Homes England – Draft Horsham District Local Plan Formal Representations

Posted on Jun 5th 2020 by West of Ifield

Making homes happen

30thMarch 2020

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
Plan.

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
period.

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
phase.
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
development.

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.

Yours faithfully,

Ken Glendinning FRICS
Project Director
Homes England
Ken.Glendinning@homesengland.gov.uk

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
pitches;
• 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
energy sources;
• 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
management arrangements;
• 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
identified needs.
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,
Para2.5).
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
– 2036);
• 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?

3.1 Whilst previous assessments through the plan making process concluded that the site is not
‘not currently developable’, this was on the basis that there were a number of potential
constraints that required further assessment. The previous assessments did not positively
identify any actual insurmountable constraints on development.
3.2 This is consistent with the findings of the Inspector at the previous Horsham District Plan
Examination who concluded (Para 78 – 80) that the site is well located in a relatively
sustainable position, that there were no insurmountable issues subject to further technical
work being undertaken and that the site should be considered again as part of the HDC Local
Plan review.
3.3 Homes England has undertaken substantive technical feasibility and site assessment work to
proactively address the evidential gaps identified previously and is now able to confirm that
there are no constraints or barriers to bringing development forward on the site.
3.4 The work undertaken to date to address previous concerns includes:
• Future Gatwick Airport Expansion – Homes England are actively engaged with Gatwick
Airport Limited (GAL). Notwithstanding this, there is currently no Government policy
supporting a new southern runway (with a third runway at Heathrow preferred) and GAL
have confirmed their intention to progress a DCO during 2020/21 in relation to the use of its
existing standby runway north of the site. Although Crawley Borough Council in its
Regulation 19 submission draft local plan has indicated its intention to remove the Gatwick
R2 safeguarding area Homes England’s proposals for SA101 are consistent with R2 in any
event . GAL has also confirmed that the emerging masterplan will not impact on operational
requirements (e.g. radar) and regular dialogue will continue to ensure this remains the case.
Homes England is committed to taking account of the potential extent of airport growth as
set out GAL’s published masterplan and future proofing development to avoid any negative
impacts. For example, not building residential development within the 60dB contour and
identifying necessary design led / other mitigation within the 57dB areas associated with a
future second southern runway.
• Cumulative traffic impacts and need for Crawley Western Link – Arcadis, (on behalf of
Homes England) has undertaken high level strategic modelling of the wider area using the
Crawley Town Model in order to assess several potential growth scenarios (including future
Gatwick Expansion). Although further testing needs to be undertaken as part of the HDC and
CBC Local Plan reviews, the indicative modelling undertaken by Homes England to date
shows that in isolation, a minimum of 3,250 homes west of Ifield is unlikely to require a full
link to be delivered but is well placed to contribute towards a Western Link particularly if it
formed part of a wider strategic allocation west of Ifield for up to 10,000 homes.
Consideration also needs to be given to Policy SD3 of the CBC Local Plan and the North
Crawley Area Action Plan that includes an area safeguarded for the link road recognising
that routing and form must be subject to further investigation.
• Delivery of social infrastructure – Homes England has engaged with service providers
including West Sussex County Council (WSCC) and the relevant Clinical Commissioning
Groups (CCGs) in relation to health, education and other community infrastructure
provision. These ongoing discussions will identify the necessary requirements to mitigate
the impact of development as well as potential opportunities for the development to
address extant requirements. This includes the provision of a secondary education site that
will help address an urgent need for additional school places in the mid 2020’s as well as
meeting future demand arising from the development. In addition, two primary schools, a
new community hub (including health, leisure, recreation and community uses) and
significant areas of publicly accessible open space are allowed for in the emerging
masterplan and Homes England is committed to ensuring that they are delivered as early as
possible within the development.
• WwTW Capacity – Homes England is actively engaged with Thames Water Developer
Services over wastewater capacity within the Crawley area and the development is currently
being modelled as part of Thames Water’s capacity review within the Crawley catchment.
While the review is still to be completed, Thames Water has confirmed that technical
solutions do exist that can provide adequate capacity for a minimum of 3,250 homes.
• Land Availability – as discussed further below, Homes England is actively engaged with all
relevant landowners and confirm that land will be within Homes England’s control so that
the first new homes to be delivered in 2022/23. As a last resort Homes England has
compulsory purchase powers that can be used.
• Flood Risk – Homes England has been working with the Environment Agency to assess flood
risk issues within the site and to identify solutions that meet the requirements of the NPPF,
that help to reduce overall flood risk within the site as well as for existing at-risk properties
along the River Mole and Ifield Brook. A comprehensive flood risk and surface water
drainage strategy is being developed that meets these objectives and further detail will be
made available during 2020 following discussions to finalise this.
• Landscape impact – detailed Landscape Impact Character Assessments have been
undertaken to identify opportunities and constraints within the site and protect areas of
greatest landscape value. These assessments are being reviewed to take account of the
recently published HDC Landscape Capacity Study (2020) and will form the basis of a
landscape led masterplan.

4. Can Site SA101 be delivered?

4.1 As set out above, Homes England has an extensive track record of delivering strategic
development sites. The early delivery of homes and infrastructure on site SA101 is a specific
priority in Homes England’s Strategic Plan 2018/19-2022/233
. This provides a commitment
from Homes England to progress the promotion of a strategic growth area for a minimum of
3,250 new homes as part of a comprehensive approach to master planning and place making.
This is alongside a public commitment to begin major infrastructure work and start
construction of the first homes on the site by 2022/23.
3 https://www.gov.uk/government/publications/homes-england-strategic-plan-201819-to-202223
4.2 Homes England already owns the majority of land within site SA101 and has agreed terms
and made the necessary arrangements with the remaining landowners to ensure that all land
can be brought within the control of Homes England in line with its commitment to deliver
homes and supporting infrastructure within the first 5 years of the Plan period, and for site
SA101 to be delivered in its entirety over the Plan period.
4.3 In line with its delivery approach at Northstowe and Burgess Hill, Homes England’s intention
is to act as a ‘master developer’, overseeing the delivery of critical infrastructure and
controlling the delivery of the site. Through this approach, Homes England can confirm that
the scheme is viable, and that Homes England will assume project responsibility from
conception through to implementation, de-risking development opportunities to the level
needed for the private sector to invest and build.
4.4 As master developer, Homes England will continue to work with HDC and other local
stakeholders throughout the delivery stage to ensure high quality design is delivered
consistently across the site and that the vision and key objectives of the development are
met. Where required, Homes England will work with partners to bring forward the delivery of
other infrastructure in order to provide serviced plots for housebuilders to deliver the new
homes. In line with Homes England’s strategic objectives to accelerate housing delivery,
Homes England will work with several delivery partners in order maximise the number of
outlets within the site.
4.5 This delivery model provides a much greater level of certainty compared to other potential
strategic allocations that the necessary infrastructure can be delivered at the right time and
that delivery rates on the site can be maximised.

5. Land West of Crawley – garden town strategic opportunity

5.1 In line with the ambition of Para 72 of the NPPF, Homes England has identified and supports
the potential for SA101 to form part of the first phase of a wider strategic growth opportunity
at Land West of Crawley – for a minimum of 10,000 homes and 10,000 jobs – providing a long
term development opportunity that can be delivered in accordance with garden town
principles and potentially as part of Government’s Garden Communities programme. Whilst
Homes England considers that SA101 could come forward as a standalone allocation, we
consider that incorporating SA101 for a wider 10,000 unit allocation would deliver greater
public benefits.
5.2 A definitive boundary for the 10,000 unit scheme is yet to be determined, and a broad “area
of search” is being considered. This comprises land located north of the A264 from Faygate in
the west and extends in an arc north west towards Crawley, Gatwick Airport and the A23. To
the east, the site adjoins the neighbourhood of Ifield, in Crawley and Gatwick Airport is to the
north, both of which are key urban influences in this area.
5.3 For current purposes, Homes England consider that there are a number of potential options
to include within the Plan a commitment to the wider strategic opportunity to ensure there is
a strong policy and framework against which the opportunity can be delivered. One option
would be to prepare a dedicated joint Development Plan Document with Crawley Borough
Council in the form of an area action plan (AAP). Another option could be a requirement for
applicants of any early phase delivery to work with the Council to agree a strategic
framework and demonstrate compatibility with it. Whichever option is taken, there will be a
need to provide long term certainty to housing and infrastructure delivery across this plan
period and beyond, together with the ability to realise the benefits of the wider strategic
opportunity West of Crawley.
5.4 The use of an AAP will provide long term certainty to housing delivery across plan periods
and beyond, together with the ability to realise the benefits of the wider strategic
opportunity West of Crawley.
5.5 The benefits of allocating a wider strategic opportunity for 10,000 new homes include:
• The opportunity to meet long term housing in a comprehensively planned and sustainable
manner – providing clarity around how long-term housing needs for both Horsham and
Crawley (in line with the duty-to-cooperate) could be met, integrating with existing
communities alongside the delivery of new infrastructure as part of a long-term
comprehensive strategy.
• The opportunity to protect areas not suitable for development – providing long-term
defensible boundaries and protection against piecemeal development.
• The opportunity to deliver a step change in environmental enhancement – facilitating and
support low and zero carbon approaches for wider environmental gains.
• Providing greater certainty on the delivery of strategic transport infrastructure (including
the provision of a Crawley Western Link) – supporting the case for significant long-term
investment, promoting the use of modern sustainable transport modes and safeguarding
the opportunity to adapt to a low carbon future.
• Enabling a comprehensive approach to masterplanning and placemaking to create high
quality, well planned places for the future in line with the objectives of the Building better,
Building Beautiful agenda.
• The potential for the site to respond to key economic drivers identified in the Economic
Growth Assessment Update (2019), making available new employment land opportunities
and providing for the workforce needed to establish and grow other nearby employment
centres such as Manor Royal, Gatwick Airport, Horsham and Crawley Town Centres that
make a positive contribution to the regional and national economy.
• The opportunity to deliver large scale social and community infrastructure and facilities
(e.g. schools, health facilities and other community facilities) as part of accessible
neighbourhood centres.
5.6 The opportunity for longer term delivery of a new garden town is considered to provide
greater benefits and opportunities to maximise the sustainability of the scheme in
comparison to other opportunities within Horsham District. Commentary to support this
position is also included within Annex B to these representations.
5.7 In line with Para 72 of the NPPF, it is considered prudent for HDC to consider the potential for
large scale development in this area as part of this local plan review, although recognising
that the full development potential will be realised over multiple Plan periods.
5.8 In considering the opportunity for 10,000 new homes, Homes England has engaged positively
with major landowners and interested parties. Meaningful discussions have taken place and it
is expected that an allocation would compromise land located north of the A264 from
Faygate in the west (including SA291 that is identified in the Draft Local Plan as part of the
potential West of Crawley allocation) and would extend in an arc north west towards Crawley
(SA101) – see Figure 1.
Figure 1: HDC Site Allocations 101 and 291 within the context of a Wider Strategic Opportunity (Land West of
Crawley Garden town)
5.9 Subject to the strategic growth opportunity being supported, Homes England will work with
the Council, promoters of Site SA291 and other landowners to bring forward a strategic
framework (incorporating SA101 and SA291) that meets the long term needs identified in the
Strategic Housing Market Assessment (SHMA), in a way that supports the long term
economic expansion and success of the Gatwick Diamond and North West Sussex Functional
Economic Areas.
5.10 To provide the certainty needed for Horsham District Council to confidently take forward a
strategic growth area opportunity, the case for an allocation will be supported by a clear
strategy as to how the necessary investment in essential infrastructure can be provided that
meets future population growth.
5.11 As set out above, the allocation and delivery of SA101 as the first phase of a wider 10,000 unit
allocation is an important step in realising the wider garden town growth opportunity and will
contribute positively to a number of the Local Plan objectives and meet identified housing
needs. Similarly, proposed site allocation SA291, or wider allocations in the vicinity of the
A264, is also expected to make a positive contribution over the Plan period.
5.12 Within this context, and on the basis that there is a commitment from Homes England to
support a strategic growth opportunity in this location, it is important and considered
appropriate for Horsham District Council to allocate the full garden town comprising 10,000
new homes at this stage in order that:
• HDC and neighbouring authorities can demonstrate how duty to Cooperate requirements
can be met;
• the early phase delivery on SA101 (and potentially SA291) can plan for and be future
proofed to ensure they are fully integrated and that the benefits from the wider allocation
are maximised;
• important strategic transport corridors can be safeguarded;
• the necessary certainty is provided that supports long term investment strategies for
infrastructure planning and delivery;
• the necessary certainty is provided that supports the preparation and implementation of
key economic strategies – including Coast2Capital LEP Local Industrial Strategy and
preparation of the North Crawley Area Action Plan as proposed by Crawley Borough
Council ;
• there is a positive basis upon which Horsham District Council, Homes England,
landowners and other deliver partners can continue to identify and establish appropriate
delivery mechanisms; and
• secure opportunities to protect land outside of the strategic growth area, promoting long
term sustainable patterns of development and preventing settlement coalescence in
accordance with the objectives of draft Strategic Policy 29.
5.13 To achieve the above objectives and ensure that the HDC Plan is positively prepared and
meets the soundness tests set out in the NPPF, it is considered that the HDC Regulation 19
consultation should incorporate a strategy that seeks to:
• allocate sites within the opportunity areas where these can be delivered within the first 5
years and make a positive contribution to meeting identified housing and employment
needs (including SA101 and potentially SA291);
• provide clear ambition and commitment to larger scale development West of Crawley
that can deliver a sustainable new garden town community with a minimum of 10,000
homes and jobs across multiple plan periods (potentially as part of a wider allocation);
• establish clear guiding principles for the longer-term strategic growth opportunity to
guide the design and delivery of early phases allocated within this Local Plan;
• provide opportunities to deliver strategic infrastructure outside of the early Site
Allocations where these will assist in their delivery and help realise the potential of the
wider growth ambition; and
• should the wider growth area not be allocated at this stage, provide the necessary
mechanisms to safeguard the longer-term strategic growth opportunity, ensuring that it
isn’t prejudiced in the short – medium term.
5.14 As noted above, we consider that there are potentially a number of mechanisms that could
be explored to deliver the garden town growth opportunity for 10,000 new homes.

6. Specific Comments on Regulation 18 draft polices

6.1 The following representations are presented in the order in which policies are documented in
the Draft Local Plan. They include a response to Key Questions posed by HDC where
relevant. For clarity these are copied in advance of each representation that follows.
Chapter 3: Spatial Vision and Objectives – Key Questions
• Do you agree with the spatial context – is there anything else we should add?
• Do you agree with the objectives for the new Local Plan?
• Are there any others which you would suggest?
6.2 Homes England has reviewed the Spatial Vision and Objectives and consider these present an
ambitious but realistic set of guiding principles for the Local Plan. No amendments are
proposed, and Homes England looks forward to working with Horsham District Council to
demonstrate how a Strategic Allocation West of Crawley can make a significant contribution
to achieving these ambitions.
Chapter 4: Policies for Growth and Change – Key Questions
• Do you agree with the draft policies in this section? If not, what changes would you suggest?
6.3 Homes England has reviewed the draft policies and broadly support the text contained within
Chapter 4. The following amendment is, however, suggested in respect of Strategic Policy 3:
Settlement Expansion. Bullet point 5 states one aspect of the criteria that must be met in
demonstrating the acceptability of development outside Built Up Area Boundaries (BUAB). It
records that development will be supported where ‘The development is contained within an
existing defensible boundary and the landscape and townscape character features are
maintained and enhanced.’ Homes England recommends that this is amended to read: ‘The
development is contained within an existing defensible justified boundaries and the landscape
and townscape character features are maintained and enhanced.’ This amendment is
necessary to ensure the policy is both Justified and Effective thus recognising that in
developing masterplans that relate to settlement expansion it is in many cases appropriate to
establish new boundaries and not only rely on existing ones. In some cases, these may not
meet a definition of defensible but remain appropriate to the landscape and townscape
character features.

Chapter 5: Economic Development – Key Questions

• Do you agree with the draft policies in this section? If not, what changes would you suggest?

6.4 Homes England has reviewed the draft policies and broadly support the text contained within
Chapter 5. The following observations and amendments are recommended.
6.5 The Northern West Sussex Economic Growth Assessment 2019 that forms part of the Local
Plan evidence indicates current employment commitments (such as existing allocations and
planning permissions) broadly matches the employment needs generated by a population
growth derived from the housing requirements based on the Government’s Standard Method
(965 dwellings per annum). However, as set out under representations made to Chapter 6 in
respect of Housing Number Options, Homes England supports the case for HDC to plan for
the higher growth scenarios that seek to accommodate unmet housing needs of
neighbouring local planning authorities, and therefore intensification of existing sites and / or
additional employment land will be required to meet the future needs in the District over the
plan period which could increase the employment requirement overall.
6.6 Furthermore, it will be important that the final spatial strategy (both in terms employment
and housing) responds to and, where possible, supports wider strategic economic
development strategies within functional economic areas (e.g. Gatwick Diamond Strategy,
West Sussex Economic Growth Plan, C2C LEP Local Industrial Strategy and emerging
aspirations of Crawley Borough Council to facilitate significant expansion of Manor Royal
through the North Crawley Area Action Plan).
6.7 Within this context, Homes England supports in principle the requirement under Strategic
Policy 6: Economic Growth for all Strategic Allocations of 800 homes or more to provide
opportunities for employment and for people to live and work locally. However, Homes
England recommends that the following policy text is amended as indicated to ensure
appropriate flexibility is maintained for site specific employment solutions that support a
clear economic strategy that maximises local, sub-regional and economic potential.
6.8 All strategic site allocations must demonstrate how provision for one job (all Use Classes) for
each new dwelling will be provided for within the site or in justified cases within close proximity
to the site and accessible via sustainable modes of transport. This could include through
evidenced means such as home working, retail and community employment, and general
B1/B2/B8 employment opportunities.
6.9 This amendment is necessary to fulfil HDC’s duty to ensure the plan is justified and effective,
thus recognising that in some instances there are more established and appropriate locations
for employment that must be supported by significant housing delivery alongside jobs on
site. For example, Land West of Crawley exists within close proximity to the Borough
boundary of Crawley and within close proximity to Manor Royal, which is the principal
business location for Crawley, and instrumental to the success of the wider Gatwick
Diamond. Policy EC3 of the Crawley Borough Council Regulation 19 Local Plan sets out
specific policy to support the continued success of this employment location.
6.10 On this basis it is important for HDC Plan Policy to be prepared cognisant of its wider duty to
co-operate and recognise the potential for jobs to be provided for within close proximity to
site allocations (which may be outside of the HDC boundaries) where an overriding case for
offsite provision exists.
Chapter 6: Housing – Key Questions: Housing Number Options
• The work to understand the suitability, sustainability, delivery and infrastructure implications
is ongoing and your views on these issues are important to us and will feed into the options
that are taken forward for examination.
• Which of the housing options above do you think the Council should set as our housing
number?
• If you think the number should be different to the above what level of growth do you think we
should provide. What evidence do you have for this?
• What do you consider to be the challenges to this Council in bringing forward the increase in
housing development to meet the Governments unprecedented change in housing growth?
6.11 As summarised in the North West Sussex Strategic Housing Market Assessment (2019) under
Section 3 ‘Housing Market Geography and Spatial Relationships’ a range of previous studies
have considered issues relating to the housing market geography. These have identified a
‘Northern West Sussex’ Housing Market Area which (as a best fit to local authority
boundaries) comprises Crawley, Horsham and Mid Sussex. This has been tested and endorsed
at Local Plan Examinations in each of the three areas.
6.12 Under Strategic Policy H1 of the CBC Regulation 19 Submission Draft Local Plan there is
recognition that despite the draft plan making provision for the development of a minimum
5,355 new dwellings in the borough in the period 2020-2035, there will remain an unmet
housing need of approximately 5,925 dwellings arising from Crawley over the plan period.
The policy states that CBC will continue to work closely with its neighbouring authorities,
particularly those which form the Northern West Sussex Housing Market Area, in exploring
opportunities and resolving infrastructure and environmental constraints in order to meet
this need in sustainable locations. This will include continued assessment of potential urban
extensions to Crawley.
6.13 Homes England therefore strongly encourages HDC to advance Housing Growth Option 3 as
detailed under Strategic Policy 14: Options for Housing Growth. This option would meet
the local housing need and 5% buffer and provide around 400 homes each year to help meet
the unmet housing needs of Crawley and the Coastal Sussex area.
6.14 The Sustainability Appraisal of Growth Options recognises that allowing for higher growth
could support new service provision as well the viability of sustainable transport links in
Horsham. It would also be likely to deliver benefits in relation to addressing housing
affordability in the plan area as well as contributing to the housing need of neighbouring local
authority areas. It can also help to support ambitious economic growth within a nationally
important economic area.
6.15 Notwithstanding this, the Sustainability Appraisal does identify a number of risks associated
with the higher growth scenario including likely demand for higher amount of greenfield
land, potential to place development in closer proximity to sensitive environmental
receptors, higher value landscape and heritage assets, an increase in the number of private
vehicle journeys being made more regularly which will be to the detriment of air quality and
the District’s contribution to climate change).
6.16 At this assessment level, these risks are generic and are assessed on a Borough wide basis.
Homes England firmly believes that when considered in relation to individual sites, these risks
can be mitigated through site specific masterplanning and mitigation measures and
therefore should not be considered as a given when considering the potential to
accommodate higher growth levels. In some instances, the opportunities to maximise the
benefits from growth and minimise the impacts are only achievable where a sustainable
commitment to higher housing growth under option 3 is made.
Chapter 6: Housing – Key Questions: Potential Housing Allocation Options
• What are your views on the site assessment process, and the potential development sites
that are identified in this and the supporting documentation?
• How do you consider these sites would bring forward development that accords with wider
sustainable development principles that balances the need for economic growth with social
and environmental requirements as identified in the NPPF?
6.17 As set out above, Homes England supports the allocation of SA101 for a minimum of 3,250
homes as part of a wider strategic growth opportunity area for up to 10,000 homes that will
help deliver the garden town vision.
6.18 Homes England recognises that HDC needs approximately 1000 homes per annum to meet
its own Objectively Assessed Need and that HDC has not yet indicated the extent to which
such OAN should be met within Crawley’s administrative area. The Draft Local Plan does
however envisage that the Site has “the potential to deliver a very significant proportion of
[HDC’s] housing requirements”.
6.19 In addition, CBC is unable to deliver more than about 50% of its current OAN for housing.
CBC currently has a 5,925 shortfall in the Plan period. HDC is considering options to meet 200
or 400 of that shortfall per annum (or around 3600 or 7200 over the Plan period). The natural
location for that is to the west of Crawley at the Site.
6.20Making allocations under SA101 and SA291 would be insufficient to make a significant
contribution to both CBC’s and HDC’s AON. In contrast an allocation of 10,000 new homes at
Land West of Crawley would assist with the AON for both authorities whilst also providing for
future growth beyond the plan period (as part of the comprehensive whole) potentially
through to 2050.
6.21 This approach of allocating very large sites to meet needs both during and after the plan
period is well-established – and is a recognised (and successful) way of delivering major new
settlements giving the landowners and developers an incentive and opportunity to plan,
invest and deliver for the whole rather than just incremental parts of the whole.
Chapter 6: Housing – Key Questions: Strategic Site Principles
• Please consider the strategic site development principles set out in the draft policy above. We
would welcome your views on whether this policy captures all the requirements that new
development can provide, or whether there are any omissions. We would also welcome your
thoughts as to how the requirements set out in this policy can be practicably achieved and
how any obstacles that it may present can be addressed.
• Do you think the draft policy captures all the requirements that new development can
provide? If not, what would you add?
• How do you think the requirements in this policy could be practicably achieved? And how
could we address any obstacles?
6.22Homes England has reviewed the draft Strategic Site Principles detailed under Policy 15
and broadly supports the policy wording. However, the following amendments are
recommended.
6.23 Under Item2, the policy states that Masterplans will be expected to identify key areas of
biodiversity enhancement, demonstrating that a minimum of 10% biodiversity net gain can be
achieved. Whilst Homes England is committed to meeting this policy, we request clarification
is added to the supporting text or policy wording to define the metric to be used in calculating
10% net gain. We suggest that reference should be made to the Natural England Biodiversity
Metric (latest version at the time of writing is 2.0). This is to ensure that the Policy is justified
under the tests of Soundness.
6.24Under item 6, the policy refers to job provision of one new job per home. The wording of the
policy is recommended to be re-phrased as follows: Provide sufficient new employment
opportunities through new employment land and through other opportunities to meet the
principle of one new job per home within the site or in justified cases within close proximity and
accessible via sustainable modes of transport.
6.25 This amendment is consistent with our comments relating to Strategic Policy 6: Economic
Growth and is necessary to recognise that in some instances that are more established and
appropriate, locations for employment that must be supported alongside jobs on site. This
will ensure that the policy can be assessed as being positively prepared, justified and
effective.
6.26Whilst the draft Strategic Site principles are supported, it is considered that as preferred site
allocations are confirmed, there will be a need for more specific site criteria-based policies for
each of the Strategic Sites to be taken forward. In the absence of any intention or
commitment at this stage to prepare subsequent Local Plan Documents to guide
development on the strategic allocation, the inclusion of site specific policies will provide the
necessary policy framework and guidance for promoters, landowners and developers to bring
forward proposals at the earliest opportunity. This policy(ies) should include sufficient detail
to inform the comprehensive masterplanning and delivery of Land West of Crawley as a
whole, including reference to potential land assembly and delivery mechanisms (such as the
use of Compulsory Purchase Powers) that provides certainty around delivery.
Chapter 6: Housing – Key Questions: Affordable Housing
• Do you consider that, if supported by viability evidence, the target for providing affordable
housing on housing sites should be increased? If so, what % of affordable housing should the
Council be seeking?
• Should the Council seek to use the threshold for affordable housing of 10 dwellings on all
sites? Are there occasions when it may not be appropriate and if so, what should the
threshold be?
6.27 Homes England is committed to delivering a policy compliant level of affordable housing that
meets the needs identified in the North West Sussex Strategic Housing Market Assessment.
However, at this stage and in the absence of the Local Plan Viability Assessment (currently
being prepared) Homes England does not consider it appropriate to conclude whether a
variation to the target percentage of affordable housing is appropriate this stage. Homes
England note the possibility to increase this target up to 50% is being considered through the
viability testing. Homes England will comment as the evidence is presented for consultation.
6.28As the Government’s housing Agency, Homes England do, however, commend the
commitment that HDC will pursue alternative and innovative ways to deliver a range of
housing tenures in partnership with local registered providers including market, affordable
and social rent. Homes England also recognises that HDC is embarking on direct delivery of
affordable housing through a housing company as well as referencing opportunity for
Community Land Trusts (CLTs). Homes England has significant expertise in a range of
affordable housing tenure and delivery models and would be keen to ensure this policy and
the outcomes of the Viability Testing is considered with full appreciation of the opportunities
and support for different delivery models. These are shared ambitions and should SA101 be
progressed as a preferred site, there are opportunities for Homes England and HDC to work
in partnership to ensure this ambition is realised.
Chapter 6: Housing – Key Questions: Gypsy and Traveller Accommodation
• Do you agree with the draft policy on Gypsy and Traveller sites? If not, please give details as
to why not or how the policy could be changed.
• In terms of meeting the identified need for Gypsies, Travellers and Travelling Showpeople, do
you agree with the approach of intensifying existing authorised sites, if required, in addition
to identifying severalstrategic and non-strategic sites?
• If possible, do you think that the Council should allocate all identified need on several new
sites? Should these all be strategic (800 dwellings +), or a range of large and smaller sites?
6.29Homes England recognises the requirements of Strategic Policy 15, Point 4 for all Strategic
Sites to provide a range of housing types and tenure, including provision for Gypsies and
Travellers.
6.30 Homes England has previously responded to the Gypsy, Traveller & Travelling call for sites
exercise between 3 June 2019 and 30 August 2019. Under this response we stated that Land
West of Crawley could accommodate up to 15 Gypsy, Travellers or Travelling Show people
pitches. This was calculated using the DCLG Guidance note: Designing Gypsy and Traveller
Sites Good Practice Guide (May 2008). Whilst this has been withdrawn, it provided a useful
starting point in terms of the sizing pitches which are proposed to extend to 750m2
.
6.31 Pitches could be delivered as an integral part of the comprehensive development with
essential infrastructure and community facilities in close proximity.
6.32 With regard to Policy 24 – Gypsy, Traveller and Travelling Showpeople Accommodation
Homes England agree with the commitment for Council will meet the identified current and
future accommodation needs of Gypsies, Travellers and Travelling Showpeople in Horsham
District but do not consider it our position to comment in the spatial distribution of such sites.
Chapter 7: Conserving and Enhancing the Natural Environment – Key Questions
• Do you agree with the draft policies in this section? If not, what changes would you suggest?
6.33 Homes England has reviewed the draft policies and broadly support the text contained within
Chapter 7 The following observations and amendments are recommended.
Strategic Policy 29: Settlement Coalescence
6.34 The broad objectives of Policy 29 are supported. It is for HDC to determine the most
appropriate mechanism to meet the aims and the objectives. Whilst the opportunity for
Green Belt designation is noted, there may be other policy mechanisms – such as the use of
locally designated Strategic Gaps or Local Green Spaces that could also have role in meeting
these objectives.
6.35 Whatever mechanisms are chosen, it is important that they do not prejudice or frustrate the
long-term delivery of sustainable development especially in relation to larger strategic sites
where sustainable development opportunities will be realised over multiple Plan periods.
6.36Notwithstanding the above, as a minimum Strategic Policy 29: Settlement Coalescence
should be amended as follows under criteria a and b.
a) There are no significant effects arising from a reduction in the openness and ‘break’
between settlements
b) It does not generate negative or harmful urbanising effects within the retained ‘break’
between settlements, including artificial lighting, development along and/or the
widening of the roads between the settlements, and increased traffic movements.
6.37 These amendments are necessary to ensure that the policy is justified and effective in
accordance with the supporting text which provides “that recognises that several proposals
have been submitted to the Council for consideration as locations for strategic housing growth. A
number of these are in the key locations which have been identified as being most sensitive for
their potential for settlement coalescence. Whilst no final decisions have been made as to
whether these sites should be allocated, the sites are in locations where there has been sustained
pressure for development”.
6.38 Without the above amendments important strategic sites that will naturally have impact
upon existing gaps could fall foul of the strategic policy. Homes England considers that the
criteria must therefore focus on no negative or harmful impacts arising. Specifically, in
relation to proposals on Land West of Crawley, Homes England acknowledges that the
potential impact on this landscape area will need to be carefully considered taking account of
the local value of the area for local residents.
6.39 Recognising that there are several areas of historical importance on the western edge of
Crawley and elsewhere, we will have due regard to the updated Landscape Capacity
Assessment (2020) as proposals for SA101 and the wider area become more developed.
6.40 Strategic Policy 31: Green Infrastructure and Biodiversity should be amended under point 4
as follows: Development proposals will be expected to remove invasive species and will be
required to contribute to the enhancement of existing biodiversity and deliver, as a minimum, a
10% net gain through the delivery of appropriate on-site biodiversity net gain or, where this is
not practicable, to off-set the delivery to the Nature Recovery Network or using alternative land
in the district if in control of the applicant and meets biodiversity objectives.
6.41 This amendment is necessary to recognise that the policy as drafted may mean that
landowners cannot use their own land for biodiversity off-setting. It should be recognised
that if multiple land ownerships are held by a single landowner and land is within the HDC
planning boundary, then this could be a valid approach to biodiversity net gain objectives.
Chapter 9: Climate Change and Flooding – Key Questions
• Do you agree with the draft policies in this section? If not, what changes would you suggest?
6.42Homes England has reviewed the draft policies and broadly support the text contained within
Chapter 10. The following observations and amendments are recommended.
Strategic Policy 39 – Sustainable Design and Construction
6.43 The broad objectives of Policy 39 are supported. The following amendments are proposed to
enhance the effectiveness of its wording. Measure (a) should be re-worded as follows:
a) Development should minimise energy used through construction, minimise embodied
energy in materials chosen, and minimise construction and demolition waste and utilise
recycled and low-impact materials;
Chapter 10: Infrastructure, Transport and Healthy Communities – Key Questions
• Do you agree with the draft policies in this section? If not, what changes would you suggest?
6.44Homes England has reviewed the draft policies and broadly support the text contained within
Chapter 10. The following observations and amendments are recommended.
Policy 44 – Gatwick Airport Safeguarded Land
6.45Homes England recommends that the wording of this policy is updated to directly reference
CBC Regulation 19 Local Plan Strategic Policy SD3: North Crawley Area Action Plan which
acknowledges that at this stage there is no robust evidence that justifies the continued
safeguarding of land for Gatwick Airport expansion. This follows Gatwick Airport Limited
(GAL) having confirmed (29th August 2019)4 the process is now underway for the submission
of a Development Consent Order (DCO) seeking permission to bring its northern runway
alongside the main runway by the mid-2020s.
6.46Whilst at this stage Homes England accepts and acknowledges that the Regulation 19 draft
CBC local plan proposals will continue 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, such work (to commence within three months of adoption of the
Local Plan) should also (as part of the duty to cooperate) ensure that land within HDC is
appropriately considered. This amendment is necessary to ensure that the Draft Local Plan
remains positively prepared.
6.47 It is also noted that there has been no update to the strategic transport modelling or
Infrastructure Delivery Plan. Once the spatial strategy is finalised and preferred Site
Allocations are confirmed, it will be necessary to update these to identify infrastructure
requirements and identify appropriate delivery and funding mechanisms alongside viability
testing work.

7. Summary and Conclusion

7.1 We hope that the above, sets out the clear ambition of Homes England that Land West of
Crawley comes forward as part of a wider scheme that will deliver 10,000 new homes, which
in turn will contribute towards the Government’s objective to accelerate the delivery of new
homes.
7.2 There can be no doubt that SA101 should be allocated for at least 3,250 new homes. SA101
can clearly function as a standalone allocation. However, it is Homes England’s clear view
that significant benefits can be derived from an allocation for 10,000 new homes for Land
West of Crawley, with SA1010 comprising the first phase.
4 https://www.gatwickairport.com/business-community/future-plans/long-term-plans/
7.3 By progressing a strategic site that can deliver early and in their entirety within the next Plan
period, Horsham District Council will be able to address the significant and immediate
housing, employment and environmental challenges within the North West Sussex Housing
Market Area.
7.4 At the same time, there is a once in a generation opportunity for Horsham District Council,
working in partnership with Homes England to plan positively to realise the unrivalled long
term potential for land West of Crawley to deliver large scale, sustainable development that
maximises social, environmental and economic opportunities for existing communities and
future generations.