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Rusper NP Regulation 14 Summary Report

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Rusper NP Regulation 14 Summary Report oneill homer RUSPER NEIGHBOURHOOD PLAN REGULATION 14 REPORT: OCTOBER 2019 Purpose 1. The purpose of this report is to summarise part of the outcome of the consultation period on the Pre-Submission Rusper Neighbourhood Plan held from 2 September to 14 October 2019. The report reviews the representations made by some of the statutory consultees, and by developers/landowners. It then makes recommendations for minor modifications to the Plan for its submission to Horsham District Council. 2. The report will be published by the ‘qualifying body’, Rusper Parish Council, and it will be appended to the Consultation Statement that will accompany the submitted Plan in due course and in line with the Neighbourhood Planning (General) Regulations 2012 (as amended). Consultation Analysis & Recommendations 3. During the consultation period, representations were made by Homes England (promoting significant land interests within Rusper as part of the Horsham Local Plan Review), Sport England, Gladman, Chichester Diocese and Evison & Company on behalf of Chichester Diocese, Barton Willmore (on behalf of Legal and General), Lewis & Co Planning (on behalf of the Director of Hotel Operations of Boundless in relation to Ghyll Manor), Bell Cornwell (on behalf of Denton Homes and Mary Hurst), ECE Planning (on behalf of Mr Simon Bastable), Don Burstow (on behalf of Daniel and Sophie Burstow and Diana Miles), Natural England, Thames Water, Surrey County Council, West Sussex County Council, Highways England and Horsham District Council (HDC) as the Local Planning Authority. 4. Sport England, Natural England, and Surrey County Council had no specific comments to make on the policies of the plan. 5. Homes England highlights that the specific reference to a 2,000m separation between Horsham and Crawley is factually incorrect. It is recommended that the Steering Group satisfies itself that the statement within the Foreword to the Plan is suitably justified perhaps by including this distance on the 2018 SHELAA map. 6. It is also noted, that Homes England also suggests that the opportunity for development of Land West of Ifield is underplayed in Sections 2 and 3 of the Plan given the history of proposals in this area. Such a significant proposal (described in paragraph 3.8 and 3.10) which has only recently been announced is a matter for the Horsham Local Plan Review and is entirely supposition as far as the current neighbourhood plan is concerned. 7. The mechanism for considering proposals, particularly those that ‘anticipate and respond to long-term requirements and opportunities, such as those arising from Rusper Neighbourhood Plan: Regulation 14 Summary Report 1 major improvements in infrastructure’ (§22) should be considered through strategic policies. As this option is yet to be tested through the plan-making process, the most appropriate channel to respond to such proposals, including the option being promoted by Homes England, is through the formal channels with the Local Planning Authority at appropriate stages through the Local Plan Review. 8. A Neighbourhood Plan can come forward before a spatial development strategy is in place and it will not be tested against the policies of an emerging plan. However, the reasoning and evidence base informing the local plan process is likely to be relevant (PPG ID 41-009-20190509). The latest update with regards to the Local Plan Review does not include a preferred option and therefore Paragraphs 3.8 and 3.9 sets out how the Neighbourhood Plan has had regard to this process. 9. There is no mechanism in legislation that requires Neighbourhood Plans to be reviewed, however as set out in Paragraph 3.12 the Parish Council has committed to undertaking a review once up-to-date evidence becomes available. It is therefore considered that no specific amendments are required to the Plan. 10. Barton Willmore suggests that the Land North of Horsham approved planning application should be included on the Policies Map. The purpose of a Policies Map is to identify where the plan’s policies apply, it is not necessary to include the location of consented land, however if the Steering Group consider it necessary to demonstrate this matter it can be included in Section 2 of the plan. Barton Willmore also confirms that its proposals accord with the relevant policies of the plan, but seeks further clarification on the scope of the proposed entry gates in Policy RUS 13 (see below). 11. Thames Water have requested policies regarding new water/wastewater infrastructure. This neighbourhood plan does not allocate housing development, nonetheless the issue is understood, and it is noted that Policy 39 Strategic Policy: Infrastructure Provision in the Horsham District Planning Framework 2015 deals with this matter. It is recommended that the Steering Group notes this requirement for the future review of the Neighbourhood Plan. 12. West Sussex County Council highlights that the Parish is underlain by brick clay which is a safeguarded resource under Policy M9 of the West Sussex Joint Minerals Local Plan 2018. This means that development within the parish may be subject to a minerals resource assessment to ensure that viable mineral resources are not permanently sterilised. Although the plan does not allocate land for development, it is recommended that paragraph 3.13 is updated to accurately reflect this matter. Specific comments on education are considered under the policy heading below. 13. HDC and Highways England notes that the plan does not allocate, and a review will be undertaken once the emerging Horsham Local Plan is adopted, which is expected in 2021. In general, HDC considers that the Steering group have fully engaged with the relevant stakeholders to a produce a neighbourhood plan supported by a robust evidence base and that the plan meets the Basic Conditions and will contribute positively towards sustainable development and improving the quality of the environment. Specific comments in relation to HDC’s comments on Local Green Spaces are considered under the policy heading below. Rusper Neighbourhood Plan: Regulation 14 Summary Report 2 14. Bell Cornwell (on behalf of Denton Homes) criticise the absence of a policy on housing mix and tenure given a Housing Needs Assessment had been completed. Additionally, Bell Cornwell (on behalf of Denton Homes and Mary Hurst) consider that the decision to ‘postpone’ allocation means that the plan does not meet its ‘basic conditions’ given that §66 of the NPPF allows for an indicative figure based on the latest evidence of local housing need. §66 is only engaged if requested by the qualifying body and the scope of a Neighbourhood Plan does not need to include housing allocations. The reasons for not doing so is clearly set out in the plan and in adopting this approach, the Parish Council has been made aware of the risks. 15. Highways England comments concentrate on proposed housing numbers across the District and the importance of HDC’s Transport Study supporting the emerging Local Plan. The opportunity for neighbourhood plans to influence such matters are limited, however, it does seek to highlight the existing transport issues in the parish of Rusper and how it can be part of the solution to the existing issues, particularly regarding Policies RUS12 and RUS13. Additionally, the Parish Council continues to remain committed to working with HDC and West Sussex CC (the Highways Authority) in continuing a dialogue on traffic calming measures in the Parish. It is therefore recommended that the Parish Council highlights this response to HDC and continues to engage with HDC through the preparation of its Local Plan and supporting transport evidence and Infrastructure Delivery Plan. 16. A further summary analysis of these representations is provided in respect of each policy below, together with recommendations on making modifications for the final version of the Plan: RUS1 – Spatial Plan 17. Homes England and Gladman consider that the policy seeks to undermine the future strategic growth of Crawley. The policy is seeking to reflect the status of the settlements in the parish as currently identified in the HDPF. While the policy may become out of date when the new Horsham Local Plan is adopted, nevertheless the purpose of the policy is to define the Parish as currently set out in the HDPF. We recommend however that the policy is amended to read as an earlier version to avoid confusion with the purpose of RUS8 and worded as follows: RUS1: Spatial Plan The Neighbourhood Plan defines the built-up area boundary for Rusper, as shown on the Policies Map, for the purpose of applying Policy 4 of the Horsham District Framework. Development proposals should conserve the open and tranquil character of the intervening landscape and its views at the following locations: SP1 Between Ifield and Ifieldwood; and SP2 Kilnwood Vale, Crawley and Lambs Green. Proposals which would either individually or cumulatively, unacceptably harm or detract from the distinctive landscape character and separation of these areas, as defined on the Policies Map, will not be supported. Rusper Neighbourhood Plan: Regulation 14 Summary Report 3 18. Bell Cornwell (on behalf of Denton Homes) consider that the settlement boundary should be amended to include sites for development. The reasons why this is unnecessary is clearly set out in the plan in section 3. Planning Practice Guidance Paragraph: 104 Reference ID: 41-104-20190509 states “The scope of neighbourhood plans is up to the neighbourhood planning body. Where strategic policies set out a housing requirement figure for a designated neighbourhood area, the neighbourhood planning body does not have to make specific provision for housing, or seek to allocate sites to accommodate the requirement (which may have already been done through the strategic policies or through non-strategic policies produced by the local planning authority)…” RUS3 – Design 19. Homes England suggest that criteria viii. should remove reference to specific technologies and should be replaced with generic reference to the most suitable technologies at that point in time.
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