUSE 16 LENTEN STREET ALTON HAMPSHIRE GU34 1HG
FIRST FLOOR STUDIO 4-8 EMERSON STREET LONDON SE1 9DU
36 ST MARY’S STREET EDINBURGH EH1 1SX
FABRIKUK.COM
COMMENTS FORM Horsham District Local Plan 2019 - 2036 Draft Plan Regulation 18 Consultation (February 2020)
We are inviting comments on the emerging Local Plan. Comments should ideally be submitted online by visiting https://www.horsham.gov.uk/planning/local- plan/have-your-say. It is better for comments to be submitted in this way as it ensures a thorough analysis of comments against particular parts of the Local Plan and ensures representations are processed quickly and efficiently such that the Council can swiftly proceed onto the next stage of the plan-making process. If you are unable to comment online, this form should be used to make comments in response to this consultation. Please use a separate form for each comment made on a different policy or part of the Local Plan. The consultation period begins on Monday 17 February 2020 and ends at 5pm on Monday 30 March 2020.
Please note: 1. Responses must include as a minimum your name and address. Please also provide your email address if you have one – without an email address, we will be unable to provide an acknowledgement of receiving your response. 2. Anonymous representations will not be accepted. Your comments cannot be treated as confidential. By completing this form you agree to your details being shared and your name and comment (but not your address or other personal details) being made available for public viewing. Please review the Council’s Privacy Statement at https://www.horsham.gov.uk/privacy-statement. 3. No inappropriate, derogatory or discriminatory comments should be made regarding an individual or a collective group of individuals. Any comments made of this nature will be disregarded. 4. It is recommended that groups that share a common view send a single response rather than multiple copies of the same response. 5. Completed comment forms can be returned to us via email to [email protected] or by post to Strategic Planning, Horsham District Council, Parkside, Chart Way, Horsham, West Sussex RH12 1RL. 6. Completed forms should be received by us no later than 5pm on 30 March 2020.
1 Continues over page
Please leave this page blank and go to the next page.
2 Continues over page
For official use only: Date received: Consultee &
comment ID: Section 1 – Your details
Personal details
Title Mr
Name (required) Charles Collins
Organisation / group Savills
(if you are an agent (on behalf of Bellway Homes & Crest Nicholson) representing a client, please specify the client you are acting on behalf of)
Address 1 (required) 244-246 High Street
Address 2 Guildford
Address 3
Address 4
Postcode GU1 3JF
Telephone number 07870 999 596
Email address (required) [email protected]
Section 2 – Your comments
To which part of the draft Local Plan do your comments Please see overleaf. relate? Please state the policy number, paragraph number or figure number, or where applicable enter ‘SA’ (Sustainability Appraisal’ or ‘HRA’ (Habitat Regulations Assessment)
What is the nature of your comments? [tick as appropriate]
Observation X Support X Objection X or General comment
3 Continues over page
Provide your comments below:
Expand this box as necessary or attach additional sheets. If attaching additional sheets, please clearly mark these with the consultation question that the representation relates to and your name.
Please see Main Representation Report prepared by Savills with appendices, notably:
Illustrative Master Plan – David Lock Associates (Appendix 2) Framework Plan – David Lock Associates (Appendix 3) Little Daux Vision Document – David Lock Associates (Appendix 4) Technical Note – Ardent (Appendix 5) Biodiversity Net Gains Report – Ecology Solutions (Appendix 6) Mens SAC and Ebernoe Common SAC Note – Ecology Solutions (Appendix 7) Landscape and Visual Report – fabrik (Appendix 8)
HDC Evidence base commentary:
Built up Area Boundary Review (February 2020) Habitats Regulation Screening Report (30 January 2019) Horsham District Local Plan Interim Sustainability Appraisal (February 2020) (including SA of strategic sites and growth options, SA of smaller sites and policies and SA Non-technical Summary of sites and growth options) Infrastructure Delivery Plan (January 2020) Landscape Capacity Study Rev B (February 2020) Northern West Sussex Housing Market Assessment (November 2019) Strategic Flood Risk Assessment (January 2020)
Representations (PTO):
4 Continues over page
Strategic Policy 1: Sustainable Development – Support
Strategic Policy 2: Development Hierarchy – Object
Strategic Policy 14: Housing Provision – Comment
Potential Housing Allocations – Comment
Smaller Scale Development – Comment
Strategic Policy 15: Strategic Site Development Principles – Object
Strategic Policy 16: Affordable Housing - Object
Strategic Policy 17: Housing Mix - Object
Strategic Policy 18: Housing Standards – Object
Strategic Policy 25: Environmental Protection – Comment
Strategic Policy 26: Air Quality – Comment
Strategic Policy 27: The Natural Environment and Landscape Character - Comment
Strategic Policy 31: Green Infrastructure and Biodiversity – Support
Strategic Policy 33: Development Quality – Object
Strategic Policy 34: Development Principles – Object
Strategic Policy 35: Heritage – Object
Strategic Policy 37: Climate Change – Object
Strategic Policy 38: Appropriate Energy Use – Object
Strategic Policy 40: Flooding – Comment
Strategic Policy 42: Sustainable Transport – Comment
Strategic Policy 43: Parking – Comment
Policy 46: Community Facilities and Uses – Object
5 Continues over page
Section 3 – Declaration
How we will use your personal information All comments will be publicly available, and identifiable by name and (where applicable) organisation. Please note that any other personal information provided will be processed by Horsham District Council in line the Data Protection Act 1998 and General Data Protection Regulations. Horsham District Council will process your details in relation to this preparation of this document only. For further information please see the Council’s privacy policy: https://www.horsham.gov.uk/privacy- policy.
Please sign and date this form. Forms signed electronically will be accepted. Declaration: By completing and signing this form, I agree to my name, organisation and representations being made available for public inspection on the internet and in paper form. I further understand that my personal contact details will be used to notify me further of later stages of consultation relevant to the Horsham District Local Plan Review. I understand that personal details will not be made publicly available. A copy of our privacy notice is available on our website - https://www.horsham.gov.uk/privacy- statement
Signature: Date: 30th March 2020
We would also like to keep you informed of future Local Plan and planning policy consultations and updates. If you would like to be kept informed, please register your details on our consultation portal by going to https://www.horsham.gov.uk/planning/local-plan/have-your-say and clicking on the ‘Register to have your say’ button.
6