Homes England – Draft Horsham District Local Plan Formal Representations
Posted on Jun 5th 2020 by West of Ifield
Homes England has submitted formal representations to Horsham District Council’s consultation on the Draft Horsham District Local Plan. Horsham District Council’s initial report on the consultation outcomes can be found here.
We have submitted these representations as a majority landowner and promoter in relation to our land to the West of Ifield, which is identified as Land West of Crawley in the Draft Local Plan. The representations demonstrate how we can help to provide the new homes, infrastructure and employment needed as identified in the draft Local Plan and ensure future development is sustainable. We have also provided suggested amendments and / or additions to some draft policies in the Local Plan to ensure the best overall outcome for the community.
Our representation once again highlights our commitment to bring forward a high-quality new community on land West of Ifield in a way which supports sustainable development in as much it will:
reduce the need to travel and encourages the use of sustainable transport;
provide at least 50% open space and a minimum 10% net gain in biodiversity;
provide homes and jobs to meet the needs of local people ;
provide a climate resilient development that contributes towards national carbon reduction targets;
build essential supporting infrastructure;
promote local stewardship and community management.
We believe that our site is in a crucial location and offers an excellent opportunity to deliver much needed new homes and infrastructure in a strategic location within the Plan period to meet Crawley and Horsham’s urgent housing needs.
The Land West of Ifield (site SA101) can be built as a stand-alone scheme, delivered in full over the Plan period and has the capacity to deliver a minimum of 3,250 homes. However, our plans show how the West of Ifield site could be the first phase of a larger strategic allocation comprising some 10,000 new homes which will progress over 30 years and create several new neighbourhoods.
The representations submitted to Horsham District Council confirm that the site is suitable for development and set out how we will work in partnership with Horsham District Council and Crawley Borough Council to ensure identified housing needs and wider objectives of the Draft Local Plan are met. We have set out our support and rationale for Horsham District Council’s provision of a large strategic allocation within the Local Plan that allows for the long-term growth for a garden town on Land West of Crawley.
The representations provide further information on some of the questions we have received during the consultation – for example regarding infrastructure, employment and biodiversity. Further information will become available as our plans are progressed.
Following our public consultation earlier in 2020, we want to continue the dialogue with residents about the proposals and demonstrate our commitment to support the creation of these new neighbourhoods throughout the planning and development process.
To read the representations please click here.
If you have any questions regarding the information in the representations please get in touch at firstname.lastname@example.org.
Making homes happen
Dear Sir / Madam,
HORSHAM DISTRICT COUNCIL LOCAL PLAN REVIEW REGULATION 18
We set out below our representations to Horsham District Council’s Regulation 18 consultation on
the Draft Horsham District Local Plan 2019 – 2036 (the Draft Local Plan). These representations
are made by Homes England in its role as the Government’s housing accelerator, and as a majority
landowner and promoter in relation to land identified as Land West of Crawley in the Draft Local
Purpose of Representations
Pursuant to Regulation 18 of Town and Country Planning Act (Local Planning) (England)
Regulations 2012 these representations are made in respect of the Draft Local Plan and set out
Homes England’s position in so far as the Draft Local Plan is relevant to Land West of Crawley.
Homes England endorses and supports the identified opportunity to bring forward and plan
positively for a long-term strategic growth opportunity for a minimum of 10,000 homes on Land
West of Crawley.
Within the current Draft Local Plan, Land West of Crawley comprises Site SA101 (with capacity for
a minimum of 3,250 homes) together with SA291 West of Kilnwood Vale. These sites form part of
a larger strategic growth opportunity area for a minimum of 10,000 new homes.
Whilst the starting point for any allocation should be on the basis that sites SA101 and SA291 will
be delivered early in the next plan period to meet identified housing needs, the consideration of
the longer-term ambition is important and is therefore strongly supported by Homes England.
Homes England considers that a significant opportunity exists to identify Land West of Crawley as
a strategic allocation of 10,000 new homes, supporting infrastructure, employment and
community facilities that would collectively comprise a “garden town”. Although site SA101 is
capable of functioning as a standalone site that can be master planned so that it is consistent with
adjacent allocations, Homes England considers that significant additional benefits can be
achieved by way of a wider strategic allocation for 10,000 homes. Rather than incremental, ad
hoc, standalone allocations over time, it is considered that a single large allocation now, to meet
needs for the long term, is capable of being much more than the sum of its parts.
In its role as housing enabler, Homes England can help facilitate delivery of that wider public benefit.
Following discussions with other landowners and key delivery partners, Homes England considers
that there is a compelling case for including Land West of Crawley in a strategic allocation within
the Draft Local Plan for at least 10,000 new homes, recognising that the comprehensive delivery
of the scheme will go beyond the plan period.
Within this context it is necessary to clearly distinguish between (A) the first phase of
development within SA101; and (B) other development parcels which can deliver early and wholly
within the Plan period; and (C) the wider opportunity that will be delivered outside the plan
We therefore consider the allocation should be considered as follows:
a) Allocation of Land West of Ifield (SA101), providing early comprehensive delivery of
homes, employment space and supporting infrastructure during the plan period as a first
b) Allocation of other land within the Land West of Crawley where this can deliver early
against the vision and objectives for a new sustainable garden town.
c) Allocation of the remaining Land West of Crawley, providing long term strategic
development opportunity for at least 6,000 additional homes as part of a comprehensive
garden town that has the potential to become a national exemplar for sustainable
Site SA101 should be identified as the first phase of the wider 10,000 unit allocation, but if a
10,000 unit allocation is not considered appropriate at this time, Site SA101 would function as a
standalone site whose development is consistent with the later development of the wider area if
that is then thought appropriate.
These representations therefore set out:
• The role of Homes England and how it can work in partnership with Horsham District
Council to ensure identified housing needs and wider objectives of the Draft Local Plan
can be met.
• Homes England’s support for Land West of Crawley being allocated for 10,000 new
homes and why this is considered to be an optimal outcome in terms of the overall
benefits that can be realised from such an approach;
• Homes England’s support and rationale for the allocation of Land within SA101 as the first
phase of a larger strategic development opportunity on Land West of Crawley (or if a
10,000 unit allocation is not considered appropriate at this time, SA101 would function as
a standalone site whose development is consistent with the later development of the
wider area if that is then thought appropriate);
• Homes England’s support and rationale for Horsham District Council to provide a larger
strategic allocation within the Local Plan that enables the comprehensive planning for
long term growth for a garden town on land West of Crawley. This recognises the
opportunity for such development to provide a long-term sustainable solution to meeting
future needs of the North West Sussex Housing Market Areas, the Gatwick Diamond and
North West Sussex Functional Economic Areas.
• Suggested amendments and / or additions to draft policies where these will help support
the draft vision and objectives and ensure they meet the soundness tests set out in the
National Planning Policy Framework (NPPF) (paragraph 35).
Where necessary, these representations refer to the supporting evidence base published
alongside the Draft Local Plan.
Please contact me if you would like to discuss any points raised in this submission. In
the meantime, I look forward to further engagement and would be grateful if you could continue
to keep up us informed in relation to the HDCLPR and progression towards Regulation 19.
Ken Glendinning FRICS
Annex A: Homes England Representations on Horsham District Draft
Local Plan 2019 – 2036 (Regulation 18)
1. How Homes England can help support the objectives of the draft Local Plan?
1.1 Homes England is an executive non-departmental public body, sponsored by the Ministry of
Housing, Communities and Local Government. Homes England has the aspiration, influence,
expertise and resources to drive positive market change. By releasing more land to
developers who want to make a difference, Homes England is assisting in the delivery of new
homes and is helping to improve neighbourhoods and grow communities. Homes England
works in collaboration with partners who share our ambition. These include local authorities,
private developers, housing associations, lenders and infrastructure providers. Within the
next few years, Homes England will have invested over £27 billion across our programmes.
1.2 Homes England has a strong track record in acting as a ‘master developer’ on large housing led schemes such as the Northern Arc in Burgess Hill and Northstowe in Cambridgeshire. In
the case of Burgess Hill, Homes England acquired the site, which had been identified as a
location for major housing delivery for over 10 years but had stalled due to the complexities
of land ownership and the need for upfront strategic infrastructure delivery. Homes England
worked closely with Mid Sussex District Council, the landowners and the site promoter to
acquire the land. At the Northern Arc, Homes England is investing in the required
infrastructure to secure early release of the first phases of development before the first
homes are built.
1.3 Homes England is deploying our knowledge and delivery expertise to ensure that
development on land within our control comes forward to meet local ambitions, meeting
identified local housing needs and supporting wider sustainability and economic objectives.
1.4 As a Government Agency, working in partnership with Horsham District Council, Crawley
Borough Council, West Sussex County Council and other delivery partners, Homes England
has a range of mechanisms to assist in the delivery of a new sustainable new garden town on
Land West of Crawley, including:
• Unlocking land – a commitment to using our existing land holdings and using our
funding programmes to unlock land within SA101. Within our Strategic Plan 2018/19 –
2022/23, we are committed to bringing forward land to deliver Land West of Ifield in
the first five years of the Plan period and will continue to proactively address land
assembly issues within the wider garden town area if required. If necessary, Homes
England has compulsory purchase powers through the Housing and Regeneration Act
2008 and would consider the use of such powers as a last resort where necessary in
the public interest.
• Unlocking investment – a commitment to investing in infrastructure upfront,
ensuring that new homes are delivered alongside by the necessary facilities, services
and infrastructure. Working with delivery partners we will ensure a range of
investment products are available to support housebuilding and infrastructure
delivery – including more affordable housing and homes for rent.
• Increasing productivity – using the scale of development at Land West of Crawley to
support the housebuilding construction industry to overcome challenges in terms of
productivity, workforce, skills and materials. This includes supporting skills for future
workforce, as well as using new technologies such as modern methods of construction
to ensure accelerated delivery rates are achieved.
• Delivering market resilience – using the scale of development at Land West of
Crawley to support smaller builders and new entrants, while promoting better design
and higher quality homes.
• Supporting local areas – providing support to Horsham District Council to provide
confidence in the delivery of a new garden town West of Ifield – helping to create and
deliver more ambitious plans to get more homes built. In bringing forward important
community infrastructure, we are exploring how early delivery can also help address
current requirements within existing communities.
• Delivering home ownership products – ensuring a new garden town at Land West of
Crawley maximises the opportunities for shared ownership and rent to buy, amongst
other government sponsored programmes including new First Homes.
1.5 Homes England’s commitment to the above within the context of development to the Land
West of Crawley is confirmed in its Strategic Plan in terms of the delivery of infrastructure
and the first 200 homes by 2022/23.
2. Land West of Ifield [SA101] – providing early comprehensive delivery of homes,
employment space and supporting infrastructure as a first phase
2.1 Homes England is promoting SA101 as the first phase of a new sustainable garden town.
SA101 has capacity for a minimum of 3,250 homes, supporting employment and
infrastructure. Homes England envisages this as the first phase of the larger strategic
allocation comprising some 10,000 new homes, albeit SA101 is capable of functioning as a
stand alone site if a larger strategic allocation is not considered appropriate. Through its
recent public consultation1
, Homes England has set out a clear commitment for the
development West of Ifield to:
• Deliver a sustainable new community in line with garden town principles that reduces
the need to travel;
• Develop a landscape led masterplan that provides for at least 50% open space and a
minimum 10% net gain in biodiversity;
• Meet the identified housing needs within the North West Sussex Housing Market Area
– including delivering a policy compliant level of affordable housing and providing a
1 Homes England is committed to engaging the community in the design and planning process throughout the project and have
undertaken initial engagement though a series of public exhibitions in venues around Crawley and Horsham through January 2020.
‘The engagement events were well attended with a total of 726 members of the community visiting over the eight days. 251 feedback
forms were received from the exhibitions, in addition to 305 online forms being completed on www.westofifield.co.uk. Engagement
will continue with further events scheduled for later in 2020 to test design ideas and concepts. Further information regarding these
events be found online1 and we will be seeking to publish comprehensive feedback in due course ahead of initial masterplanning.
range of housing types and tenures – including the provision of gypsy and traveller
• Provide the homes and jobs required to maximise the economic potential within the
Gatwick Diamond and North West Sussex Functional Economic Areas – enhancing the
local employment offer and providing for start-up and SME business in line with wider
strategic economic objectives;
• Provide a climate resilient development that contributes to the achievement of zero
carbon through a range of measures, including construction, and is resilient to climate
change – including appropriate flood risk management and low carbon and alternative
• Deliver supporting infrastructure in timely manner to mitigate the impacts of
development and which helps to meet the needs of existing communities;
• Provide a positive local legacy through use of local stewardship and community
• Be futureproofed to support the potential to bring forward a sustainable strategic
growth area on the wider Land West of Crawley.
2.2 These ambitions are consistent with the Local Plan vision and criteria set out in the draft
Strategic Site Principles detailed under draft Policy 15. Further detail is provided in Annex
B as to how specific principles can be met.
2.3 Site SA101 has a long history of being promoted and has previously been assessed through
the current Horsham Local Plan. Promotion has always been considered within the context of
enabling Horsham and Crawley authorities to meet their housing requirements through the
duty-to-cooperate by bringing forward new sustainable communities that meet locally
2.4 Within this context, Homes England agrees with the observations set out in the HDC SA of
Growth Options that acknowledge failure to provide some level of growth which is well related
to Crawley, may fail to best respond to economic realities of the area. Moreover, a strategy
which is not well related to Crawley would miss the opportunity to respond positively to the
unmet housing need arising from Crawley specifically (HDC SA of Growth Options, 2020,
2.5 Furthermore, as demonstrated by the Site Assessment set out in the Draft Local Plan, site
SA101 performs well against the alternative strategic sites, with clear locational and
sustainability benefits that include:
• The ability to fully deliver the site within the Plan period, making a positive and substantial
contribution towards meeting the identified housing needs within the North West Sussex
Housing Market Area – providing the opportunity for Horsham and Crawley councils to
work collaboratively to meet unmet housing need identified in CBC Local Plan Review (2020
• The opportunity to maximise the economic potential within the Gatwick Diamond and
North West Sussex Functional Economic Areas – helping to deliver against the strategic
priorities identified in the emerging C2C Local Industrial Strategy and North West Sussex
Economic Growth Assessment Update (2019)2
• The ability to provide a new sustainable community at scale with the potential to deliver
significant reduction in household emissions and wider environmental enhancements;
• The opportunity to provide significant new investment in supporting environmental, social
and transport infrastructure to mitigate the impacts of development and help meet the
needs of existing communities;
• The opportunity through significant investment in infrastructure and high-quality placemaking to achieve a step-change in modal shift towards sustainable transport modes;
• The potential to address issues of inequality – especially in relation to housing affordability
and access to local services.
2.6 In reviewing the Draft Local Plan, we recommend several instances where revised SA Scores
would be appropriate based on the evidence provided within this response. This is provided
at Annex B to these representations. These changes will impact positively on the Site
Assessment scoring, providing further justification as to why Land West of Ifield should be
included as a preferred strategic allocation.
2.7 Together, the Site Assessment and the Sustainability Assessment (as amended)
demonstrates the significant strategic, locational and sustainability advantages of Land West
of Ifield over other potential allocations, and that previous soundness concerns raised
through earlier Local Plan examination – and reflected in the current HDC Site Assessment
Paper (2018) – can be addressed.
2.8 On this basis, Homes England supports the inclusion of site SA101 as a potential strategic
allocation with capacity for a minimum of 3,250 homes as the first phase of a sustainable new
community that can help address the challenges set out in Chapters 4, 5 and 6 of the Draft
Local Plan. Should site SA101 not be progressed as a preferred strategic allocation within the
Regulation 19 consultation, it is considered that potential soundness issues could arise.
2.9 The opportunity for longer term delivery of a new garden town is considered below. It is
important to recognise that when SA101 is considered as part of a longer term strategic
growth opportunity, the extent of the benefits and opportunity to maximise the sustainability
of the scheme through appropriate land uses and infrastructure provision is further
enhanced. Commentary to support this position is also included with Annex B.
2 The EGA 2019 identifies the need for additional employment floorspace to support the continued success of the
Functional Economic Area recognising the need to identify wider supply side opportunities within the FEA to support
continued economic growth within the Crawley area and the opportunity for Horsham to enhance the quality of its offer
for office based employment by complementing existing town centre floorspace through smaller scale, new office
developments in smaller locations and settlements elsewhere in the District. The EGA also identifies a number of
structural changes – such as the increase in flexible and home working and consolidation of formal space – that need to
be provided for so as to fully meet the needs of businesses located within it.
3. Can Site SA101 be Developed?