OCTOBER 29 2020 – REQUEST FROM HORSHAM DISTRICT COUNCIL TO CRAWLEY BOROUGH COUNCIL FOR COMMENTS ON THE SUBMITTED ENVIRONMENTAL IMPACT ASSESSMENT SCOPING OPINION FOR DEVELOPMENT ON LAND WEST OF IFIELD (HDC REF EIA/20/0004)

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ECONOMY AND PLANNING SERVICES
Contact: Mrs J. McPherson Our Ref: CR/2020/3002/EIA
Direct Line: (01293) 438577  Email: development.control@crawley.gov.uk
Direct Fax: (01293) 438495 Date: 27 October 2020
Horsham District Council
FAO Emma Parkes
Email to planning@horsham.gov.uk

Dear Madam

TOWN AND COUNTRY PLANNING ACTS
LOCATION: LAND WEST OF IFIELD
PROPOSAL: REQUEST FROM HORSHAM DISTRICT COUNCIL TO CRAWLEY BOROUGH
COUNCIL FOR COMMENTS ON THE SUBMITTED ENVIRONMENTAL IMPACT ASSESSMENT
SCOPING OPINION FOR DEVELOPMENT ON LAND WEST OF IFIELD (HDC REF EIA/20/0004).

I write with reference to your letter dated 6th October seeking the views of Crawley Borough Council
(CBC) on the information to be included in the Environmental Statement (ES) that would be submitted
by Homes England to accompany any planning application for development on land ‘West of Ifield’.

While the majority of the land within the red edged site boundary is within Horsham District, the
application site does extend into Crawley with around 25 hectares of the overall site within the Borough.

While the substantive built development would take place on HDC land, there are very significant
impacts for Crawley Borough and its residents.

Based on the information supplied, this would be a cross boundary planning application with the EIA
regulations requiring the production of a single scoping response in this case from Horsham District
Council (HDC) as lead authority. It should be noted however, that substantial weight should be
accorded to the comments made by CBC in this response as the cross boundary authority.

CBC has reviewed the information submitted in the ‘West of Ifield EIA Scoping Opinion Request’ (the
EIASR) dated 22nd September 2020 prepared by Homes England and has a number of comments and
recommendations to make in respect of the proposed scope of the ES to be prepared to accompany
any application.

The Borough Council has focussed its detailed comments on those topics comments which impact
most directly on the Borough (with the exception of transport where the technical expertise rests with
West Sussex County Council as the Highway Authority).
The attached response is structured under the headings used in the EIASR.

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Yours faithfully
Clem Smith
Head of Economy and Planning Services

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Part 1 – Introduction

1.1 The EIASR states that the proposed planning application for the development would be in
outline with ‘all matters reserved’. CBC have serious concerns about this approach firstly, given
the very limited description of the development and secondly, considering how realistic it would
be for any Local Planning Authority to assess an application with all matters reserved for a
development of this scale and magnitude given the known environmental and transport
constraints of the site. This is also considered a particularly high risk approach for the
applicants, Homes England, who are progressing this project ahead of the Crawley and
Horsham Local Plan reviews and without any certainty that the site would be allocated for
development later in the review process. Further explanation is given later in this response.

Part 2 – Site Context

2.1 There are concerns that the report does not explain accurately the context of the development
site. While it is accepted that this document only needs to provide a brief summary of the site
and surroundings, there is concern that there is no apparent understanding of the site’s context
in relation to Crawley Borough and that the importance of the land and its relationship to the
town is downplayed. Without a detailed understanding of the site context and character of the
area, there is concern that the impacts of the development on the borough may be
misrepresented in the ES.

2.2 In Section 2.1, the ‘small proportion of the site’ in Crawley Borough relates to around 25
hectares (around 12% of the site area). This is a significant area of the site. The site description
is vague and does not allow the reader to fully understand the site context. For example,
Gatwick Airport is not beyond Charlwood Road, there is a significant swathe of intervening open
countryside in-between.

2.3 The description of the site itself also seems confused. In paragraph 2.1.3, the site description is
unclear about Ifield Meadows which are not ‘to the east of the site’ but included within the red
line. Where is Ifield Park?

2.4 In section 2.2, the description of the surrounding area also seems inaccurate and, while it may
be mainly agricultural to the west of the site, the land to the east within Crawley Borough is very
clearly aligned with the residential edge of Crawley. While historic Ifield Village is along the
eastern boundary and the site includes land that contributes to the setting of Ifield village, which
is a Conservation Area, there is no reference whatsoever to the New Town neighbourhood of
Ifield which is just east of Rusper Road or to the development of Ifield West which extends
beyond the southern and eastern corner of Ifield Golf Course.

2.5 In paragraph 2.2.4, the description of the site and surroundings bears little resemblance to the
red edged site plan stating ‘the southern boundary adjoins the rear boundaries of properties
fronting Rusper Road’ suggesting perhaps a different site area and the whole analysis appears
to exclude any reference to the golf course or the relationship of this land as important section of
countryside along the western edge of Crawley.

2.6 The lack of understanding of the site and context is of significant concern. The EIASR does not
consider or accurately reflect the site characteristics or the relationship of the land as an
important section of countryside along the western edge of Crawley or to the wider town which
is a significant settlement with an important role in the wider economy of the area. This lack of
reference raises concerns that there could be a misunderstanding about the development
context and surroundings. The eastern edge of the site is very much linked to the built-up form
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of Crawley and due to this its character, and the way the land is used is perceived by residents
as the countryside edge of the town and an important recreational resource and point of access
to the countryside. This needs to be understood as part of the ES along with the movement
patterns and local linkages for Crawley residents into this area.

Part 3 – The Proposed Development

3.1 The description of the proposed development is unclear. While it is understood that up to 4,000
homes are envisaged for the land, details of the other infrastructure to support the proposal are
rather vague. The description of the project in paragraph 3.2.2 suggests that the proposals are
still evolving. For the social infrastructure, the school proposals seem fairly certain. However,
there is no indication given on indicative floorspace for other uses such as employment and
retail and therefore it is unclear how an ES would scope for an indeterminate amount of
floorspace. A range and upper floorspace limit should be specified.

3.2 In respect of highways the bullet point in paragraph 3.3.2 suggests the following:
‘Creation of a new road and bridge across the River Mole running on a south-west to north-west
alignment connecting to Charlwood Road/ Ifield Avenue.’
‘Options are currently being considered for a new junction of this road with Charlwood Road/
Ifield Avenue together with new creations into Rusper Road.’
‘A connection onto the section of Rusper Road that runs along the eastern site boundary is
being considered. This connection would cross field meadows and be for foot/cycle and
pedestrian use only.’

3.3 These proposals seem far from certain and do not take into account the CBC requirement as set
out in its Regulation 19 Local Plan (Policies H3g and ST4) for the provision of a comprehensive
Western Link Road (connecting from the A264 to the A23, north of County Oak) to serve any
development to the western side of Crawley, or the requirement for effective linkages through
Crawley’s neighbourhoods to the countryside and from any new neighbourhood to existing
neighbourhoods, the countryside and Crawley town centre by sustainable modes of transport. It
is unclear how the EIASR boundary has been determined given there is so much uncertainty
over the transport impacts.

3.4 It is noted that nowhere in the EIASR is there a clear description of the project works or any
understanding of how this might be phased or delivered. It is considered that the development
area of the ES should be drawn much wider to cover off all impacts including the alignment of a
potential Western Link Road. Furthermore, the description of works gives no indication of any
other infrastructure connections or improvements back into Crawley itself, the impact on road
infrastructure is likely to be significant. It is considered that the proposed ES boundary is too
tightly defined as new infrastructure may be needed well beyond this defined development
boundary. CBC does not support the suggested approach that more land could be included
within the ES as a minor amendment. An Indicative Search Corridor for a Western Link Road is
included on the Regulation 19 Crawley Borough Local Plan Proposals Map.

3.5 CBC is aware that Homes England has promoted a much more extensive development for up to
10,000 homes on land West of Ifield. While this is understood to be speculative, the other
proposed phases should be identified in some way or at least recognised. This is critical as
some of the proposed solutions for the ES and the proposed development may be affected by
the potential further expansion of the development over the longer term (for example flood
mitigation or biodiversity). It would also allow the cumulative impacts to be better assessed.
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3.6 CBC is concerned about the significant engineering and land re-profiling that may be required to
the River Mole to address any road link and the lack of detail about the potential extent of such
works in what is a highly environmentally sensitive part of the development site (not just for
flooding but also in terms of the impact on the landscape and heritage assets).

3.7 There is also some concern with the suggested maximum 18m height limit. While it is
understood that there may need to be some limited building heights to deal with landscape
sensitivities, there is some concern that an upper limit could prevent potential innovative designs
for higher residential development, such as more sustainable development in the centre of any
neighbourhood or the introduction of alternative energy sources such as CHP (which could
require a taller flue).

Part 4 – Methodology

4.1 CBC agree that the proposal would be EIA development and that there needs to be appropriate
consultation with relevant stakeholders. The consultee list set out in section 4.2 of the report
should be widened in particular to engage local Ward Members, resident groups and Crawley
residents. The method of public engagement to ensure meaningful feedback should also be
carefully considered given the restrictions in place as a result of the Covid pandemic and, in
particular, give consideration to those who may feel more isolated or excluded from engagement
at this time.

4.2 In addition, and specifically in relation to active travel matters, the following stakeholders should
be included:
· Active Travel England (announced in Gear Change – from 2021)
· Horsham District Cycling Forum, Crawley Walking & Cycling Forum.
· Local environmental groups

4.3 In respect of the scope and baseline for the assessment, CBC has concern about establishing
2020 as the current baseline for each topic. Due to the pandemic, 2020 is not a typical year and
for example, vehicle traffic levels and aircraft movements have been considerably reduced. As
a result the environment is also quieter and there are potentially changes in levels of pollution.
CBC would expect the EIA to rely on pre- pandemic data as the baseline for impacts such as
traffic, air pollution and noise because 2020 is not representative of these impacts.

4.4 The other baseline years in the assessment are far from clear and again suggest that there is
insufficient certainty about the timing, phasing or the project or its impacts. These should be
agreed with the two LPAs once the project is further developed although some specific
baselines have been suggested for different topics within the subject areas later in this
response.

4.5 The cumulative effects assessment is important, but the level of detail provided in section 4.8 of
the report and Appendix B and the rationale for their inclusion is unclear. The illustrative plan in
Appendix B and attached table identifies developments such as residential from a scale of 10
units and above as a longlist. However, the EIASR suggests in paragraph 4.8.3 that the in combination cumulative effects assessments will be on very major projects, such as
development of more than 200 residential units or employment floorspace of over 10,000 sq m.
This would exclude many of the residential sites within Crawley which are of more limited
capacity yet cumulatively generate increased demand on the town’s infrastructure. CBC does
not consider that the approach set out in paragraph 4.8.3 is sufficiently refined to assess the
cumulative impacts from other planned development in the borough. The thresholds need to be
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lowered to factor the smaller residential sites and to ensure that the cumulative impacts are not
under-estimated.

4.6 Furthermore, the cumulative assessment should make allowance for likely development within
the next Local Plan period (based on the emerging Local Plan reviews) as the timing of this
proposal, if permitted, would be within the emerging plan period.

4.7 Within the Scoping Table for Major Accidents and Disasters (Table 4.1) it is considered that
under adverse weather a severe heatwave event should be included and factors such as
overheating should be addressed under the adverse weather category.

4.8 Table 4.2 proposes to exclude ‘waste and resource management’ from the scope of the ES on
the basis that these would be considered within standalone document appended to the ES. The
logic of this exclusion is not clear and it is not considered to be justified. The availability or
otherwise of information about the development’s impacts from other documents which are not
themselves part of an ES process should have no bearing on the scope of the ES itself,
although they may inform the ES. Given that waste and resource management have potential
impacts associated with climate change, these should form part of the ES in relation to climate
change.

4.9 CBC has serious concerns about the proposed scope of the planning application (set out in
paragraph 4.14) which proposes to reserve ‘all matters’. The timing of this EIASR is challenging
as this proposal is running parallel with both authorities Local Plan reviews. The ES must
therefore take full account of the emerging policy requirements from both the HDC
Regulation 18 and CBC Regulation 19 Local Plans (and any subsequent revisions that
may follow). The ES needs to ensure that it remains flexible to assess any emerging
parameters that may arise as the Local Plan processes continue. It is noted that there is no
reference in Section 16 ‘References’ to either of Crawley Borough Council’s emerging Local
Plan Review documents (Regulation 18 or Regulation 19). These plans give clear guidance on
the policy direction for the Borough, the aspirations of the Council in respect to matters of
design, ecology, sustainable construction, infrastructure etc. and the requirements which must
be addressed within the ES.

4.10 While the timing of the planning application is not explicitly stated, it is indicated as being
sometime in 2021. CBC has serious concerns about the progression of this application ahead
of the adoption of the new Crawley Borough Local Plan and the new Horsham District Local
Plan. Both these documents are currently being prepared with the benefit of extensive evidence
bases and detailed background information. Such an application ahead of the Examination and
adoption of these plans would represent a Departure and, dependant on the precise timing of
the submission, could conflict with the guidance in paragraphs 49 and 50 in the NPPF.

4.11 CBC consider that, even if the site were proposed to be allocated by Horsham, the proposed
timing of the application could be well in advance of any Public Examination of the Horsham
District Local Plan when all assumptions on this site and its environmental impacts should be
considered along with the Local Authority evidence base to support its arguments. The ES is
therefore proceeding at risk ahead of any new policies being agreed or endorsed by either Local
Planning Authority (LPA).

4.12 Given that there is no certainty at this stage even about the principle of the development, an
outline application with no detailed matters resolved is considered inappropriate. The site is
known to be very environmentally sensitive and has considerable transport constraints. A
detailed access strategy and precise details of a means of access to the site is considered to be
a minimum requirement as, without this, no development could proceed. This should include
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addressing the current requirement within the CBC Regulation 19 plan for a full Western Link
Road. Furthermore, if the application were to proceed prior to formal adoption of the Horsham
District Local Plan and assuming it is allocated as a housing site, any application would need to
provide additional robust information to support the proposal in order to be certain of layout and
phasing and to demonstrate it could meet the emerging policies.

4.13 The suggested planning application documents and drawings for approval have not been
discussed to date with CBC and would need to be subject to verification against validation
checklists. The expectation is that any planning application would need to be supported by a
robust evidence base and this should include an ‘Existing Character Assessment’ providing
background evidence on the constraints, movements and existing character of the area which in
turn should be used to inform the structuring principles of any development. CBC consider that
this document is essential to any submission and should be added to the EIASR document list.

PROPOSED SCOPE OF THE ASSESSMENT

Part 5 – Agriculture and Soils

5.1 CBC has no specific comments to make on this section of the assessment as there is no land in
active agricultural use within the development area within the Borough boundary. It is noted
however, that the submitted land classification maps have discrepancies between them in
respect of the agricultural land classification and extent of the land uses along the settlement
boundary, this evidence will need to be updated.

Part 6 – Air Quality

6.1 The report identifies the likely significant effects of the development in the air quality study area
(exact area yet to be defined) and how these are subsequently to be assessed and reported
within the ES at both the construction and operational phases of the development.

6.2 CBC consider that the Air Quality Assessment methodology outlined in the report is acceptable,
subject to the following points:
· Assessment Process and Study Area: Due to the size and duration of the construction phase,
as well as uncertainty of future baseline projections, the council would expect the assessment
process to follow a conservative approach and precautionary study area. This is particularly
relevant in areas where there are existing residential receptors within 200m of the likely routes,
or where temporary traffic management schemes will displace traffic onto local roads where
increased emissions may have significant impact.
· Emissions mitigation: The report acknowledges the Air Quality and Emissions Mitigation
Guidance for Sussex (2020) (AQEMG) as a key factor in the assessment methodology.
However, it does not specifically reference this document under Section 6.6 Potential Mitigation
Measures. This should be included.
· The assessment methodology should include a damage cost calculation and an emission
mitigation statement detailing proposed measures to mitigate the impacts. These measures
must exceed minimum policy requirements in order to satisfy the requirements of the Sussex
AQEMG. The estimated value of the proposed measures should not be less than the
environmental damage costs, and the package of mitigation measures should be agreed.
· Model Verification If predicted results from the model differ significantly from measured
concentrations, the choice of suitable additional sites for model verification should be agreed
with the Councils (CBC and HDC).

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Part 7 – Biodiversity

7.1 In addition to the consultees listed, further consultation should involve the CBC arboricultural
officer in so far as impacts relating to trees within the Borough boundary and CBC Amenity
Services who manage the playing field adjacent to the southeast boundary of the site.

7.2 CBC consider that the impact of the development on the Local Green Space designation (Policy
ENV3 in the adopted Crawley Borough Local Plan 2015-2030 (CBLP) at Ifield Brook Meadows
and Rusper Road playing fields should be scoped into the ES. This is the only designation of its
kind in the Borough and one of the key attributes for its safeguarding under this policy relates to
its value for wildlife.

7.3 CBC’s ecological advisor considers that, while further bat survey work is planned, insufficient
consideration has been given to baseline data or impact assessment for rarer Annex II species.
The acoustic surveys to-date show the presence of Barbastelle bats. The area may also support
Bechstein’s bats which have recently been recorded on woodland on the western side of
Gatwick airport (near the Boeing Hangar) and, although woodland specialists, would also be
affected by landscape-scale impacts on commuting and foraging areas and may often roost in
non-woodland trees such as those found in hedgerows. Bechstein’s bats cannot be adequately
surveyed for using acoustic bat detectors as their quiet calls and high canopy foraging strategy
means they are often undetected. Even where calls are recorded there is no scientifically robust
way to separate the calls from other Myotis species. Trapping methods are the only way to
determine presence of this species. Trapping also provides a means to identify if breeding
females are using habitats, meaning they will be of increased importance to supporting breeding
colonies. The only way to understand foraging patterns of both Bechstein’s and Barbastelle is
through radio tracking studies and it also provides a more reliable way to identify roosts,
especially maternity roosts, than basic survey techniques. Whilst these techniques are more
intrusive than basic methods, given the scale of the proposed development in proximity to
suitable habitat for these rarest UK bat species, this considered to be justified to allow the
impacts to be properly understood and adequately mitigated in accordance with NPPF and local
plan requirements. This requirement should be scoped into the ES.

7.4 In respect of the potential effects set out in paragraphs 7.5.2 and 7.5.3, the ES should be clear
on the synergies between drainage and ecology impacts both upstream and downstream from
the site as any increase in water flow to a water course, change to run off rates, changes to the
floodplain or the physical form of the watercourse could impact on the ecology of the
watercourse (including any increased sediment loading or contaminants). The ecological impact
of the development on the fluvial habitat should be specifically referenced. Impacts from the
development could be more far reaching than the identified ecologically sensitive sites set out in
the EIASR, therefore impact on the watercourses upstream and downstream should be scoped
into the ES (assessed and mitigation measures identified).

7.5 In section 7.6 the sustainable mitigation measures should include opportunities to design for
nature within the fabric of the built environment (within buildings including dwellings and other
structures) and should not just be considered as standalone features like wildlife tunnels or
pockets of habit left within the site. This should be scoped into the ES.

7.6 The mitigation list at 7.6 makes no reference to the enhancement of biodiversity which should
be included as a requirement of this development, to be consistent with the Government
Position set out in its 25 year Environment Plan (2018) (and reflected in the CBLP – Policy
ENV2) and paragraph 170 of the NPPF to halt the loss of biodiversity and move to net gain.

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Part 8 – Climate Change

8.1 Under Section 8.3 of the report the following are policies and legislation should be added to the
account in the ES as they are relevant to the Environmental Impact Assessment for the
development:
· Building Regulations Approved Documents F, G, H and L (as updated)
· The UK’s Industrial Strategy (2017)
· Industrial Strategy: The Grand Challenges (2017, as updated)
· Spring Statement 2019: Written Ministerial Statement (includes commitment to introduction
of Future Homes Standard and mandating end of fossil-fuel heating in new-builds from
2025)
· The Future Homes Standard: changes to Part L and Part F of the Building Regulations for
new dwellings (2019)
· Planning for the Future: White Paper August 2020
· Committee on Climate Change (CCC), UK Housing Fit for the Future (Feb 2019)

8.2 In terms of methodologies the following are considered to be relevant:
· The Government’s Standard Assessment Procedure for the Energy Rating of Dwellings
(SAP) 2012
· The Government’s Standard Assessment Procedure for the Energy Rating of Dwellings
(SAP) 10.1 (draft) (2019)

8.3 It is considered that the following documents should be added to the account of Local Policies
which are relevant to the ES for the development (relevant to Surface Water Resources and
Flood Risk and Transport as well as Climate Change):
· Crawley 2030: Crawley Borough Local Plan 2015-2030 (2015)
· Emerging Crawley Borough Local Plan 2021-36 (Regulation 19 draft)
· Planning and Climate Change Supplementary Planning Document (Crawley Borough
Council, 2016)
· Climate Emergency Declaration (Crawley Borough Council, 2019)
· New Directions for Crawley: Draft Transport Strategy (2020)
· Crawley Draft Local Cycling and Walking Infrastructure Plan (2020)

8.4 Under section 8.3.11 the Report proposes to undertake the Greenhouse Gas Assessment in line
with principles set out in PAS 2080: 2016. This document is not freely accessible and it is
therefore not possible to comment in detail on the appropriateness or otherwise of this
approach. CBC consider that the methodology used in the Environmental Statement for the
Greenhouse Gas Assessment must be transparent and capable of being followed on the basis
of information in the public domain. It is also noted that the PAS 2080: 2016 document is
subtitled ‘Carbon management in infrastructure’, whereas the proposed development mainly
primarily of housing. CBC therefore questions whether this document is an appropriate
framework for consideration of the emissions of the proposed development. It is therefore
considered that any reference made to this document as a basis for the approach taken in the
EIA must include justification as to its relevance in respect of the proposed development.

8.5 Under paragraphs 8.3.15 and 8.3.16 the descriptions of the methodology for assessment in
respect of Climate Change Resilience and In-Combination Climate Change Impact lack detail
and simply refer to ‘qualitative assessment based on professional judgment and IEMA guidance’
in terms of identifying specific impacts. Given potential impacts involved, including overheating,
exacerbation of the urban heat island effect and water supply, it is queried how useful such
qualitative assessments can be. CBC consider that these assessments should seek to establish
a quantitative basis as far as possible, and include reference to recognised quantitative
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benchmarks or concepts, so that the assessment can easily be compared with other similar
assessments. It is also noted that IEMA guidance is not freely accessible, and in these
circumstances it is not considered acceptable merely to cite this source as justification for a
proposed approach without setting out the underlying justification.

8.6 In paragraphs 8.4.1 and 8.4.2 the proposed approach to the definition of potential significant
effect in respect of greenhouse gas emissions is not considered adequate. Simply to place the
greenhouse gas emissions from the development within the overall UK Carbon budget offers no
insight into the extent to which the proposed emissions are consistent with international, national
and local legislation and targets, which in turn based on an assessment of a threshold for the
prevention of catastrophic climate change. Given the difficulty of achieving reductions in
emissions through the retrofit of existing developments, compliance with the overall carbon
budgets requires that emissions from new builds to be brought down to net zero as quickly as
possible. The proportion of the forthcoming UK carbon budgets realistically available for new
build residential developments is thus only a tiny fraction of the overall budgets, and the
assessment of significant impact needs to take account of this context. Moreover, the carbon
budgets identified only extend to 2032, whereas the ES purports to assess the impact of the
development over a 60 year period following construction, i.e. into the 2080s. This extends well
beyond the point at which UK emissions are required to reach net zero. Clearly the emissions
arising in later years will have no meaningful relationship to carbon budgets for the period up to
2032, but will instead arise in a context where scope to accommodate a net contribution of
greenhouse gas emissions has vanished. The threshold for identifying potential significant
impact should accordingly be proportionately reduced over the lifetime of the development to
reflect this reality.

8.7 In paragraph 8.3.11 the inclusion of Transport Emissions, including emissions from traffic arising
from the development during its operational phase, as part of the assessment of greenhouse
gas emissions is strongly supported. The ES should seek to model these emissions for the
whole lifetime of the development, while making clear what assumptions have been made and
what difficulties have been encountered. The treatment of this issue in the ES, and the
discussion of mitigation measures should cross-refer to the transport section of the ES.

8.8 The discussion of the assessment of Climate Change Resilience lacks detail in terms of the
types and range of climate change impacts which are to be considered. It is not clear whether
table 8.4, listing ‘examples of weather events’ and associated effects is intended to be
comprehensive in this regard. Table 8.5 meanwhile includes a range of impacts which do not
appear to be directly relevant to climate change resilience.

8.9 One key issue related to climate change resilience which does not appear to be given adequate
treatment in the report is water stress, and associated impacts of drought/water shortage. Policy
ENV9 in the current CBLP specifically highlights this issue and that the Borough is in an area of
serious water stress. Water stress is mentioned in table 8.4, but there is no further discussion,
and the treatment of this issue in the section on Surface Water Management and Flood Risk
does not seem adequate, notwithstanding the concerns identified as being raised by Southern
Water, for example no potential mitigation measures relating to this area are suggested. Impacts
associated with water stress (both on the study area itself, and on the wider area) will need to
be considered as part of the assessment of climate change resilience, and as part of the
assessment of impacts linked to Surface Water Management and Flood Risk and must be
scoped into the ES.

8.10 Section 8.5 does not seem to make any attempt to assess the baseline greenhouse gas
emissions of the study area. Various UK wide statistics on emissions and construction activity
are cited, but it is not clear what relevance these have to the current proposal. A rough baseline
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position could be established based on the buildings and activities within the study area and
their operational requirements.

8.11 Overall it is considered that the ES would need to include the following information in respect of
climate change in order to comply with Regulation 18 of the Environmental Impact Assessment
Regulations:
– A description of the baseline scenarios in respect of climate change mitigation and
adaptation and an outline of their likely evolution without implementation of the development
as far as natural changes from the baseline scenario can be assessed with reasonable effort
on the basis of the availability of environmental information and scientific knowledge.
– Energy demand (gross and net where applicable, i.e. where on-site generation is proposed
to meet some development needs): to be expressed as a range in so far as this is
uncertain/still to be established, with an account of the methodology used to calculate this
(construction and operational phases)
– Water demand: to be expressed as a range in so far as this is uncertain/still to be
established, with an account of the methodology used to calculate this (construction and
operational phases)
– Greenhouse gas emissions: to be expressed as a range in so far as this is uncertain/still to
be established, with an account of the methodology used to calculate this (construction and
operational phases)
– Heat losses from the development: to be expressed as a range in so far as this is
uncertain/still to be established, with an account of the methodology used to calculate this
(construction and operational phases)
– A description of reasonable alternatives in terms of the treatment of waste during the
construction phase of the development, and an indication of the main reasons for selecting
the chosen option, including a comparison of the environmental effects, and a description of
the methodology used in this comparison
– A description of reasonable alternatives in terms of energy-generating and energy- and
water-consuming technologies (including construction materials) proposed to be used in the
construction and operational phases, and an indication of the main reasons for selecting the
chosen option, including a comparison of the environmental effects, and a description of the
methodology used in this comparison
– A description of reasonable alternatives in terms of transport strategies and access
measures to be used in the construction and operational phases, and an indication of the
main reasons for selecting the chosen option, including a comparison of the environmental
effects, and a description of the methodology used in this comparison
– A description of anticipated health impacts arising from overheating during the lifetime of the
development, and a description of the methodology used to assess this (construction and
operational phases)
– A description of anticipated impacts on water supply within study area during the lifetime of
the development, and a description of the methodology used to assess this (construction
and operational phases)
– A description of the forecasting methods or evidence, used to identify and assess the
development’s contribution to and vulnerability to climate change, including details of
difficulties (for example technical deficiencies or lack of knowledge) encountered compiling
the required information and the main uncertainties involved.
– A description of the measures envisaged to avoid, prevent, reduce or, if possible, offset any
identified significant adverse effects in terms of contribution to and vulnerability to climate
change and, where appropriate, of any proposed monitoring arrangements (for example the
preparation of a post-project analysis). That description should explain the extent, to which
significant adverse effects on the environment are avoided, prevented, reduced or offset,
and should cover both the construction and operational phases.

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Part 9 – Cultural Heritage

9.1 Under paragraph 9.3.2 ‘relevant guidance and methodology’, the Ifield Village Conservation
Area Statement has been omitted. This must be considered as part of the assessment along
with any new background evidence.

9.2 CBC has consulted its archaeological advisor on the EIRSR who has raised the following
comments:
· The land with Crawley Borough is of a significant size, and largely undeveloped which
indicates that there is a high potential for hitherto unknown below ground archaeological
Heritage Assets being present. In addition, the area is adjacent to several identified
Archaeological Notification Areas relating to; The Medieval Church of St Margaret, Ifield
Forge, and more generally relating to the Iron Ore industry. The boundaries of these are
indicative and remains associated with each of these could extend beyond the boundaries,
with significant industrial remains particularly likely along the banks of the Ifield Brook.
Therefore the potential impact on below ground surviving archaeological horizons is large
and therefore along with known Heritage Assets, the potential for previously unknown below
ground Heritage Assets needs to be considered and explored in relation to this proposal.
· The EIASR states that a full Cultural Heritage Assessment will be produced as part of the
ES including Archaeology. CBC are in agreement with the scope and sources of
archaeological advice to be consulted (as previously advised by HDC’s archaeological
advisor) which are considered appropriate to ensure that Heritage Assets across the entirety
of the proposed development site are suitably considered, and to create a more accurate
picture of the site’s archaeological potential.
· Once the desk-based assessment section of the ES has been completed the conclusions
should also consider any need for, and scope of, a field evaluation of the site to better clarify
the potential. If the site retains potential which needs to be further defined, in order for
appropriate mitigation measures to be developed, then a programme of evaluation will
determine, as far as is possible, the location, extent, date, character, condition, significance
and quality of any archaeological remains. This may need to be completed in advance of any
further decision making on the application, or the work may be able to be secured by an
appropriately worded condition on the planning consent. The results of the assessment
combined with the results of any subsequent evaluation will inform the need for, and scope of,
any further mitigation measures that might be necessary in response to the proposals.

9.3 The CBC Listed Building and Conservation advisor has also commented as set out below:

9.4 While just outside the Borough, the EIASR makes reference to Ifield Court Scheduled Ancient
Monument (SAM) effectively becoming an island within the proposed development site. There is
therefore potential harm to this nationally important designated heritage asset which currently
occupies a rural setting surrounded in all aspects by open countryside that affords far reaching
views due to the topography of the site. Any ‘built form’ development therefore has the capacity
to cause harm in the intermediate and far reaching view. Whilst this harm will not be ‘physical’
the impact upon historic context and legibility is likely to be at the high end of less than
substantial.

9.5 While it is noted that Historic England have been consulted, that there is no planned built form in
the vicinity of the SAM and that extensive green areas are proposed in this vicinity, any
development is likely to affect the skyscape which forms part of the setting of the SAM. Leading
on from this, if the premise is to provide an undeveloped zone around the SAM, then it is likely
that there will be built form impacting upon the setting of both Ifield Village Conservation area
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and its listed buildings. While no ‘tall’ buildings (5-storeys) are proposed to be located near the
SAM (addressed by moving the buildings further away) in doing this, this may have further
implications upon the remaining Designated Heritage Assets within Crawley’s borough and, as
such, a similar assurance is necessary to protect the setting of Ifield Village Conservation area
and its listed buildings.

9.6 The ES assessment of setting of Ifield Conservation Area should establish all the buildings that
positively contribute to the special character of the area and consequently an impact
assessment of the setting of these buildings should also be included. The assessment should
identify important views / vistas into and out of the conservation area which should be preserved
in accordance with the NPPF Chapter 16. Further research is necessary to establish the
historic context of Ifield and its association with the surrounding land which should inform any
proposed development design.

9.7 In table 9.2 it is noted that ‘All heritage work will be undertaken by qualified heritage consultants
who are members of the Chartered Institute for Archaeologists.’ Whilst this accreditation is
important, particularly when considering the impact upon buried archaeology, the built heritage
aspects are equally important and as such this aspect of the ES should be undertaken by
consultants accredited to the IHBC (Institute of Historic Building Conservation).

9.8 Finally it should be noted that the introduction of natural screening should not be considered to
mitigate against ‘harm’.

Part 10 – Landscape and Visual Impact (Landscape Townscape and Visual resources)

10.1 In relation to landscape and visual impact, CBC have no expertise to comment in detail on the
LIVA. The key points to be considered in the ES in respect of the town are:
· the importance of the countryside west of Ifield to the setting of the town, the rural character
of Ifield Village and wooded/ well landscaped and wooded character of the new town.
· The value of the landscape and countryside west of Ifield Brook beyond the CBC boundary
to the character and setting of Ifield Conservation Area and St Margarets Church and
ensuring that any impact views of the church from the development site and beyond are fully
assessed and impacts mitigated.

Part 11 – Noise and Vibration

11.1 There is general agreement with the scoping document subject to the following detailed
comments.
11.2 Paragraph 11.3.24 relates to Operational Plant and Commercial Development. With regards the
assessment using BS4142 where the development affects noise-sensitive dwellings in Crawley
it would be expected that the noise rating level will not exceed the background LA90 and to
prevent background creep in mixed commercial residential areas the LA90 should be 10dB below
the LAeq. Where there are commercial noise sources where assessment using the BS4142
standard is not recommended then early discussions with HDC and/or CBC (depending on
location) should be sought.
11.3 In paragraph 11.3.29, it should be noted that the internal noise levels quoted in BS8233:2014
relate to steady external noise sources (i.e. the distant hum of traffic) and not noise made up on
intermittent events like aircraft and passing traffic in close proximity, in such circumstances the
WHO standard for 45LAmax ay night should be used in conjunction with the levels in BS8233. If
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internal noise levels are likely to be exceeded those set down in BS8233 then appropriate
mitigation must be employed following the principals set out in ProPG and the Sussex: Planning
& Noise Guidance (section 5.5.5) in conjunction with a summer overheating and ventilation
strategy (prioritising the use of natural ventilation over mechanical) to create an acceptable
internal living environment.

Part 12 – Socio Economic Effects and Health

12.1 The impacts of the development on Crawley Borough and in particular on residents on the
western side of the town will be considerable. The impacts on existing residents and local
infrastructure from any new population must be fully understood and either mitigated or new
provision made.

12.2 With regard to further consultation, the CBC Housing Enabling and Development Manager can
advise on matters in relation to Affordable Housing and the CBC Community Services team
should also be considered a key stakeholder.

12.3 In respect of the methodology, reference should be made to both the emerging Local Plans and
their related evidence bases which provide an more up to date picture of the Borough and
District. In respect of economic impacts, HDC and CBC have produced an Economic Growth
Assessment in January 2020 with more recent updates. Crawley skills data is also relevant and
updated unemployment figures should also be reviewed given the impact on Crawley from the
ongoing Covid pandemic. The joint Strategic Housing Market Assessment should also be
referenced.

12.4 The EIASR (paragraph 12.3.8) is not clear on the study area for this chapter or what level the
data would be collected, however it should be anticipated that any new occupants would identify
with Crawley and would be dependent on its infrastructure and services. The document does
acknowledge that the population and economic data for HDC and CBC is quite different and
there needs to be an appropriate balance struck between the needs of Crawley and Horsham
residents.

12.5 CBC consider that, due to the development’s location and anticipated close links with Crawley,
the needs of Crawley residents should strongly inform the housing mix, services and community
infrastructure to be provided in the proposed neighbourhood. The baseline data needs to
clearly explain and capture the differences in terms of housing need, affordable housing and the
cultural needs of the community but any development would be expected to address some of
Crawley’s housing need.

12.6 Paragraph 12.3.10 in respect of the community services assessment methodology suggests an
existing facility audit but should also be informed by community engagement to ascertain not
just what is currently provided but where there is a perceived lack of provision. This is
particularly important in establishing the diverse cultural and social needs within the town. A
cultural needs audit is recommended as part of the baseline data.

12.7 Other community needs across both areas should also be considered and this should include
data on Gypsy, Travellers and Travelling Showpeople.

12.8 In relation to the health documents should be considered: ‘Public Health England Working
Together to Promote Active Travel (May 2016)’ document should be considered and key
stakeholders should include the Crawley Walking and Cycling Forums and CBC Wellbeing
services
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12.9 In paragraph 12.4.20, the health profile should look more specifically at those indicators that are
specifically affected and influenced by the built environment. For example, obesity, health issues
caused by inactivity and premature deaths caused by poor air quality should be considered. The
work should also consider the impacts, such as aircraft noise, which have documented impacts
on health and would affect the development.

12.10 In table 12.3 ‘Socio-Economics and Health – Resources and Receptors’ should include
active travel as a resource (this is walking and cycling on their own or as part of a multi-modal
journey (including public transport) for transport) Transport systems and the wider built
environment play a crucial role by either promoting or hindering physical activity.

12.11 Levels of walking & cycling and public transport use for all types of journeys including
commuting and school trips should be included as other sources of data (paragraph 12.4.23).

12.12 There is little detail about mitigation measures for health impact in paragraph 12.6.7 for the
operational phase of the development. This section should be broadened once the baseline
data is collated and the details of the development are better understood.

Part 13 – Surface Water Resources and Flood Risk (Water Environment)

13.1 Paragraph 13.3.1 refers to relevant guidance and needs to include and take of account of the
more recent CBC Local Plan Review documents (Regulation 19) and its associated background
documents which include an updated Joint Water Cycle Study (covering Crawley, Horsham,
Reigate and Banstead and Mid Sussex). The Water Cycle Study has highlighted a concern with
water abstraction at Hardham due to its potential impacts on the Arun Valley SAC, SPA &
Ramsar. This applies to Horsham and Crawley and should be considered as part of this ES.
Reference should also be made to the updated Strategic Flood Risk Assessment (joint Crawley
and Horsham).

13.2 CBC have no detailed comments to make on the proposed methodology in respect of surface
water and flood risk however, the drainage officer has requested that the following key principles
are adopted:
· The developer should ensure that all proposed buildings and associated structures including
SuDS should be designed and built outside the flood plain.
· A Surface water management plan should be planned to achieve the full benefits of the four
elements of SuDS i.e. water quantity, quality, amenity and biodiversity.
· The developer should note that land raising in any form or shape within Ifield Brook
Meadows will not be accepted.

Part 14 – Transport

14.1 CBC consider that the detailed advice from West Sussex County Council as the Local Highway
Authority and Highways England should be relied upon in respect of transport modelling and
traffic impacts.

14.2 It should be noted however, that the impact on the local road network within Crawley is a key
concern as there are existing problems with traffic and congestion on the west side of Crawley.
The Council’s position with regard to any further development on the western side of Crawley is
that there is a requirement for a Western Link Road. This has been ignored by this
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development proposal and a deviation from such a requirement should at the very least be
robustly demonstrated. It is difficult to see how the Link Road issues could be adequately
addressed by an outline application with all matters reserved. The Link Road would form a
fundamental part of the development, not something that could be added later.

14.3 The cumulative impact of this development and others planned on the highway network is also
of particular concern. In advance of any certainty on housing numbers within future Local Plans,
and ahead of any transport modelling outputs for the emerging Local Plans, modelling for this
development is considered at best challenging. The ES should not ignore the fact that the
applicants have already suggested publically that more extensive development to the west of
Crawley, beyond the current scheme, could be promoted and must be mindful of future further
development and how this infrastructure could be accommodated.

14.4 In respect of cycling, the following documents should be referred to:
· West Sussex Cycling Design Guide – A guide for Developers, Planners and Engineers
(2019)
· DfT Policy Paper: Gear Change – a bold vision for cycling & walking (July 2020)
· DfT local transport note LTN1/20 – Cycle Infrastructure Design (July 2020)

14.5 In addition to those listed in paragraph 14.2.2 it is considered that the content of the TA and
associated ES chapter should also address:
· Pedestrian facilities (including seating to enable walking by those less mobile)
· Accessibility for people on bikes
· Permeability of the site for people walking and on bikes
· Connections for active and sustainable travel across the development boundary

14.6 For cycling the study impacts (paragraph 14.3.4) are suggested to include:
· Route diversion and severance for all modes (walking, by bike, public transport) to all
required services (including those outside the development)
· Cycle amenity
· Directness and coherence of pedestrian routes
· Directness and coherence of cycle routes
· Parking policy (for bikes and cars)

14.7 It is noted that paragraph 14.3.5 states that the assessment of the pedestrian, cycle and public
transport network effects will be based on the fully completed development. CBC consider that
this should be changed to and assessed from the first phase occupied, as transport
behaviour is embedded from first occupation. Pedestrian, cycle and public transport facilities
need to be in place on first occupation, otherwise car use becomes embedded.

14.8 It is noted in paragraph 14.4.3 that baseline data includes pedestrian and cycle routes. To fully
assess this data, the quality, coherence, directness and safety of any existing/connecting
pedestrian and cycle facilities needs to be taken into account to fully understand linkages and
movement patterns.

14.9 Under paragraph 14.5.3 potential permanent traffic and transport effects during operation should
include both the changes in journey times for walking and cycling and the potential severance of
established routes for those walking and cycling.

14.10 In relation to potential mitigation measures (paragraph 14.6.) during construction, the following
measures should be included:
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· to minimise changes to pedestrian and cycle routes, please consult traffic management
guidance for walking & cycling here https://tfl.gov.uk/info-for/suppliers-and-contractors/trafficmanagement
· Ensure that any temporary cyclepaths or footways have all weather surfaces.
· The construction worker travel plan should enable and not just encourage the use of other
transport modes.

14.9 In respect of mitigation measures during operation set out in paragraph 14.6.2 the following
measures should be included:
· Sustainable travel needs to be enabled not just promoted.
· Reducing delays and journey times for pedestrians, people on bikes and public transport
should be prioritised over delays to drivers.
· Reference is made to provision for pedestrian and cyclist movements at junctions and links
to reduce severance. This needs to be separate provision for pedestrians and cyclists (see
Gear Change and LTN1/20), cyclists must be separated from volume traffic, both at
junctions and stretches of road in between, cyclists should be treated as vehicles, and
cyclists must be separated from pedestrians.

Part 15 – Waste and Resource Management

15.1 CBC consider that the detailed advice from West Sussex County Council as the Waste Planning
Authority should be relied upon in respect of waste resource management impacts. However,
there are a couple of detailed points in respect of energy and sustainability which are
considered of relevance within this section and should be considered within the ES.

15.2 This section includes resource management in its title but does not address energy or ‘energy in
use’ as a resource issue. An Energy Strategy both for the development in construction and
operationally clearly needs to be defined and assessed.

15.3 In paragraph 15.3.6 ‘Operation materials’ it must be acknowledged that the material choices
made at the design stage will influence the longevity of the material such as the need to repair
or replace during the lifetime of the building/development. As the material resources required
for maintenance are clearly within the control of the proposed development, this should be
assessed.

 

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