Crawley 2035: The Crawley Borough Local Plan
Statement of Representation Procedure and Notification of Public
Consultation Submission Local Plan: 20 January – 2 March 2020
Regulation 19, 20 and 35 of the Town and Country Planning (Local Planning)
(England) regulations 2012

The submission Local Plan sets out the council’s vision for the development of
Crawley from 2020-2035. This is a Local Plan Review that contains strategic
planning policies and principles which will shape the future of the town and will be
used in the consideration of planning applications.

The publication of the submission Local Plan for Crawley is being made available for
representations over a six week statutory consultation period starting on Monday 20
January – Monday 2 March 2020. During this period the Local Plan will be published
and made available alongside other supporting documents.

Making a representation

If you would like to comment on the submission Local Plan, you will be required to
comment on whether you consider the plan to comply with legal requirements, the
duty to cooperate, and whether the document is sound.
Representations must be received by the Borough Council no later than 5pm on 2
March 2020 or they will not be considered.
All representations received within the statutory consultation period will be submitted
to the Secretary of State, who will appoint an Inspector to carry out an independent
examination of the Local Plan and its evidence base.
Representations should be provided in writing. This can be done by completing and
submitting the standard representation form using the following methods:
• Online: using the council’s eform at
• Email:
• Post: Forward Planning, Crawley Borough Council, Town Hall, The
Boulevard, Crawley RH10 1UZ.
Paper copies of the representation form and guidance notes are available at the
Town Hall or can be posted out if requested, or can be viewed online at

Document availability

During the representation period the submission Local Plan and all of its supporting
documents will be available to view online at
Paper copies of the documents will be available at the following locations:
• Town Hall: The Boulevard, Crawley RH10 1UZ. Phone: 01293 438000.
Opening hours: Monday to Friday 8.30am-5pm.
• Crawley Library: Southgate Avenue, Southgate, Crawley RH10 6HG. Phone:
01293 651744. Opening hours: Monday to Friday 9am-7pm and Saturday

Please indicate in your representations if you would like to be notified of future stages
of the Local Plan, including the submission of the Local Plan for independent
examination, the publication of the Inspectors recommendations and the adoption of
the Local Plan.
For more information visit, email us at or call us on 01293 438624.


Crawley 2035: A Vision

By 2035, Crawley will be a place that people want to visit, to have fun and spend their leisure time. As a town within a countryside setting that is very much valued by local people, it will be safe and well cared for.

The rich heritage which has shaped what the town is today will be respected, protected and enhanced.

Local communities will be directly involved in planning how the town grows and develops in order to achieve the best outcome for all concerned; particularly where difficult choices have to be made

Protecting the Environment: Sustainability

…Active travel and public transport will be significantly improved (Traffic congestion – gridlock? – Ed) and supported by a road network that prioritises sustainable transport modes….A sustainable road network will be complemented by a good public transport system, giving people choice about how they travel…Conserving natural resources to support future growth will be vital to the longevity of the town.

Air, noise [vehicle & aircraft -Ed] and water [flooding & sewage/waste disposal – Ed] pollution will be reduced.

The borough will prepare for the increasing effects of climate change, through adaptation measures including lower water usage standards and delivering a net gain in biodiversity.

Losses to protected and priority species and habitats [eg bat & dormouse – Ed] will have been avoided and the delivery of vital ecosystem services, including pollination, flood alleviation and carbon capture, will have been enhanced in order to facilitate a sustainable and resilient future…


2.23 Within the borough, the identification of housing sites has required consideration of
all competing land use needs including open space and employment to ensure an
appropriate balance has been struck in delivering sustainable development.


Development adjacent to Crawley

2.29 Delivery of homes in new neighbourhoods in close proximity to Crawley is an
appropriate way to meet the needs of the emerging households from within the
existing population, and joint working has been long established in recognition of this.
This has included the Joint Area Action Plan prepared and adopted by Crawley
Borough and Horsham District Councils in 2009 for West of Bewbush which is seeing
the current delivery of the new Kilnwood Vale neighbourhood, immediately adjacent
to Crawley’s boundary whilst being located wholly within Horsham District. The
identification of a Strategic Development Location to the West and North West of
Crawley for 2,500 homes was set out in the West Sussex Structure Plan. Kilnwood
Vale was subsequently determined as the most appropriate location to take forward

15 Northern West Sussex Authorities Position Statement, paragraph 6.13 (September 2013), Crawley Borough
Council, Horsham District Council and Mid Sussex District Council
16 Northern West Sussex Authorities Position Statement, paragraph 6.21 (February 2015), Crawley Borough
Council, Horsham District Council and Mid Sussex District Council
17 Reigate and Banstead Core Strategy, paragraph 7.4.1 – 7.4.4 (2013) Reigate and Banstead Borough Council;
Horsham District Planning Framework, paragraph 6.3 (November 2015) Horsham District Council; Mid Sussex
District Plan 2014 – 2031, Policy DP4: Housing, second paragraph, page 30, and Policy DP5: Planning to Meet
Future Housing Need, pages 33-34 (March 2018) Mid Sussex District Council
18 2014-based Household Projections; affordability ratio ONS 2018

following detailed assessments of the opportunities and constraints for providing a
new neighbourhood and development potential around all of Crawley’s boundaries19
2.30 In addition to Kilnwood Vale, the new neighbourhood within Crawley’s administrative
boundaries (Forge Wood) and the new neighbourhood level extensions to Horley
(within Reigate and Banstead administrative boundaries) are being progressed.
Further significant level of development is permitted, and taking place, to the east of
Crawley’s administrative boundaries at land west of Copthorne, to the west along
Rusper Road and to the south, in the Area of Outstanding Natural Beauty, at Pease
Pottage. The development coming forward adjacent to the borough’s administrative
boundary, is shown on the plan below.
Fig 2: Planned Development Adjacent to Crawley
2.31 Other potential urban extensions to Crawley may include extensions to the east
and/or west of the borough boundary. All opportunities are being explored to
understand whether these would constitute the most sustainable housing
development locations in the context of the wider housing market area and travel to

19 At Crawley Study (2009) GL Hearn
work area and whether the existing infrastructure, and environmental constraints can
be resolved.
2.32 This plan should not be considered as an indicator of the extent of acceptable
development adjacent to Crawley. Many physical, environmental and policy
designations apply to these areas, including Green Belt, Area of Outstanding Natural
Beauty, Ancient Woodland and Sites of Special Scientific Interest. The planning
policies of the neighbouring authorities will apply in cases of development outside of
Crawley’s administrative boundaries. However, it illustrates the locations of current
developments taking place close to Crawley which will have implications for, and
impacts on, Crawley’s infrastructure and setting.


2.36 As a result of this, there are several areas where the planning system can build upon
nationally described standards to ensure that the borough’s potential to adapt and
mitigate against the effects of climate change is maximised. These are fundamental
to the priority objectives for Crawley to 2035 and to the most significant elements of
the town’s locally distinctive context.
2.37 The priority areas are:
1. Ensuring new buildings are low carbon
2. Bringing forward district energy networks
3. Combating serious water stress
4. Promoting public transport and active travel
5. Protecting and enhancing the Green Infrastructure Network in terms of
connectivity, accessibility and net gain in biodiversity, including water quality.


Neighbourhood Plans

2.52 Currently there are no neighbourhood plans within the borough, but the council is
working closely with neighbourhood forums and other groups, and is offering support
if any wish to bring forward a neighbourhood plan.


Presumption in Favour of Sustainable Development
3.1 The NPPF confirms that the purpose of the planning system is to contribute to the
achievement of sustainable development21, and sets out the planning system’s role in
supporting the three dimensions of sustainable development:
 An economic objective: to help build a strong, responsive and competitive
economy, by ensuring that sufficient land of the right type is available in the right
places and at the right time to support growth, innovation and improved
productivity; and by identifying and coordinating the provision of infrastructure;
 A social objective: to support strong, vibrant and healthy communities, by
ensuring that a sufficient number and range of homes can be provided to meet the
needs of present and future generations; and by fostering a well-designed and safe
built environment, with accessible services and open spaces that reflect current
and future needs and support communities’ health, social and cultural well-being;
An environmental objective: to contribute to protecting and enhancing our
natural, built and historic environment; including making effective use of land,
helping to improve biodiversity, using natural resources prudently, minimising
waste and pollution, and mitigating and adapting to climate change, including
moving to a low carbon economy.


Strategic Policy SD1: Presumption in Favour of Sustainable Development

Development will be supported where it meets the following strategic objectives:
1. Progress towards Crawley’s commitment to being carbon neutral by 2050 and adapts
to climate change;
2. Complements Crawley’s character as a compact town within a countryside setting,
developed on a neighbourhood principle and maximises the use of sustainable travel;
3. Conserves and enhances the heritage of the borough;
4. Protects, enhances and creates opportunities for Crawley’s unique Green
5. Provides a safe and secure environment for its residents and visitors;
6. Provides for decent and affordable homes and meets the social and economic needs
of Crawley’s current and future population; and
7. Accords with the policies and objectives set out in this Plan unless material
considerations indicate otherwise.


Reasoned Justification:

3.2 Taken as a whole, the principles and policies set out in this Local Plan for Crawley
will deliver the sustainable development of the town and will guide development
proposals to meet the long-term vision as well as maximising short-term benefits. All
plans should be based upon and reflect the presumption in favour of sustainable
development, with clear policies that guide how the presumption should be applied
3.3 This must be achieved having regard to the limited availability of developable land in
Crawley, which is a result of the borough’s tight administrative borough boundary and
constraints including flooding and aircraft noise. This means that the Local Plan must
strike a considered balance between conflicting demands to meet Crawley’s
significant housing, employment, and open space needs in a sustainable manner. To
ensure this is the case, Policy SD1 provides the overarching principles on meeting
the presumption in favour of sustainable development.
3.4 In accordance with the NPPF, the presumption in favour of sustainable development
applies unless specific policies indicate development should be restricted. Those
sites with strongest weight against development22 will include land designated as
LOCAL GREEN SPACE, Area of Outstanding Natural Beauty, designated heritage assets
(including Listed Buildings, Conservation Areas, Scheduled Ancient Monuments and
non-designated heritage assets of archaeological interest which are demonstrably of
equivalent significance to scheduled monuments), locations at risk of flooding and
irreplaceable habitats, such as areas of Ancient Woodland and ancient and aged
. Other constraints which have been locally assessed within Crawley include
areas subject to unacceptable levels of noise, particularly from aircraft; historic parks
and gardens; Local Wildlife Sites; structural landscaping; and open space which has
not been identified as surplus to open space requirements. Development within these
locations will be considered carefully against the reasons for their designation and
will only be approved if mitigation measures can adequately reduce the negative
impacts of development.
3.5 To ensure development is truly sustainable and supports the needs of economic
growth within such a constrained and tightly drawn urban borough, it is essential for
Crawley to be considered in its wider geographical context, including its housing
market and travel to work areas, rather than restricted to its administrative
boundaries, and for continued cooperative working to ensure the most appropriate
balance is struck.


Enabling Healthy Lifestyles and Wellbeing

3.6 There is now a strong evidence base that our health is impacted by the environments
and places within which we live. Government planning policy is explicit that ‘planning
for health’, achieving healthy and safe places is a material consideration to enable
and support healthy lifestyles to address identified local health and wellbeing needs.
Creating and enabling healthy places and improving the wider determinants of health
can help to promote good health, better lifestyles, prevent poor health and have a
positive impact on reducing health inequalities. To aid understanding of the built and
natural environment and health, researchers24 have devised the Health Map (Figure
3). The map is focused on the role of neighbourhood and planning, and emphasises
the importance of the built and natural environment’s contribution to health and
wellbeing outcomes, in line with the socio-ecological approach to health (Orme et al.,

22 National Planning Policy Framework, paragraph 11 and footnote 6 (2019) MHCLG
23 National Planning Policy Framework, glossary definition “Irreplaceable habitat”, page 67-68 (2019) MHCLG
24 Barton and Grant (2006), drawing upon the work of Dahlgren and Whitehead (1991)
Fig 3: Barton and Grant Health Map

3.7 Therefore, planning for health involves thinking about the interrelated factors that
affect health, including social and psychological elements, such as wellbeing and
fulfilment. The wider determinants of health are conditions in which people are born,
grow, work, live and age, and the wider set of forces and systems shaping the
conditions of daily life. A healthy place is one that can contribute to the prevention of
ill health and provide the environmental conditions to support positive health and
3.8 When considering the health impact of individual developments, it is important that its
surroundings are taken into account as well as its intended purpose. This includes
looking at population health as a whole. It also involves the examination of population
groups, vulnerable communities and sensitive uses, such as residential care homes,
supported housing, schools, hospitals and health centres.
3.9 Public Health England has noted that “Some of the UK’s most pressing health
challenges – such as obesity, mental health issues, physical inactivity and the needs
of an ageing population – can all be influenced by the quality of our built and natural
environment”. The considerate design of spaces and places can help to promote
good health by providing:
 Healthy lifestyles: places to access good diet, nutrition, opportunities to
breastfeed, take part in physical activity minimise risk taking and addictive
behaviour such as gambling, alcohol and smoking.
Positive social and community influences on health: community cohesion,
community power, identity and local pride, community resilience, neighbourliness,
sense of belonging, community connectivity and inclusiveness, social networks
and support.
Good mental health and wellbeing: facilitating a sense of control, enabling
participation in the community and economic life, access to green open spaces
and water bodies, and accessibility to social opportunities.
 Safe and healthy living environmental conditions: air quality, attractiveness of
area, noise control, dementia friendly communities and homes, social inclusion,
community safety, accessibility, housing quality and tenure, home safety and
safety of public spaces, adaptable dwellings and high quality green space
accessible to all.
 Economic conditions that affect and promote health: employment
opportunities, availability of food and fuel, income, economic activity and good
working conditions such as those related to health and safety.
 Access and quality of services: access to leisure services, information
technology, medical and health services, education and training, public
amenities, shops and commercial services, sustainable transport (including
parking, public transport and active travel).
Positive macro-economic, environmental and sustainability factors:
biodiversity, mitigating climate change (i.e. flooding, heatwave), sustainable
development principles (integration; collaboration; involvement; long term
thinking; and prevention) and regeneration for example.


Strategic Policy SD2: Enabling Healthy Lifestyles and Wellbeing

New development must be designed to achieve healthy, inclusive and safe places, which
enable and support healthy lifestyles and address health and wellbeing needs in Crawley,
as identified in the Crawley Joint Strategic Needs Assessment.
In order to maximise opportunities to enable healthy lifestyles, new development must:
 Meet the principles of good urban design and support Crawley’s status as a
Dementia-Friendly Town, through ensuring legibility of layout, materials and design
(Policies CL2 and DD1);
 Meet the needs of all through the use of the highest standards of accessible and
inclusive design (Policy DD2);
Provide opportunities for open space, play and recreation (Policies OS1 – OS2);
 Prioritise the use of accessible and reliable sustainable transport and active travel
through providing greater levels of safe and attractive opportunities for active travel
(Policies OS3, ST1 – ST2);
 Be supported by, and not result in a loss of, necessary infrastructure provision
(Policies IN1 – IN2);
 Ensure proposals are safe for future site users and do not result in unacceptable
harmful impacts (Policies EP1 – EP6); and
Ensure proposals incorporate biodiversity and green infrastructure which enable
climate change resilience (Policies GI1 and GI2).
Major developments must set out how they address the requirements of Policy SD2 as
part of the planning application. In order to satisfy this policy requirement, a Health Impact
Assessment must be included with qualifying planning applications, as set out in the Local
List of Requirements, at the point of submission for validation purposes.


Reasoned Justification

3.10 National planning policy confirms that planning polices and decisions should aim to
achieve healthy, inclusive and safe places which: promote social interaction,
including opportunities for meetings between people who might not otherwise come
into contact with each other – for example through mixed-use developments, strong
neighbourhood centres, street layouts that allow for easy and safe pedestrian and
cycle connections within and between neighbourhoods, and active street frontages25
3.11 To provide the social, recreational and cultural facilities and services the community
needs, planning policies and decisions should:
 Plan positively for the provision and use of shared spaces, community facilities
(such as local shops, meeting places, sports venues, open space, cultural
buildings, public houses and places of worship) and other local services to
enhance the sustainability of communities and residential environments26;
 Take into account and support the delivery of local strategies to improve health,
social and cultural well-being for all sections of the community;
 Guard against the unnecessary loss of valued facilities and services, particularly
where this would reduce the community’s ability to meet its day-to day needs.
3.12 The Health and Social Care Act (2012) sets out local authorities’ new duties and
responsibilities for health improvement and health protection. The Act requires every
local authority to use the levers at its disposal to improve health and wellbeing.
Through the Sustainability Appraisal, the health impacts of the Local Plan are
assessed against the identified issues. The benefits and outcomes of the
implementation of the Plan will be monitored annually against these indicators
through the Authority’s Monitoring Report.
3.13 Planning for health involves thinking about the interrelated factors that affect health,
including social and psychological elements, such as wellbeing and fulfilment. The
wider determinants of health are conditions in which people are born, grow, work, live
and age, and the wider set of forces and systems shaping the conditions of daily life.
A healthy place is one that can contribute to the prevention of ill health and provide
the environmental conditions to support positive health and wellbeing.
3.14 The West Sussex Joint Strategic Needs Assessment (JSNA) “People and Places” for
Crawley (2019)27, highlighted the following characteristics to consider:
 There has been a 10% increase in residents since 2007, due both to more births
than deaths and inward migration;
 133,425 people were registered with Crawley CCG GP practices in 2017/18
(more than the 111,700 total residents within the borough);
 The resident population has a younger profile compared with England with 22%
aged 0-15 years and only 13% aged 65+ years, although the numbers are
 28% of the local population were from black and minority ethnic (BAME) groups
at the time of the last census (2011), higher than England;
 83.3% of the adult population are economically active (2017-2018) and the
borough has a very high ratio of private sector jobs to public sector jobs;
 Deaths (under 75 years) from cardiovascular disease have fallen over the last 10
years, although the rate of decline has slowed in recent years.


North Crawley Area Action Plan [GATWICK – ED]

3.18 613 hectares of land lies to the north of Crawley, between the town and Gatwick
Airport. Since 2003, Crawley Borough Council has been required by government
policy to safeguard much of this land from development in order to accommodate the
possible construction of an additional wide spaced runway and associated facilities.
This has placed significant constraint on the ability of Crawley to meets its
development needs. National policy for Aviation has now evolved with the
government’s decision to support the expansion of Heathrow Airport and, currently,
there no national evidence of need for further runway provision beyond
Heathrow. There is also no study or decision that, if a need is proven, it should be
met by an additional runway at Gatwick Airport. The Airport Masterplan is also
proposing significant growth through the use of its existing runways and states that it
is no longer actively pursuing plans for an additional runway. The government’s draft
Aviation Strategy, Aviation 2050, reiterates the NPPF’s requirement for the future
needs of airports and their surface access requirements to be considered when
developing local plans, where there is robust evidence. These issues are explained
in more detail in the Local Plan’s Gatwick Airport Chapter.
3.19 In order to ensure the potential future growth needs of the airport can be properly
considered alongside other development needs in Crawley, including those arising
from the expansion of the airport on its existing runways, the council commits to
producing an Area Action Plan (AAP) to address all needs in full and ensure airport
development is properly considered alongside other needs.
Strategic Policy SD3: North Crawley Area Action Plan
Land to the north of Crawley, to the south and east of Gatwick Airport, is designated for
the preparation of an Area Action Plan (AAP).
Work on the AAP will commence within three months of the adoption of the Local Plan.
The AAP will assess the needs for the future growth and operational needs of the airport
alongside other development needs arising in Crawley, including:
i. economic growth;
ii. housing;
iii. infrastructure (including a western link road, sustainable transport and education);
iv. community/recreation facilities; and
v. any other uses identified through the evidence gathering and consultation on the
Important heritage and environmental assets, including ancient woodland and Local
Wildlife Sites/Local Nature Reserves, will be protected and net gain for biodiversity will be
secured in accordance with the policies in this Local Plan and updated appropriately as
required through the AAP.
Consideration will be given to the character of the rural area and the importance of
maintaining a visual break between the edge of Crawley and Gatwick Airport.
Until the AAP is adopted, only minor extensions to existing buildings will be permitted in
the previously safeguarded area, amended to correspond to the Gatwick Airport
Masterplan 2019. In the current Area of Search for a Western Link Road, development
which would be incompatible with the future delivery of a full Crawley Western Link Road
will not be permitted. These areas are shown on the Local Plan Map. Countryside policies
also apply.
Minor extensions to Manor Royal will be permitted on the land outside the amended
safeguarded area if they don’t prejudice future comprehensive development within the
AAP area.


Planning applications for noise sensitive development will be considered on the basis of
Air Noise Map – Additional Runway – Summer Day – 2040 as shown at Plan 31 of the
Gatwick Airport Master Plan and in the Local Plan Noise Annex, unless otherwise
confirmed through the AAP once it is adopted.

Reasoned Justification

3.20 Historically a large area of land north of Crawley has been safeguarded for a
potential future second runway at Gatwick Airport. For a land constrained borough,
with high development needs this has posed significant challenges and the borough
has been increasingly reliant on neighbouring authorities to pick up unmet
development needs within areas outside of the borough’s administrative boundaries.
The adopted Local Plan 2015-2030, through Policy EC1, identified land to the north
of Manor Royal and south of the airport as an area of search, which could potentially
accommodate Crawley’s unmet business land needs were safeguarding to be lifted.
The council does not consider there is, at this time, robust evidence to justify the
continued safeguarding of land for a further runway at Gatwick, and in light of the
other significant needs arising which this land could support, commits to commencing
work on an AAP to determine the most appropriate use of this land for future
development needs rather than just protecting an extensive area for one use. The
indicative plans for a southern runway provided in the Gatwick Airport Masterplan
show a large area for surface car parking, indicating an inefficient use of valuable
land in a constrained borough with high development needs. A more consolidated
approach could potentially open up opportunities for other developments.
3.21 The commitment to producing an AAP for this area presents opportunities to support
the growth of airport if this can be justified with robust evidence of need, as well as
delivering other requirements. The AAP approach, rather than identifying allocations
in this Local Plan, is considered to be pragmatic. It allows for the principle of lifting


safeguarding to be considered first, through this Local Plan, and then allows greater
time for the growth needs of the Airport to be demonstrated by the airport operator
and any future protection of some or all of the land for airport purposes to be justified
alongside other development needs as part of the work on the AAP.
3.22 On this basis, this Local Plan still needs to apply the same protections of the
previous safeguarding policy to the area identified in the Gatwick Airport Masterplan
2019 until the AAP is finally adopted. This recognises that, if there is evidenced need
for a future southern runway at Gatwick, this is the only location it could be
delivered. Therefore, the amended previously safeguarded area identified on the
Local Plan Map will be protected against incompatible development which would add
constraints, add costs, or increase the complexity of the development of an additional
runway. The Airport Operator will continue to be consulted on all applications within
this area. Also, as the work on the AAP may still conclude there is a need to
safeguard land for a potential southern runway, it is important to ensure that, until the
AAP is adopted, noise sensitive development is not located in an area which could
become unacceptably noisy in the future due to air traffic movements from a
southern runway. The issue of land safeguarding for a future runway should be
distinguished from that of aerodrome safeguarding which considers the impact of
proposals on the operation of aircraft. Policy DD6 of this Local Plan covers
Aerodrome Safeguarding.
3.23 The Economic Growth Chapter explains the detail in relation to employment needs
emerging from the borough. Specifically, Policy EC1 sets out a justified approach to
planning for employment needs, and sets out the evidence of the potential for higher
levels of employment growth in an unconstrained scenario, with the market
preference for this within the Crawley/Gatwick area. The AAP will assess the most
appropriate, sustainable locations to accommodate future employment floorspace, in
a comprehensively planned manner, rather than in a piece-meal approach.
3.24 It is recognised that some areas of land immediately adjacent to Manor Royal lie
outside of the land identified for safeguarding by the Gatwick Airport Masterplan. The
Local Plan continues to take the same approach as the previous Local Plan in
allowing extensions to Manor Royal in these locations, but it is important that
consideration is now given to future potential opportunities within the wider AAP area
and therefore these developments will only be permitted where they don’t prejudice
the future proper planning and use of the land beyond these and where they continue
to respect their edge-of-settlement/countryside location (see Policy CL8 and Policy
EC1). Similarly, Policies CL8 and EC12 apply to the area north east of Forge Wood.
3.25 To enable economic and housing growth of the borough to continue without
significant harm to the existing infrastructure and to maximise opportunities for
sustainable travel, this Local Plan identifies an area of search for a Crawley western
link road (Policy ST4). This search area runs through the AAP land. Further work
needs to be established to secure the optimum line of the Crawley section of this
route. Possible alignments for the route may move further north should work on the
AAP demonstrate that the land is not required for future growth of the airport but, until
that is determined, development within the current search corridor which would be
incompatible with the delivery of the link road will not be permitted.
3.26 The AAP land includes a number of significant constraints including the land
previously identified for expansion at Gatwick, flooding, existing employment
buildings and land, biodiversity areas and recreation/sports uses. The AAP will allow
for these challenges to be balanced.
3.27 Preparing an AAP further acknowledges that much work is yet to be done to identify
areas of land suitable for housing. This has previously been extremely restricted due
to the noise contours associated with an additional southern runway. Therefore,


whether any land is available to meet some of the borough’s housing need, critically,
relies on understanding the appropriate noise contours to be applied in the future.
This is not currently possible until the extent of future growth at Gatwick has been
established. Other matters relating to housing will include the need for creating
3.28 Other infrastructure needs may also be able to be accommodated in the area,
including, if required, extension to Crawley Sewage Treatment Works and possibly a
secondary school if access needs and noise constraints can be met. Similarly, needs
for larger scale community and/or recreation uses may be able to be accommodated
in this area.
3.29 Whilst this land has been safeguarded from development, it does provide a number of
key planning roles. These include ensuring Crawley is maintained as a compact town
in a countryside setting, physical and visual linkages from the town to the country,
and a number of heritage assets and sites of nature conservation value, including
areas of ancient woodland and a Local Nature Reserve (LNR). These assets will
continue to be protected through this Local Plan and their importance and the
appropriate extent of protection will be considered as part of the AAP.



Built-Up Area Boundary.

The Key Issues

4.6 The Ministry of Housing, Communities & Local Government (MHCLG) recently
published the interim report from the Building Better, Building Beautiful Commission
(BBBBC). It identifies shortcomings in the government’s approach to planning and
design over the years. It is particularly relevant and timely when considering the
NPPF’s requirements and emphasis in regard to the efficient use of land and
increasing densities and the importance of how new development should maintain
and be grounded in an understanding and evaluation of each area’s defining local
character and history:

“Public disenchantment with so much of what has been built since the war cannot be
adequately captured in facts and numbers; it is a powerful and present feeling of
loss.. The reason for this failure…translating principle to built form. People fear that
the places they love will be spoiled, and the fear is very often justified”

“Instead of directing their energies towards ensuring that new developments will
enhance the places where they occur, they devote their energies instead to stopping
development, whatever form it might take”.

The identification and understanding of local character is the essential first design
and planning step, to altering and reversing these disillusioning ‘development’

“We need to deliver…at three scales: Beautiful buildings – considering windows,
height, space and materials; Beautiful places – the ‘spirit of place’, the nature of
streets, squares and parks; and Beautifully placed – sustainable settlement patterns
in the right place and sitting in the landscape.”



Landscape Character

4.10 Trees and areas of landscaping form a central part of Crawley’s New Town heritage.
As development pressures increase within the town and development land within the
urban area becomes scarce, it is critical that this land is protected and improved and
used to secure multiple benefits, wherever possible. Consideration should be given
to the key role of structural landscaping and strategic views in order to maintain or
improve the character of Crawley.

4.11 Crawley’s countryside is an extremely valuable leisure, amenity and environmental
asset for the community, which should be conserved and enhanced in a positive way.
This must be integrated with the need to achieve the Plan’s wider vision and
objectives to support sustainable development within the countryside.



Local Character and the Existing Rural and Urban Structure

4.21 An unprecedented number of densification, intensification and infill development
projects as well as new planned urban extensions are occurring across big cities and
towns throughout the UK, and Crawley is no exception. New urban characters are
being introduced near, alongside and within established neighbourhoods, at a fast
pace. Therefore, it is critical that the form of new development proposals are firstly
grounded in, and secondly dictated to/directed by, an understanding and evaluation
of each neighbourhood’s defining characteristics and overall character.
4.22 Character itself, whether in an urban or rural setting, is formed by an overlap and
layering of many individual elements which together create the generalised mental
picture of the exterior physical world that is held by an individual. Many catchall
definitions are used to define what people perceive as the character of an area,
labels such as sylvan, rural, suburban, Victorian, high street, leafy, terraced.
4.23 However, these definitions are not enough on their own to define the character of a
place. Behind these labels there is a less obvious physical skeleton, or rural/urban
structure, underpinning every area. This structure consists of tangible physical
elements (such as paths, landmarks, roads, an edge of woodland, views and vistas),
which together give a place its distinct form. In order to guide the form of new
development, these key components needs to be defined accurately, their
identification practically clarifies how and why people experience, appreciate and
enjoy a place. There are five established components of structure33….



The Form of New Development: translating principle to built form

4.38 “The planning system and development market can deliver beautiful places today.
But they do so far too rarely….The aim of future planning and development should be
place-making, remodelling existing settlements and delivering enough good,
beautiful, sustainable settlements in the right places… That beauty is not just what
buildings look like (though it does include this) but the wider ‘spirit of the place’, our
overall settlement patterns and their interaction with nature. This entails both the
beauty of our streets and squares, what makes them distinct and also the wider
patterns of how we live”
4.39 Both government policy and guidance highlight how the general public justifiably fear
that the places they love will be spoiled. The impact of development on the character
of an area is complex and it needs to be considered through varied lenses, areas
such as heritage, landscape and existing built form, rural and urban structure and key
elements of form such as movement.


4.70 To maximise multiple benefits of Structural Landscaping, in line with and
complementary to the character of the area, these can also be designed and
managed as species-rich habitats. Wild flower meadows and flower-rich habitats, in
particular, are crucial to supporting pollinators by providing good sources of nectar
and pollen throughout the summer and also shelter and nest sites. The council is
committed to securing such enhancements wherever possible.



Development Outside the Built-Up Area

4.76 It is important that a vibrant multifunctional landscape around Crawley is encouraged,
maximising its contribution to people’s quality of life, wellbeing, the natural
environment and the economy. The Crawley Borough Council Landscape Character
Assessment has been used to set the criteria based policies which encourage
proposals that respect the character and role of different areas. Policy EC12 of the
Local Plan supports appropriate small-scale economic development beyond the BuiltUp Area Boundary, where this would not undermine the intrinsic character and
beauty of the countryside. There may also be limited opportunities for appropriate
new residential development. Policy H3g sets out the criteria for urban extensions
beyond Crawley’s boundary, which would be within the countryside. Policy SD3
commits the council to the preparation of an AAP for North Crawley.
Strategic Policy CL8: Development Outside the Built-Up Area
To ensure that Crawley’s compact nature and attractive setting is maintained,
development should:
i. Be grouped where possible with existing buildings to minimise impact on visual
ii. Identify existing character and key assets, heritage, landscape and built forms, and
recognise the significant qualities of the area, including its grain, aspect, scale, natural
resources, views, sense of space and tranquillity to guide any new development;
iii. Identify the strategic context of such settings and environments of the town, and
respond intelligently to the underlying landscape and environmental systems and
iv. Maintain a loose-knit, low density rural character clearly differentiating it from
development within the urban area;
v. Be located to avoid the loss of important on-site views and off-site views towards
important landscape and heritage features, understanding how they function and how
they are experienced and perceived;
vi. Reflect local character, heritage and distinctiveness in terms of form, height, scale,
plot shape and size, elevations, roofline and pitch, overall colour, texture and
boundary treatment (walls, hedges, fences and gates). Where screening and existing
character allows, careful, unique modern new design could be considered;
vii. Minimise the impact of lighting to avoid blurring the distinction between urban and
rural areas and in areas which are intrinsically dark to avoid light pollution to the night
viii. Ensure buildings and any external hard surfacing, parking areas, access roads and
outdoor storage are not visually prominent in the landscape;
ix. Avoid generating an unacceptable level and/or frequency of noise in areas relatively
undisturbed by noise and valued for their recreational or amenity value;
x. Avoid generating traffic of a type or amount inappropriate to the rural roads;
xi. Ensure access to the countryside is maintained and enhanced from Crawley’s
neighbourhoods, in accordance with Policy OS3 and demonstrate how such areas can
be better experienced; and
xii. Avoid introducing a use which by virtue of its operation is not compatible with the
In addition to the above, all proposals must recognise the individual character and
distinctiveness, and the role of the landscape character area or edge in which it is
proposed as shown on the Local Plan Map, established by the Crawley Borough Council
Landscape Character Assessment, and set out below.
Certain types of development may alter one or more important elements that make up a
Character Area or Edge. This is acceptable if its overall character and role is not
compromised and measures are taken to limit impacts through mitigation and
enhancement where possible. This may be the strengthening of other elements of the
area’s character or general enhancement through increased biodiversity, green links and
other mitigation measures as detailed in the Landscape Character Assessment.
Proposals which alter the overall character of the area must demonstrate that the need for
the development clearly outweighs the impact on landscape character and is in
accordance with national and local policy. Mitigation and/or compensation will be sought
in such cases where this can be proven. Applicants are advised to consider the
enhancement opportunities identified in the Crawley Borough Landscape Character
North East Crawley High Woodland Fringes
Proposals which do not create, or are able to adequately mitigate, visual/noise intrusion
are generally supported. This area has an important role in maintaining the separation of
the distinct identities of Gatwick Airport, Crawley and Horley.
Upper Mole Farmlands Rural Fringe
Proposals which do not create, or are able to adequately mitigate, visual/noise intrusion
are generally supported. This area has an important role in maintaining the separation of
the distinct identity of Gatwick Airport from Crawley and the valuable recreational links
from the northern neighbourhoods of Crawley into the countryside.
Development in both of the areas above which lie within the North Crawley AAP area
must meet the criteria of Policy SD3 and meet criteria i-x of this policy in its relationship
with the surrounding countryside.

West of Ifield Rural Fringe
Proposals which respect this area of locally special rural fringe, its nature conservation
and recreation value, its positive relationship with the urban edge and links to the wider
countryside will be encouraged.

West of Gossops Green/Bewbush Rural Fringe
The green infrastructure along Bewbush Brook and Spruce Hill Brook is of high value and
should be protected and linked to green infrastructure in the new neighbourhood,
Kilnwood Vale and where other opportunities arise.
South of Broadfield into Buchan Hill Forest and Fringes
The green fingers and local nature reserve will be conserved as they provide existing
green infrastructure links with potential for improvement to accessing the countryside and
wildlife corridors. The area is valued for its quiet recreational opportunities which should
be maintained. Proposals should not conflict with the High Weald AONB Management
Plan objectives.
Tilgate/Worth Forest and Fringes
Proposals within Tilgate Country Park and Worth Conservation Area/Worth Way LWS
should conserve and enhance their high landscape and biodiversity value and potential
for improved green infrastructure links to other areas.
Where development is proposed close to, or within, the High Weald Area of Outstanding
Natural Beauty, it should be planned and designed in accordance with Policy CL9


Reasoned Justification

4.77 Beyond the Built-Up Area Boundary lays the urban/rural fringe which forms an
important landscape setting for the town. The nature, extent and spatial significance
offered by differing rural settings and features offer differing advantages to the overall
form, landscape and urban structure of Crawley. Certain features will be understood
in the context of the borough as a whole whilst others contribute to very local
environments. Rural fringe areas require a policy approach which respects their
unique character and role whilst also encouraging sustainable development which
can enhance access and interaction with the area from Crawley’s neighbourhoods.
To achieve this, a well-designed approach to the urban/rural fringe is required, which
relates development at the periphery to its rural setting, maintaining the character of
Crawley as a compact town with good access to the countryside. It is important to
ensure the rural fringe does not become incrementally more suburban in nature
which would conflict with the overarching principles on meeting the presumption in
favour of sustainable development (Policy SD1: Presumption in Favour of
Sustainable Development) and will be resisted. Urban extensions will be in the
countryside outside Crawley’s boundary and need to be properly planned to ensure
the important contribution of the rural landscape setting for Crawley’s
neighbourhoods is not lost. The visual, spatial and environmental aspects of their
landscape setting must be fully assessed and any development planned to protect
and enhance important aspects. This is covered in more detail in Policy H3g.


Heritage Assets

6.1 Crawley is best known as a post-war New Town. However, the territory covered by
the borough has produced evidence of human activity extending back over
thousands of years. The physical remains of this activity above and below ground
include assets of international, national and local importance, forming a link to a long,
complex and unique history, and a focus for identity, community and learning in the
context of the modern town.
6.2 Evidence of human activity recorded in Crawley includes local finds of Palaeolithic
(Old Stone Age) and Mesolithic (Middle Stone Age) tools. The emergence of more
complex forms of social organisation is signalled by finds and sites from the Later
Bronze and Iron Ages. Local evidence of the Wealden iron industry extends at least
as far back as the Roman period, as found at Broadfield and Goffs Park, and
includes later medieval and post-medieval sites at ASDA on Pegler Way, Ifield,
Worth and elsewhere. Exposed and tangible archaeological remains include iron ore
pits, as at the Hawth, a range of medieval moated sites, and a deserted medieval site
at Tinsley Green.
6.3 The present-day town is the successor of settlements established in the Anglo-Saxon
period. Ifield and Worth are mentioned in the Domesday Book of 1086 and Crawley
was the site of a market from 1203. These grew through the pre-industrial period,
with Crawley in particular benefiting from its position on the London-Brighton
highway. The coming of the railways in the 1840s promoted further development
around stations at Three Bridges and Crawley, which became the main focus of preNew Town growth.
6.4 An unprecedented transformation of the area was heralded in 1947 with Crawley’s
designation as one of eight New Towns selected to provide work and homes away
from the overcrowded and bomb-damaged capital. Rapid growth followed from the
1950s onwards, initially under the aegis of Crawley Development Corporation
working within the framework of Anthony Minoprio’s masterplan, and latterly under
the direction of a more regular system of local government.
6.5 Much of the historic fabric has been retained as the town has grown, resulting in a
borough with a rich and diverse array of heritage assets from Grade I listed
structures hundreds of years old to excellent examples of New Town architecture and
planning. These elements blend to form Crawley’s unique character61


Housing Provision

12.21 The Local Plan provides a supply of housing sites to support delivery towards
meeting the needs of present and future generations, whilst reflecting the physical
constraints of the borough and the other policy objectives within this Plan.
12.22 These constraints include Local Green Space, designated heritage assets (Listed
Buildings, Conservation Areas and Scheduled Monuments), Local Wildlife Sites,
ancient woodland, structural landscaping, possible airport expansion/aircraft noise,
and open space and floodplains. These constraints, together with the tight
relationship between the Built-Up Area Boundary and the borough’s administrative
boundary, significantly limit capacity. The exception to this are the potential
opportunities which may be found for higher density schemes within a greater mixed
use town centre.
12.23 It is, therefore, recognised that continued cross-boundary working to understand the
nature of the wider housing market area is essential to ensure that housing needs
are being met in an appropriate and functional manner. There is already a long established means of working through numerous joint evidence base documents, a
joint Development Plan Document for the West of Bewbush neighbourhood (with
Horsham District Council), and the Gatwick Diamond Local Strategic Statement and
Memorandum of Understanding.
Strategic Policy H1: Housing Provision
The council will positively consider proposals for the provision of housing to meet local
housing needs, taking a pro-active approach to identifying suitable sites for housing
development and working to overcome constraints wherever possible, whilst ensuring
against detrimental town-cramming or unacceptable impacts on the planned character of
the existing neighbourhoods or on residential amenity.
Proposals that result in a net loss of dwellings will be resisted.
All reasonable opportunities will be considered including: brownfield sites; surplus green
space; town centre living; and opportunities on the edge of Crawley, where these are
consistent with the other policies and proposals in this Local Plan and the principle of
sustainable development.


Housing, Biodiversity and Heritage Site

 Land east of Balcombe Road/Street Hill, Pound Hill (deliverable) 15 dwellings. The
design and layout of the development of this site must:
i. respect its setting outside the built up area and the rural character of the Worth
Conservation Area;
ii. concentrate the residential element and associated infrastructure towards the least
sensitive areas, where possible, and to be located within the southern section of
the housing, biodiversity and heritage site;
iii. reflect, enhance and ensure no significant harm to the locally designated historic
iv. allow a suitable unbuilt margin around the archaeologically sensitive Moat;
v. avoid harm to the species-rich meadow grassland which contributes to the Local
Wildlife Sites (LWS);
vi. maintain the woodland vegetation buffer between the development and the church,
to retain the historic significance of the context of Worth Church; and
vii. be accompanied by a long-term commitment to the ecological enhancement and
positive management of the remainder of the LWS (excluding the ponds and
woodland in the centre and north-east in separate ownership) for the benefit of
Detailed and up-to-date ecological and archaeological assessments must be carried out.
Where impacts cannot be avoided adequate mitigation and compensation measures will
be provided to offset any harm caused to the site’s important assets.


Housing, Biodiversity and Heritage Site

12.43 Land east of Balcombe Road/Street Hill has a number of heritage and environmental
constraints which must be carefully considered and addressed through the design
and layout of a development scheme. These include (but are not limited to):
i. Forming part of the historic countryside setting of the Grade I listed Church;
ii. Its allocation within the Worth Conservation Area;
iii. Its Local Wildlife Site designation (with species-rich meadow grassland as its
important ecological attribute);
iv. Containing an archaeological sensitive asset: the Moat;
v. Forming part of an Historic Park and Garden;
vi. Being located outside the Built-Up Area Boundary of the town.
12.44 To ensure an appropriate balance between the need for housing and the important
heritage and environmental assets and characteristics of the site, a maximum
capacity of 15 dwellings is considered likely to be appropriate, subject to careful
layout and design which clearly addresses the constraints associated with the site,
including those covered by other policies in this Local Plan and national legislation
and policy, and which result in a high quality, sensitive scheme. The maximum
capacity figure should not be considered a “target” at the expense of meeting policy
and design expectations.


Reasoned Justification
12.69 Policies set out in the Wellbeing and Communities (Character, Landscape and
Development Form; Design and Development Requirements; and Open Space,
Sport and Recreation) and Environmental Sustainability (Green Infrastructure and
Biodiversity and Environmental Protection) Sections are particularly relevant when
considering applications in relation to housing on existing open space sites. In
relation to flooding, Policy EP1 will apply to development of open spaces. Wherever
possible, further reduction of surface water runoff beyond the greenfield runoff rate
levels, and additional storage introduced as part of any development proposal,
should be sought in order to offer a greater reduction in runoff rates from new



Urban Extensions: ‘At Crawley’

12.70 Over recent years, increasing numbers of houses are being built on the peripheries
of Crawley’s urban and administrative boundaries. Whilst, in some cases, this has
been promoted through joint planning between Crawley and neighbouring authorities
to come forward as comprehensive new neighbourhoods, such as Kilnwood Vale
(2,650 new dwellings104), in most other cases this has come forward in piecemeal
individual developments of between 30 and 600 new dwellings at a time, tacked on to
the existing urban infrastructure.
12.71 The Local Plan acknowledges that other potential urban extensions to Crawley
outside its administrative area could be explored in the future in order to meet the
arising housing need of the borough. This work will need to test whether this
approach is agreed as a sustainable location in the context of the wider Housing
Market Area and travel to work area and whether the existing infrastructure and
environmental constraints can be resolved105. In these cases, developments should
be laid out and designed to be reflective of their location as part of Crawley and
should not result in harm to the setting of the Masterplanned New Town

or result in urban sprawl or unplanned merging of settlements. They should protect the setting of
Crawley’s existing neighbourhoods at the edge of the countryside.

The shared evidence base including the Strategic Housing Market Assessment and Economic
Growth Assessment should be referred to, and all infrastructure impacts should be
considered cumulatively.
12.72 Well planned urban extensions which provide comprehensive, sustainable new
neighbourhoods with local facilities and services, relate well to their rural landscape
character and protect the setting of Crawley’s neighbourhoods could form an
important way to meet Crawley’s housing needs. Whilst these developments will be
outside Crawley’s boundary, the criteria set out in the Policy will be used to inform
discussions with neighbouring authorities and potential developers, and responses to
emerging policies and planning applications. Where appropriate, Joint Area Action
Plans would provide the most robust way to ensure Crawley’s needs and concerns
are fully addressed.

Strategic Policy H3g: Urban Extensions

Housing development through urban extensions on or close to Crawley’s administrative
borough boundaries will be supported by Crawley Borough Council where it can be shown
i. Development is to come forward through a Plan-Led process, supported by clear
cross-boundary and site-specific Local Plan policies, including scoping the
potential for the preparation, development and adoption of Joint Area Action Plans
in partnership with the relevant neighbouring authority;
ii. The proposals are supported by a comprehensive Masterplan agreed by the
relevant authorities (including the county council), in line with the expectations of
Policies CL2 and DD1;
iii. Cumulative infrastructure needs are clearly identified and programmed for delivery
in coordination with new development, and the proposal would not result in severe
cumulative impacts of the development for existing residents in Crawley, including
in terms of traffic and transport, flooding and drainage, air quality, town centre and
social facilities;
iv. If development is proposed to the western side of Crawley, the scoping, design
and delivery of the comprehensive Western Link Road (connecting from the A264
to the A23, north of County Oak, Policy ST4) should be agreed and provided prior to the completion of properties unless otherwise agreed by the three local
authorities: Horsham District, Crawley Borough and West Sussex County

104 The Joint Area Action Plan allocated this neighbourhood for 2,500 new dwellings. The additional 150
dwellings is due to planning permissions granted to change the initial use of the land within the allocation
105 Consultation Draft Crawley Borough Local Plan Review, paragraph 2.32, Policy H1 and paragraph 12.11
(2019) CBC

v. Crawley’s character as a compact town within a countryside setting, developed on
a neighbourhood principle which maximises the use of sustainable transport is
maintained – other relevant policy in this regard includes Policy CL4;
vi. The design of the urban form and infrastructure is of high quality design which is
not unnecessarily prominent in the existing landscape setting;
vii. Developments are designed and progressed as comprehensive neighbourhoods
rather than incremental ad hoc development;
viii. Neighbourhood centres containing local facilities and services are provided in
order to meet the day-to-day needs of residents;
ix. The development helps address unmet development needs arising from Crawley,
including in relation to housing mix, type, tenure and affordability (including
meeting the 40% affordable housing levels and agreements in relation to the
nomination rights for those on the Crawley housing register); complementary
employment and economic growth needs; social, education and health needs; and
strategic recreation and leisure requirements;
x. Linkages are maintained from Crawley’s neighbourhoods through new
development to the countryside beyond (both in terms of active transport and
visual links) as well as prioritising sustainable modes of transport links into existing
Crawley neighbourhoods and the town centre, making car journeys a longer, more
circuitous option;
xi. A landscape character, setting and heritage appraisal has been undertaken which:
a. identifies the scale, extent and spatial characteristics of the existing
landscape structure and grain, including natural and man-made features,
field patterns, views, landscape structure, tranquillity and sense of space or
enclosure, and provides an understanding of how they are experienced,
used and perceived; and this
b. has led to an assessment of the impact of the development on the
landscape character, setting and heritage of the area, and the setting of
Crawley’s neighbourhoods and development is planned to ensure the key
landscape features, character areas, areas of tranquillity and settings are
protected, and the way they can be experienced is enhanced.
xii. Development has been designed and planned to carefully address both its
connections to existing Crawley neighbourhoods as well as the wider countryside
beyond, see Policies CL4 and CL5, providing defensible boundaries which both
prevents inappropriate merging of settlements or the effects of urban sprawl and
ensures the careful stitching together of existing and new built form where
xiii. Ancient woodland or veteran trees would not be damaged or lost and an
appropriate buffer, in accordance with Policy GI3 and national guidance, is
provided between any such trees and the edge of the development’s construction.
Any TPO protected trees should be retained where possible and measures to
avoid damage and root compaction should be implemented. Where the loss of
existing trees is unavoidable, appropriate replacement trees are to be provided;
xiv. Development must incorporate strategic Green Infrastructure throughout, providing
ecological linkages, in particular to support pollination, and result in a Net Gain to


Reasoned Justification

12.73 Urban extensions should meet their own infrastructure needs on site to serve their
new residents. It is inevitable that these residents will also access larger scale
existing facilities in Crawley, including the town centre, leisure facilities and transport
networks. These will also be affected by development within Crawley and it is
important that cumulative impacts are assessed and developments fund
improvements to ensure there is no adverse impact on Crawley’s residents.
12.74 The need for a Western Link Road for Crawley has been recognised but it has not
yet come forward despite the development of Kilnwood Vale. If further urban
extensions are proposed to the west of Crawley the route, design and delivery
options for this road will need to be addressed. Policy ST4 provides more details.
12.75 In order to encourage the use of sustainable forms of transport whilst maintain
access into the countryside from Crawley, road linkages into Crawley should be more
circuitous, with more direct public transport, cycling and walking routes linking into
Crawley’s neighbourhoods.
12.76 Whilst located within Mid Sussex or Horsham Districts, any urban extension on the
edge of Crawley should be meeting the unmet housing needs arising from Crawley,
and should therefore meet Crawley’s specific needs for affordable housing [40% – Ed], housing
mix, type, and tenure. The scale of urban extensions could also provide the
opportunity to meet unmet employment needs, or infrastructure requirements such as
education and health, and could provide strategic leisure facilities serving the wider
12.77 New development, by its very nature, will always have a significant impact on the
sense of place, space and open setting of an area, both perceived and tangible.
Careful analysis is therefore required to assess whether certain elements of
landscape structure, form, or character are a major component of or contributor to an
established, recognised and enjoyed rural landscape setting [building on the golf club/deer park land?!] Not all areas have the
same capacity to accommodate change without harm to the landscape setting. For
example, where wide tracts of non-enclosed open fields or grassland exist, there is
very limited capacity for change to the rural setting without impacting on the
character of the area, and the setting of the areas adjacent to it. The proportion,
scale and extent of these areas provides a sense of space and far reaching and
expansive vistas. They provide a perceived and real sense of tranquillity due to the
extensive absence of buildings and human presence and are important close to
Crawley where such areas are very limited. In contrast, areas where the setting is
characterised by woodlands or enclosed country lanes or hedgerow corridors provide
contained views and a sense of enclosure.
12.78 Within the new development, important trees and ancient woodland should be
appropriately protected and biodiversity should be enhanced through the provision of
linked on site green infrastructure.


Strategic Policy H5: Affordable Housing

Affordable Housing
40% affordable housing will be required from all residential developments.


Environmental Sustainability

Protecting the Environment: Sustainability

By 2035, significant progress will have been made towards Crawley becoming a carbon
neutral town. Active travel and public transport will be significantly improved and supported
by a road network that prioritises sustainable transport modes. Electric Vehicles will be
promoted along with, and through, e-car clubs. A sustainable road network will be
complemented by a good public transport system, giving people choice about how they
travel. As a modern town, the technological and communication infrastructure will be in place
to ensure residents and businesses have the support needed to develop and grow.
Conserving natural resources to support future growth will be vital to the longevity of the
town. Air, noise and water pollution will be reduced. The borough will prepare for the
increasing effects of climate change, through adaptation measures including lower water
usage standards and delivering a net gain in biodiversity. Losses to protected and priority
species and habitats will have been avoided and the delivery of vital ecosystem services,
including pollination, flood alleviation and carbon capture, will have been enhanced in order
to facilitate a sustainable and resilient future.


Green Infrastructure & Biodiversity

14.1 Crawley’s natural environment is critical for wildlife conservation, adapting to and
mitigating the effects of climate change as well as being of great importance to the
health and wellbeing of the people who live, work and visit Crawley.
14.2 Throughout the borough there is a wide range of sites important for nature
conservation and biodiversity, including extensive areas of woodland, local nature
reserves, public parks and smaller areas within the neighbourhoods. This network of
green spaces support natural processes, such as flood mitigation and carbon capture
and supports the health and quality of life of the population. Crawley’s waterways
also have an important biodiversity role, albeit that many are culverted underneath
the urban area.


Strategic Policy GI1: Green Infrastructure

Any growing urban area will place additional stress on the natural environment, including
the aquatic environment. Crawley’s multi-functional green infrastructure network will be
conserved and enhanced through the following measures:
i. Development which protects and enhances green infrastructure will be supported;
ii. Development proposals should take a positive approach to designing green
infrastructure, utilising the council’s supplementary planning documents to integrate
and enhance the green infrastructure network;
iii. Proposals which reduce, block or harm the functions of green infrastructure should
be avoided. Any loss will be required to be adequately justified, minimised, mitigate
against any loss or impact or as a last resort compensate to ensure the integrity of
the green and blue infrastructure network is maintained;
iv. The strategic green infrastructure network is afforded the highest protection due to
its high value from existing or identified potential multiple functions, for example as
recreation, routeways, access to the countryside, wildlife and climate mitigation;
v. Proposals should maximise the opportunity to maintain and extend green
infrastructure links to form a multi-functional network of open space, providing
opportunities for walking and cycling, and connecting to the urban/rural fringe and
the wider countryside beyond;
vi. Cross Boundary matters relating to Green Infrastructure should be considered and
incorporated at the early stage of an application;
vii. Large proposals will be required to provide new and/or create links to green
infrastructure as well as take into consideration the use of SuDS and methods that
incorporate blue infrastructure into development designs to improve the visual
amenity of the development, to account for Policy EP1 and to aid in reducing
surface water run-off.
viii. Householder developments and small non-residential extensions should take into
account Policy EP2 and innovative solutions that incorporate green and blue
infrastructure into designs at an early stage.

113 National Planning Policy Framework, para. 91c (2019) MHCLG
114 Dementia and Town Planning RTPI Practice Advice 2017, page 4 (2017) RTPI
ix. Where possible, Natural England’s Accessible Natural Green Space Standard
recommendations and the Woodland Trust’s Woodland Access Standard should be
followed in relation to consideration of location of accessible natural green space
and woodland and, as a minimum, seek to meet the Crawley local standards set out
in the Open Space, Sport and Recreation Study.
Reasoned Justification
14.11 Plans should take a strategic approach to maintaining and enhancing networks of
habitats and green infrastructure and plan for the enhancement of natural capital at a
catchment or landscape scale across local authority boundaries115
14.12 Proposals for development will increase pressures on the borough’s landscapes and
green spaces, presenting opportunities for enhancing and extending Crawley’s green
infrastructure. For the town to develop and grow in a sustainable manner, it is
important to ensure that green infrastructure is embedded in the planning process at
the earliest stage.
14.13 Green infrastructure should not just be considered as an adjunct to new
development. Connected networks of green spaces around new development should
be treated as integral to the planning and design process conscious of its place
within wider green infrastructure networks. This is assisted by an integrated review of
existing green infrastructure functions (biodiversity, flood management, rights of way,
open space, etc.). The Green Infrastructure Study (2016) identifies deficiencies and
need in relation to future growth and the desires of the town’s residents to determine
where improvement should be focused. An Ecological Services study has been
undertaken for Crawley, which identifies the opportunities of Crawley’s Green
Infrastructure to meet a wide range of positive functions, including air quality, noise
mitigation and ecological connectivity. This baseline evidence will be used to
consider opportunities for improving and extending these functions through new
landscaping and open space provision through new development schemes and to
assess the cumulative and wider impact of development proposals on the Green
Infrastructure network.
14.14 The NPPF requires local authorities to plan strategic development considering the
impacts on existing infrastructure and the need for new infrastructure to service that
development and also to contribute to and enhance the natural and local
environment. The Local Plan evidence base, including consultation responses,
provides a clear message that Crawley’s green infrastructure is fundamental to
residents’ quality of life and the wider environment. The Green Infrastructure policy
and design, landscape, open space and biodiversity policies seek to reflect that
14.15 Through a range of Local Plan policies, the council will seek to achieve the provision,
retention and/or enhancement of the specific functions of green infrastructure:
a. Publicly accessible open space including formal sports facilities and informal
amenity space;
b. The High Weald Area of Outstanding Natural Beauty;
c. Beyond the built up area where landscape character areas have been defined;
d. Value of existing soft landscaping – character and appearance, structure,
screening or softening;
e. Requirements of development – amenity spaces including private gardens,
landscape schemes, street trees, green roofs and walls and links to and between
areas of public open space and accessible countryside;

115 National Planning Policy Framework, para. 171 (2019) MHCLG
f. Areas of biodiversity value such as Local Wildlife Sites, Local Nature Reserves,
adjacent SSSIs, Biodiversity Opportunity Areas and Ancient Woodland;
g. Waterways and water bodies;
h. Heritage Assets;
i. Opportunities to meet open space, sport and recreation needs;
j. Green spaces for flood storage, conveyance, and SuDS.
14.16 Natural England’s Accessible Natural Green Space Standards116 recommend that all
people should have accessible natural green space:
– Of at least two hectares in size, no more than 300m (five minutes’ walk) from
– At least one accessible 20-hectare site within 2km of home.
– One accessible 100-hectare site within 5km of home.
– One accessible 500-hectare site within 10km of home.
– A minimum of one hectare of statutory local nature reserves per 1,000 people.
– That no person should live more than 500m from at least one area of accessible
woodland of no less than 2ha in size.
– That there should also be at least one area of accessible woodland of no less
than 20ha within 4km (8km round trip) of people’s homes.
14.17 The Woodland Trust’s Woodland Access Standard117 aspires that:
– No person should live more than 500m from at least one area of accessible
woodland of no less than 2ha in size; and
– There should also be at least one area of accessible woodland of no less than
20ha within 4km (8km round trip) of people’s homes.
14.18 Ideally, both standards would be met. However, where it is not possible to meet the
500m threshold, for example in urban areas where there is a lack of available land,
then the 4km threshold should be the minimum provided.
14.19 Policy GI3 sets out the policy position in relation to development which is close to, or
may affect, ancient woodland and/or veteran trees.
14.20 The council’s Green Infrastructure SPD and Planning and Climate Change SPD
provides further guidance to help applicants make successful applications and to aid
the delivery of green infrastructure where required.
Biodiversity Net Gain
14.21 Crawley Borough Council is committed to halting the overall decline in biodiversity by
ensuring that development minimises impacts on biodiversity and provides net gains
including establishing coherent ecological networks that are more resilient to current
and future pressures.
14.22 Through the 25 Year Environment Plan (2018), the government is introducing a “net
gain” principle into statutory policy. In assessing progress, a baseline needs to be
set, and metrics and natural capital accounts developed to record progress so that
accountability is embedded into the planning system. Natural capital is recognised to
be at least as important as physical and human capital in producing economic
outputs and hence economic well-being. In 2011, the government committed to
working with the Office for National Statistics (ONS) and Defra to incorporate natural
capital into the UK Environmental Accounts by 2020.

116 Accessible Natural Green Space Standards in Town and Cities (2011) Natural England
117 Space for People, Targeting Action for Woodland Access (2017) Woodland Trust

Strategic Policy GI2: Biodiversity and Net Gain

All development proposals will be expected to incorporate features to encourage
biodiversity and enhance existing features of nature conservation value within and around
the development. Development will be required to demonstrate how it will meet the
government’s requirement for securing a ‘net gain’ in biodiversity. As a minimum, all
development proposals will need to achieve a net gain for biodiversity in accordance with
government expectations118 currently a 10% increase in habitat value for wildlife
compared with the pre-development baseline.
In the first instance, net gain for biodiversity will be expected to achieve a minimum 10%
net increase on site. Only where it is clearly justified this is not practicable to achieve, and
where it is shown to have been considered and sought from the early stages of the design
and layout of the development, will off-site provision, in the form of equivalent financial
contributions, be agreed.
Applications should include consideration to securing benefits for the purposes of
pollination and biodiversity as part of their on-site landscaping schemes. This can include
consideration for green roofs and green walls, where soft landscaping at ground level is
limited. Discussions with Gatwick Airport Limited in relation to planting and management
to minimise, as far as possible, the risk of bird strike should be held at an early stage of
landscape design, in accordance with Policy DD6.
Proposals which would result in significant harm to biodiversity will be refused unless:
i. this can be avoided by locating on an alternative site with less harmful impact; or
ii. the harm can be adequately mitigated, or, as a last resort, compensated for.
Compensation should consider losses of all the benefits provided by the natural
Development whose primary objective is to conserve or enhance biodiversity will be
supported; while opportunities to incorporate biodiversity improvements in and around
developments will be encouraged, especially where this can secure measurable net gains
for biodiversity.
Developers may be required to commit to providing an Ecological Management
Plan/Biodiversity Offset Management Plan for the development site. This will usually
apply to larger developments or where a development site is close to an LWS. The
developer and/or site manager must ensure the relevant management plan is handed
over and explained to any maintenance company or staff responsible for maintaining
landscaping and/or gardens and buildings. A simplified version should also be provided
for householders and other occupiers, explaining how biodiversity is being protected and
encouraged on the site. This commitment will form part of the obligations on a planning
permission and will be secured by way of a S106 legal agreement and/or planning

Reasoned Justification

14.23 Much biodiversity is outside designated areas. It is important that planning decisions
take into account biodiversity by ensuring that decisions are based on sufficient
information. The Sussex Biodiversity Record Centre data will be used to determine
whether habitats or species of principal importance may be present, for which an
Ecological Survey will be required. Where planning applications are considered to
have an impact on wildlife, advice will be sought from relevant national and local
organisations. There may be a cross-over with on-site tree planting and tree/
landscape habitat contributions for each new dwelling (Policy DD4). However,

118 Government’s Environmental Bill (2019) Defra
replacement trees (Policy DD5) will not count towards the net gain; indeed they may
involve a net loss of biodiversity due to the loss of important habitats provided by
mature trees, and the potential for new trees to fail.
14.24 The government’s proposal within the 25 Year Environment Plan to introduce a net
environmental gain requirement for new development offers a potential source of
long-term investment in the delivery of an improved natural environment. Planning
policies and decisions should encourage multiple benefits from both urban and rural
land, including through mixed-use schemes and taking opportunities to achieve net
environmental gains – such as developments that would enable new habitat creation
or improve public access to the countryside.

14.25 The government’s National Pollinator Strategy for England (2014) sets out a 10 year
plan to help pollinating insects survive and thrive across England. There are at least
1500 species of insect pollinators in the UK. Pollinators face many pressures that
with good management can be mitigated against including:
 Habitat loss;
 Pests and diseases;
 Extreme weather;
 Competition from invasive species;
 Climate change; and
 Use of some pesticides.
At a local and county level, advice and recommendations may include future West
Sussex action plans or strategies, those produced by or on behalf of the Sussex
Biodiversity Record Centre and those prepared by Crawley Borough Council.
Furthermore, the Local Nature Partnerships (LNPs) introduced through the Natural
Environment White Paper (2014) aim to bring together local people and
organisations to get the most out of the natural environment. LNPs are partnerships
of a broad range of local organisations, businesses and people who aim to help bring
about improvements in their local natural environment. The council will work closely
with the LNP covering Crawley to prioritise resources towards the improvements and
habitat creation which offers the most benefits for Crawley and the Sussex High
14.26 Detailed ecological assessments based on the latest ecological records and up to
date surveys must be carried out on all new developments and the impacts on the
loss of biodiversity must be assessed. Proposals need to be put forward that will
either result in gains to biodiversity being proposed so that developments will deliver
an overall net gain in biodiversity, or mitigation proposals (including where involving
another site) need to be put forward that will achieve a net gain in biodiversity.
Moreover, the proposals need to ensure that the net gains in biodiversity will be
permanent, all other things being equal. For example, if planting to increase pollinator
plants is proposed, it is essential that plans are included to maintain and renew the
plants over the long term.
14.27 Simple definitions of environmental loss as being just the impact upon wild species or
biodiversity are inadequate. Development can generate multiple impacts either
directly on environmental assets or mediated through environmental impacts: wild
species, recreation and related physical and mental health benefits; water quality and
flooding; air pollution emissions and GHG, etc. it is the loss of benefit value
generated by development which should be compensated for. Those whose activities
give rise to the environmental damage should pay the associated costs of
14.28 In order to calculate the net gain in biodiversity required by new development, it will
be necessary to quantify the financial resources needed for the maintenance,
restoration and enhancement of ecosystems and natural capital in order to deliver
multiple objectives for biodiversity, landscape, the historic environment, water, soil,
climate, air quality, flood management and other ecosystem services. For example,
restoration refers to the restoring of a site to the topographic shape, hydrologic
function and plant communities that existed in historical times before disturbance by
man. This practice can be expensive and generally requires detailed knowledge and
regular management. However, the Local Plan Planning Obligations Annex will be
updated accordingly on the emerging national and local guidance becomes finalised.
Biodiversity Sites
14.29 To protect and enhance biodiversity and geodiversity, it is important to gain a
thorough understanding of habitats and ecological networks. Developers can support
an in-depth understanding of local biodiversity sites by:
a. Identifying, mapping and safeguarding components of local wildlife-rich habitats
and wider ecological networks, including the hierarchy of international, national,
and locally designated sites of importance for biodiversity; wildlife corridors and
stepping stones that connect them; and areas identified by national and local
partnerships for habitat management, enhancement, restoration or creation; and
b. Promoting the conservation, restoration and enhancement of priority habitats,
ecological networks and the protection and recovery of priority species; and
identifying and pursuing opportunities for securing measurable net gains for

Strategic Policy GI3: Biodiversity Sites

Up-to-date habitat and species surveys and associated reports will be required to
accompany planning applications which may affect the areas listed below or sites
showing likely ecological value based on past ecological surveys.
Hierarchy of Biodiversity Sites
To ensure a net gain in biodiversity, the following areas and their supporting and
connecting habitat will be conserved and enhanced and the council will support their
designation and management through Management Plans:
1. Nationally designated sites:
 Sites of Special Scientific Interest (SSSI)
SSSI will receive the highest level of protection for habitat conservation value in line with
national legislation, policy and guidance.
2. National Planning Policy Framework Sites:
 Ancient Woodland, and aged or veteran trees
Development resulting in the loss or deterioration of irreplaceable habitats (such as
ancient woodland and ancient or veteran trees) should be refused, unless there are
wholly exceptional reasons and a suitable compensation strategy exists. A buffer zone
between development and ancient woodland will be required in line with Natural England
Standing Advice.
3. Locally designated sites, and habitats and species outside designated sites:
 Local Nature Reserves (LNR);
 Local Wildlife Sites (LWS);
 Nature Improvement Areas;
 Habitats of Principle Importance identified in S41 of the Natural Environment and
Rural Communities Act 2006 or Biodiversity Action Plans;
 Biodiversity Opportunity Areas;
 Where Protected Species are present;
 Where Species of Principal Importance are present, as identified in S41 of the
Natural Environment and Rural Communities Act 2006.

Reasoned Justification

14.30 As a public body, Crawley Borough Council has a duty to have regard to the
conservation of biodiversity through the proper exercising of all its functions. This is a
statutory function set out in Section 40 of the Natural Environment and Rural
Communities Act, 2006.
14.31 This means that the consideration of biodiversity must be embedded in planning
policy which should be making a contribution to the commitments set out in
Biodiversity 2020: A Strategy for England’s Wildlife and Ecosystems Services. The
ambition is to halt overall loss of England’s biodiversity by 2020 and in the longer
term, move from a position of net biodiversity loss to net gain.
14.32 To support this ambition the Local Plan Map identifies components of Crawley’s
ecological network. This ensures that biodiversity is considered, from protection of
habitats and species to identifying opportunities to enhance biodiversity.
14.33 The council will continue to work collaboratively with partners including Local Nature
Partnerships to protect and improve the natural environment based on locally
identified priorities and evidence. The Sussex Biodiversity Partnership works together
towards achieving biodiversity targets. Biodiversity Opportunity Areas have been
identified throughout the south east and are the regional priority areas of opportunity
for restoration and creation of Biodiversity Action Plan (BAP) habitats. Within the
borough, this includes the Urban Habitat Action Plan (HAP) which highlights the rich
biodiversity in Sussex’s urban areas as well as the Deciduous Woodland, Lowland
Heathland, and Lowland Meadows HAPs.
14.34 Ancient Woodlands are valuable as a biodiversity resource for their diversity of
species and longevity as woodland. Areas of ancient woodland are identified on the
Local Plan Map and protected by national policy. As ancient woodland and ancient or
veteran trees are irreplaceable, discussions over possible compensation should not
form part of the assessment to determine whether the exceptional benefits of the
development proposal outweigh the loss. The presumption in favour of sustainable
development does not apply where the plan or project is likely to have a significant
effect on a habitat site (either alone or in combination with other plans or projects),
unless an appropriate assessment has concluded that the plan or project will not
adversely affect the integrity of the habitat site119
. A minimum 15 metre buffer should
be maintained between a development and the ancient woodland (as advised by a
full ecological survey), including through the construction phase, unless the applicant
can demonstrate very clearly how a smaller buffer would suffice, in accordance with
the Natural England Standing Advice. A larger buffer may be required for particularly
significant engineering operations, or for after-uses that generate significant
14.35 Ancient wood pasture and historic parkland should receive the same consideration
as other forms of ancient woodland. The protection of the whole habitat is necessary
even though tree cover may be comparatively sparse. Development on open space

119 National Planning Policy Framework, para. 177 (2019) MHCLG
between trees in an area of ancient wood pasture or historic parkland should not be
14.36 Where it is deemed that there is going to be unavoidable residual damage or loss to
ancient woodland, the measures taken to compensate for this must be of a scale and
quality commensurate with the loss of this irreplaceable habitat. Where ancient
woodland is to be replaced by new woodland, this should aim to create 30 hectares
of new woodland for every hectare lost.
14.37 The borough has 12 designated Local Wildlife Sites, formerly known as Sites of
Nature Conservation Importance (SNCIs) covering 329.79 hectares in total. Eight
sites are borough-owned while four are privately-owned and managed. As of 2018,
ancient woodland covers 197.68 ha (4.40%) of the borough, Deciduous woodland
478.56 ha (10.64%), Ghyll woodland 25.49 ha (0.57%), lowland heathland 0.83 ha
(0.02%), traditional orchard 0.32 ha (0.01%) and wood-pasture & parkland covers
41.74 ha (0.93%).
Local Green Space
14.38 The NPPF empowers local communities to promote the designation of green areas of
particular importance for special protection as a Local Green Space.

Strategic Policy GI4: Local Green Space

The following area is designated as Local Green Space:

Ifield Brook Meadows and Rusper Road Playing Fields

This area is designated due to its value to the local community and local significance in its
function as an area for enjoyment of recreation, visual amenity, tranquillity, wildlife,
heritage, and highly accessible countryside close to the urban area.

The above area will be safeguarded from development other than in very special
circumstances or where the development is to enhance Local Green Space functions, for
example, through improvements to access, recreation and wildlife.

Reasoned Justification

14.39 Public consultations have consistently shown that Ifield Brook Meadows and Rusper Road Playing Fields should be protected because of their special value to the local
community. The Meadows are an important site of nature conservation with distinctive vegetation and wildlife. The northern part of the Meadows is of historic importance, forming part of the Ifield Village Conservation Area, contributing to the
setting of the village and church. These elements make this area unique and local in character.
14.40 The presumption in favour of sustainable development does not apply to Local Green Spaces. Proposals affecting the designated Local Green Space should be consistent
with national Green Belt Policy.


Environmental Protection

16.1 Crawley is unique in comparison to other towns in the region. It is mainly urban in
character, is well linked to the motorway network, contains a major international
airport at Gatwick, and is home to one of the largest employment areas in the south
east at Manor Royal and County Oak. These aspects have combined to make
Crawley a leading economic driver in the sub-region, but can also result in pollution
impacts which need to be mitigated and managed.
Chapter Content
16.2 This chapter sets out policies to guide the relationship between development and
local, national and global environmental protection requirements.
The Key Issues
16.3 With a growing population and a consequent need for development, it is vital that the
relationship between development and the environment is appropriately managed
Key to this will be ensuring that development is appropriately planned to ensure that
it does not result in, or expose future users to, inappropriate environmental impacts.
The planning policies in this chapter are in place to ensure that development is
planned carefully and sustainably with Crawley’s environment in mind.
16.4 Crawley is already a thriving borough, with a sub-regionally significant employment
offer, a growing population, a major international airport at Gatwick, and excellent
surface transport links. Crawley’s housing, employment and infrastructure needs are
forecast to grow over the Plan period, and will need to be appropriately planned for.
16.5 These factors illustrate the success of Crawley as a place where people want to live,
work and visit. These existing assets, and also those which may come forward over
the Plan period, may, if not planned carefully, contribute to, or potentially be exposed
to environmental issues such as noise impacts, poor air quality, or other forms of
environmental pollution. Noise is a key consideration, with a large part of the borough
falling within noise contours associated with Gatwick Airport, and the presence of
both noise generating and noise-sensitive related development. Air Quality can also
be an issue, especially where surface transport is concentrated, and Hazelwick Air
Quality Management Area (AQMA) was designated in 2015. Other forms of pollution,
such as contaminated land, can also be a consideration.
16.6 Through the policies set out in this Chapter, the relationship between development
and environmental factors will be appropriately managed to ensure that the
sustainability objectives of the Crawley 2035 Vision are met.


Flood Risk

16.7 Falling entirely within the River Mole catchment the borough’s water environment is a
key environmental consideration that needs to be taken account of in planning
decisions. Whilst the water environment provides an important leisure and visual role
in a predominantly urban area, parts of the borough are affected by flood risk from a
number of sources, and high profile flood events serve as a reminder of the need to
manage flood risk. Therefore, it is important that development is planned with flood
risk in mind, both in terms of protecting Crawley residents, and ensuring that flood
risk is not increased elsewhere.

Managing Pollution

16.8 Crawley, like many other urban areas, is home to major transport hubs and networks,
industrial and commercial uses, as well as more sensitive uses including residential
areas, green infrastructure, and also countryside outside the built up area boundary.
It is important to ensure that the relationship between these different land uses is
appropriately managed, and that development is carefully planned, to ensure that it
does not result in, nor expose its users to, unacceptable pollution impacts.
16.9 The NPPF is clear that planning policies and decisions should contribute to and
enhance the natural and local environment, including by preventing new and existing
development from contributing to, being put at unacceptable risk from, or being
adversely affected by soil, air, water or noise pollution.
16.10 Crawley is fortunate in having few areas that are subject to serious pollution issues,
though the predominantly urban nature of the borough, and the variety of different
land uses within it, means that pollution is an important consideration in planning
decisions. The council will seek to ensure that development protects, and where
possible, improves the environment and amenity of existing and future residents and
occupiers of land. Development will be required to demonstrate that it will not give
rise, or be subject to pollution that would cause unacceptable harm to health, safety,
quality of life, amenity, biodiversity or the environment. Where development is likely
to generate significant pollution impacts, the council will require that the impacts are
minimised and/or mitigated to an acceptable level.
16.11 The most significant pollution considerations relate to matters of land quality, noise
and air quality, covered specifically by Policies EP3, EP4, and EP5 respectively.
Light pollution is covered in Policy EP6.
Local Plan Policies
Development and Flooding
16.12 Crawley’s water environment is an important planning consideration, particularly from
a perspective of managing flood risk, and will continue to remain so in planning for
Crawley’s future. The borough falls entirely within the upper reaches of the River
Mole catchment, and the town’s location within the catchment has meant that several
areas are identified by the Environment Agency as being at risk of flooding. The
northward flow of the Upper Mole towards the Thames also has flood implications for
Gatwick Airport and neighbouring authorities, in particular Reigate and Banstead
Borough. River (fluvial) flooding is not the only source of flooding; Crawley is at the
highest risk of surface water (pluvial) flooding in West Sussex. Sewer and
groundwater flooding are also important planning considerations.
16.13 Therefore, it is vital that development is planned sustainably with flood risk from all
sources in mind, in order to protect current and future users of development, and
ensure that development does not increase flood risk elsewhere. The NPPF and
supporting PPG: Flood Risk and Coastal Change categorise different development
types according to their vulnerability to flood risk, and the extent to which these users
are compatible or otherwise with the level of flood risk at the development site.
Through applying the sequential test, the most vulnerable development types should
be directed to the areas of lowest flood risk.

Strategic Policy EP1: Development and Flood Risk

Development must avoid areas which are exposed to an unacceptable risk from flooding,
and must not increase the risk of flooding elsewhere. To achieve this, development will:
i. be directed to areas of lowest flood risk, as identified on the Environment Agency
Flood Map for Planning, having regard to its compatibility with the proposed location
in flood risk terms, and, where required, demonstrating that the sequential and
exceptions tests are satisfied;
ii. where located in Flood Zones 2 or 3, and for all major development in Flood Zone 1,
demonstrate through a Flood Risk Assessment how appropriate mitigation
measures will be implemented as part of the development to ensure flood risk is
made acceptable on site, and is not increased elsewhere as a result of the
iii. reduce peak surface water run-off rates and annual volumes of run-off through the
effective implementation, use and maintenance of SuDS, unless it can be
demonstrated that these are not technically feasible or financially viable. Applicants
should refer to the West Sussex Lead Local Flood Authority Policy for the
Management of Surface Water and the Climate Change SPD for further guidance;
iv. make appropriate provision for surface water drainage to ground, water courses or
surface water sewer. Development will not be allowed to drain to the foul sewer;
v. post construction, provide to the council certification of the drainage works from a
third party professional. This should not be the consultant who designed the
drainage features. This will be to ensure that the drainage details and design
submitted for planning application has been constructed in line with the submitted

Reasoned Justification

16.14 Flooding is a natural process that can happen at any time in a wide variety of
locations, potentially posing a risk to life, property and livelihoods. The risk of flooding
posed to properties within Crawley arises from a number of sources including river
flooding, localised runoff and sewer flooding.
16.15 Development has the potential to increase the likelihood of flood risk if it is not
carefully planned and managed. There are areas which are particularly at risk from
fluvial flooding as Crawley is crossed by a number of designated main river
watercourses that form part of the River Mole catchment. Climate change, and the
predicted alterations to weather patterns this will bring, will place additional need to
ensure developments can be considered as safe for its lifetime. Therefore, to ensure
that people and places are not exposed to unacceptable flood risk, it is essential that
planning decisions are informed by, and take due consideration of, the flood risk
posed to (and by) development.
16.16 Flash flooding from surface water run-off is frequently an issue across the borough
following heavy localised rainfall events. It is a specific issue in Crawley as the
underlying clay soil and density of urban development reduces permeability and
increases the levels and speed of surface water run-off. This can result in localised
surfaces flooding, and can lead to rivers exceeding their storage capacity more
quickly, often resulting in ‘flash flooding’. Sewer flooding is also an issue, and to
minimise the risk of sewer overload, development will not be allowed to drain to the
foul sewer.
16.17 The NPPF requires local planning authorities to take a pro-active approach to
managing impacts associated with climate change, including flood risk. The risk of a
flood event is a function of both the probability that the flood will occur and the
consequence to the community as a direct result of the flood. To minimise risks to
property, development should be avoided in areas which are at greatest risk of
flooding, and directed to sequentially preferable areas of lowest risk. Where, having
applied the sequential test, it is not possible for development to be located in areas of
lower flood risk, then the NPPF exceptions test should be applied and satisfied.
16.18 To guide the location of development, Planning Practice Guidance: Flood Risk and
Coastal Change (DCLG, 2019) identifies the different levels of flood risk, ranging
from Flood Zone 3b (functional floodplain), the land at greatest probability of flooding
to Flood Zone 1, the lowest probability. Table 2 of the Planning Practice Guidance
categorises different development types according to their vulnerability to flood risk,
with Table 3 outlining which development types are suitable within each flood zone.
16.19 To identify the extent to which land is at risk of flooding, applicants will be required to
refer to the most up-to-date Environment Agency Flood Map for Planning. Based on
this mapping, Crawley is delineated into the following Flood Zones:
– Flood Zone 3b Functional Floodplain: land where water has to flow or be
stored in times of flood.
– Flood Zone 3a High Probability: Land assessed as having a 1% AEP (1 in 100
chance in any year) or greater of flooding.
– Flood Zone 2 Medium Probability: Land assessed as having between a 1%
AEP (1 in 100 chance in any year) and 0.1% AEP (1 in 1000 chance in any year)
of river flooding.
– Flood Zone 1 Low Probability: Land assessed as having a less than 0.1% AEP
(1 in 1000 chance in any year) of river flooding in any year (i.e. 0.1% AEP).
16.20 The Environment Agency Flood Map for Planning does not delineate Flood Zone 3
into its sub-designation of Zones 3b and 3a. Therefore, as agreed with the
Environment Agency, within Flood Zone 3 all undeveloped areas and areas of open
space will be treated as Flood Zone 3b (Functional Floodplain).
16.21 The NPPF recognises residential development as a ‘more vulnerable’ use which
should be directed to Flood Zone 1 in the first instance, and then Flood Zone 2,
subject to demonstrating compliance with the sequential test and the acceptability of
development through a Flood Risk Assessment. The Flood Risk Assessment will
need to demonstrate how flood risk will be managed now and over the development’s
lifetime, taking climate change into account and with regard to the vulnerability of its
users. Residential development on land falling within Flood Zone 3a will only be
acceptable where, having demonstrated compliance with the sequential test and the
acceptability of development through a Flood Risk Assessment, it can be
demonstrated that the NPPF exceptions test is satisfied.
16.22 All housing sites identified in Local Plan Policy H2 are considered to be appropriate
locations in terms of flood risk. This assessment follows early engagement on the
Local Plan with the Environment Agency and West Sussex County Council (WSCC)
which provided information on flood risk levels across the Crawley area from rivers,
surface water and groundwater. Of the sites allocated by the Local Plan for
residential development, three are situated in areas partially affected by Flood Zone
2 and/or Flood Zone 3a; these being: Breezehurst Drive, Bewbush; Henty Close,
Bewbush; and Land adjacent Desmond Anderson, Tilgate. The principle of
residential development at each of these sites is accepted, subject to applicants
demonstrating, through a Flood Risk Assessment, that the development has been
carefully planned to ensure it is acceptable in terms of flood risk.
16.23 West Sussex County Council (WSCC) is the Lead Local Flood Authority (LLFA),
meaning it is a statutory consultee on planning applications where flood risk is a
consideration. In its capacity as LLFA, WSCC has published West Sussex Lead
Local Flood Authority Policy for the Management of Surface Water (updated
November 2018), which sets out the requirements for drainage strategies and
surface water management provisions associated with applications for development.
In responding to flood risk as part of the planning application process, applicants
should meet the requirements set out by WSCC in this document.
Flood Risk Guidance for Householder Development and Small Non-Residential
16.24 Some existing residential dwellings and non-residential buildings in Crawley are
situated in areas of flood risk, falling within Flood Zone 2 (medium probability) or
Flood Zone 3a (high probability). It is recognised that the occupiers of these
properties may seek to apply for planning permission to undertake small-scale
development that is associated with the use of the existing building, such as
householder applications, or small ground floor extensions. This type of
development, though of a relatively small-scale, still has potential to take up flood
storage, and will itself be vulnerable to flooding.
16.25 In these situations, it is recognised that a detailed Flood Risk Assessment would not
be proportionate to the nature and scale of development being proposed. Therefore,
for the development typologies identified in Policy EP2, and defined at paragraph
16.28, a proportionate Flood Risk and Resilience Statement will be required to
support planning applications. This will be required to demonstrate how any lost flood
storage will be mitigated, and how the proposed development will be made resilient
in flood risk terms.
Non-Strategic Policy EP2: Flood Risk Guidance for Householder Development,
Small Non-Residential Extensions
Within Flood Zone 2 (medium probability) and Flood Zone 3a (high probability) a detailed
Flood Risk Assessment will not be required for:
i. Householder development
ii. Minor non-residential extensions with a footprint of less than 250m2
iii. Minor alterations to property.
Instead, a Flood Risk and Resilience Statement must be provided. This will be required
to, on a proportionate basis, demonstrate how:
i) any loss of flood storage resulting from the development will be appropriately
mitigated; and
ii) the development has been designed to ensure that, over its lifetime and taking
climate change into account, it is resilient to the level of flood risk posed.

Reasoned Justification

16.26 Some existing buildings within Crawley Borough are situated within Flood Zones 2
and 3a, and are, therefore, subject to an existing level of flood risk. In individual
cases where small-scale development, as set out at 16.24, is proposed to existing
buildings that are already affected by floor risk, this is unlikely to result in a significant
increase in flood risk. However, cumulatively, such developments will have an overall
impact of reducing flood storage capacity in the borough, unless carefully planned to
ensure that any loss of flood storage is appropriately mitigated. Equally, it is
recognised that the development proposed will, as is the case for the existing
building, be at a risk of flooding. Therefore, it is important to ensure that development
is designed to ensure that any loss of flood storage is appropriately mitigated, and
that development is resilient to the level of flood risk posed.
16.27 The nature and scale of these development types can be problematic to consider as
part of a detailed Flood Risk Assessment, sometimes resulting in delay to the
decision-making process. To simplify the planning process for small-scale
development, whilst still ensuring that matters of flood storage and resilience are
adequately addressed, a proportionate Flood Risk and Resilience Statement will be
required. This will need to demonstrate how any loss of flood storage resulting from
the development will be appropriately mitigated, and how the development has been
designed to ensure that it is resilient, now and over its lifetime, to the level of flood
risk posed. In doing so, the statement will be expected to show how appropriate flood
storage mitigation such as green infrastructure or SuDS has been incorporated into
the development, and will need to explain how the development will be designed and
constructed to reduce impacts in the event of flood water entering the building.
16.28 Local Plan Policy EP2 applies to the following development typologies:
i) Householder Development: For example, sheds, garages, games rooms etc. within
the curtilage of the existing dwelling, in addition to physical extensions to the existing
dwelling itself. This definition excludes any proposed development that would create
a separate dwelling within the curtilage of the existing dwelling, e.g. subdivision of
houses into flats.
ii) Minor Non-Residential Extensions: For example, industrial, commercial, leisure
extensions with a footprint less than 250 square metres.
iii) Minor Alterations to Property: Minor development that does not increase the size
of buildings, such as alterations to external appearance. This definition excludes
changes of use that would result in increase in flood risk as a result of a changed
flood risk vulnerability classification.


Strategic Policy EP5: Air Quality

People’s health, quality of life and wider environment shall be protected from the
significant adverse effects of atmospheric pollution.
Development should help to improve air quality and enhance the environment. New and
existing development will be prevented from contributing to, being put at risk from, or
being adversely affected by atmospheric pollution. To achieve this, development will be
required to prevent, or where this is not practicable, minimise the generation of pollutants
that would result in a deterioration in air quality and to prevent exposure to poor air
To ensure that air quality is appropriately taken into account in the planning of
development, applicants will adhere to national and local guidance, including the Local
Plan Planning Obligations Annex and Air Quality and Emissions Mitigation Guidance for
Sussex (2019 or latest version) which should be used to identify if:
a) an Emissions Mitigation Statement is required as part of a planning application;
b) an Air Quality Impact Assessment is required as part of a planning application.
To reduce the overall background levels of pollution, sustainable design principles shall
be incorporated into the development to ensure that the residual local emissions of air
pollution are prevented or, where this is not practicable, minimised. This shall include the
high standards of insulation, the selection of low emission technology for heating and
power; and the provision of facilities for sustainable transport including electric vehicle
charge infrastructure and charge points.
Planning permission will only be granted where it:
i. can be demonstrated that air quality has been appropriately factored into the
location, design and operation of development, and where necessary, appropriate
mitigation provided; and
ii. will not result in a deterioration of air quality within an AQMA; and
iii. will not lead to the declaration of a new AQMA; and
iv. does not conflict with the requirements of an air quality action plan; and
v. will not result in an increase exposure within an AQMA.
Development of Industrial and Commercial Use
Development that includes industrial and commercial land uses must submit appropriate
detailed evidence to enable assessment of potential significant adverse air quality
impacts. Mitigation measures should be included in proposals where evidence suggests a
likely significant adverse effect.

Reasoned Justification

16.45 The council has responsibility to ensure that air quality does not negatively affect the
public health or the environment, both within and beyond the borough boundary, and
for this reason it is important that the Local Plan is pro-active in supporting the
improvement of air quality.
16.46 The NPPF is clear that planning decisions must contribute to and enhance the
natural and local environment, and ensure that development is appropriate to its
location, taking into account the likely effects (including cumulative effects) of
pollution on health, living conditions and the natural environment. This is expanded
upon through the Planning Obligations Annex and Planning Practice Guidance: Air
Quality (2019), which outlines how Local Plans may consider air quality, having
regard to the type of development and where it is proposed, and measures for
offsetting air quality impacts that may arise from new development.
16.47 Air Quality & Emissions Mitigation for Sussex enables the Local Plan to apply a proactive approach to ensure that development is appropriately planned to take account
of air quality, and provides appropriate mitigation where air quality is a material
consideration. Applicants will be required to refer to the checklists contained within
the Guidance to identify if the development being proposed will require supporting
information in the form of an Emissions Mitigation Statement, and if required, an Air
Quality Impact Assessment. Through this approach, the Local Plan will be able to
ensure that development has regard to the air quality impacts that may arise from it,
having regard to its scale and location.
16.48 The purpose of the Emissions Mitigation Statement is to quantify the additional
transport emissions created by the development to determine the appropriate level of
mitigation that is required to avoid, minimise or offset the impact of the development
on air quality. The emissions calculator contained within the document to estimate
monetary value of damage from the development caused by nitrogen dioxide and
particulate pollutants. The identified figure is the minimum sum that must be spent on
practical mitigation measures, which will be implemented as part of the development,
following agreement with the Local Planning Authority. The preference will be that
mitigation is provided on-site by the developer. If it is not feasible to provide on-site
mitigation, an equivalent financial contribution will be sought, to be secured by way of
a S106 Agreement.
16.49 The purpose of the Air Quality Impact Assessment is to determine the significance of
the predicted impact of the development. Where an Air Quality Impact Assessment is
required, applicants are expected to complete the assessment in accordance with the
Institute of Air Quality Management (IAQM) Planning Guidance available at and should
liaise direct with the council’s Environmental Health team



Strategic Policy ST4: Safeguarding of a Search Corridor for a Crawley Western Link

The Local Plan Map identifies a Search Corridor for a Crawley Western Link Road linking
the A264 with the A23. This Search Corridor will be safeguarded from development which
would be incompatible with the future delivery of a full Crawley Western Link Road.
The design and route of the Western Link Road must take account of:
a. its impact on (but not limited to):
 residential properties close to the route;
 the flood plain;
 the rural landscape;
 local biodiversity; and
 heritage and heritage landscape assets and visual intrusion.
b. the desirability and requirements of bus priority measures (including future
proofing for forecast traffic growth and congestion).
Connectivity by non-vehicular modes of transport between Crawley’s urban
neighbourhoods and the wider Sussex countryside should be maintained and enhanced.
Reasoned Justification
17.23 The Western Link Road should provide a new strategic road link for traffic from the
west, and from Kilnwood Vale and any new development west of Crawley to link
directly with the A23 north of County Oak serving Manor Royal and Gatwick. This will
remove the need for this traffic to come further east into Crawley, travel around all
the Bewbush/Broadfield roundabouts to link with the A23, a route which is known to
be increasingly congested at peak times.
17.24 The provision of a full Western Link Road between the A264, west of Kilnwood Vale,
and the A23 (North of County Oak) is necessary to reduce existing congestion on the
A2220 and A23, remove through traffic from the neighbourhood junctions and
residential roads, reduce inappropriate usage and increased levels of traffic on rural
routes to Gatwick Airport, and reduce pressure on the M23 Junctions 10 and 11. It
will also help mitigate the surface access impacts of growth at the Airport, provide
alternatives to help address the impacts from permitted new developments (Kilnwood
Vale, Pease Pottage and North Horsham) and from potential future developments on
the western side of Crawley. It is anticipated that detailed impacts of further
development onto the Crawley road network would be modelled through the
Horsham District Local Plan Review process, and will also be included in the Crawley
Transport Model Update as part of the Crawley Local Plan Review.
17.25 Without commitment to the construction of a full Western Link Road between the
A264 and A23 (North), all the traffic from any development to the west of Crawley,
from permitted schemes and any future proposals which could emerge through the
Horsham District Plan Review and/or through planning applications permissions
granted as windfalls, is likely to feed into residential roads in Ifield and/or Langley
Green and onto the already congested A23 junctions, particularly the Ifield
Avenue/A23 junction in the long term. New highways crossing the Ifield Brook
Meadows and Rusper Road Playing Fields Local Green Space would be wholly
unacceptable, given the impact this would have on ancient woodland, the biodiversity
in the LWS and LNR, the character of Ifield Village Conservation Area, the flood plain
and the recreational use of the Local Green Space.
17.26 A Western Link Road would enable the prioritisation of connectivity by more direct
routes for public transport, cycling and walking into Crawley from any new