Homes England have submitted an Environmental Impact Assessment (EIA) scoping opinion request together with associated documentation to Horsham District Council. Here is a link to the documentation: HE EIA
There is a lot of documentation available – some items are more detailed than others, but more specific information related to the Homes England proposals are starting to emerge.
This is the formal CBC response – CBC response
Key items that I have noted include:
- There is an alignment shown for the northern part of the Western link road
- There is a potential connection to Rusper Road that would cross Ifield Meadows and Ifield Brook and would be for foot / cycle and pedestrian use only
- 12% / 25 hectares of the proposed site area is within Crawley Borough
- Proposals do not include consultation with Crawley councillors or residents groups
And I didn’t notice a lot of publicity along with this submission?! Many thanks to certain Ifield residents who drew our attention to these materials.
Cllr Peter Smith
Ifield and Ifield West
We have just sat through Homes England’s YouTube propaganda attempting to justify their intentions for the above site.Looking at the aerial view of their “West of Ifield” proposals it would seem that they would be equally appropriately titled “West of Crawley”!!HE refer to a requirement for 19,000 additional houses in the Horsham area but, if Horsham actually has need for these houses, why are they to be built on the edge of Crawley and not on the edge of Horsham town?
The presentation of the HE video is desperately poor, an extremely amateur effort! If this is an indicator of Homes England’s development “quality” it is not reassuring.The location of the film seeks to suggest that the site is a wasteland, with no visual or environmental value. A propagandist’s “illusory truth effect.” – ie. the greater the illusion the more people may believe it.This site is certainly not scrub wasteland!!It is in part active, working, arable land. It is home for wildlife, such as deer, foxes, moles, water birds, including 10 Egrets settled in the middle of the “quarter” mile field last year!!, Red Kites, Buzzards, Kestrels, owls etc. There is no mention of where these are all to be “relocated”.The fields are crossed with public footpaths widely used by walkers from all over Crawley and further afield. Are people instead expected to walk through a widespread housing development?The presentation avoids reference to about one third of the “site” which is Ifield Golf Club.Homes England unsurprisingly make no reference to this important facility in their presentation. Not surprising because it would be difficult to justify the obliteration of such a valuable feature.Homes England claim that they propose to dramatically increase the green space!!How can they realistically claim to increase the green space when they propose to build over about 160 acres of open country on the golf course.15 years ago, the Forestry Commission planted 8,500 trees on Ifield Golf course. Many of these would need to be chopped down to accommodate housing of current density. Similarly, there would be a loss of established oak trees on Ifield Golf course, many of which are over 100 years old. The world’s big, old trees store an enormous amount of carbon, keeping it out of the atmosphere, and will continue to do so, even if their net CO uptake decreases. So long as they are not cut down and burned that is.This when Boris Johnson wants to plant millions of trees to help combat climate change.
National Planning Policy Framework, Paragraph 97 requires: –
Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:
a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or
b) the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location;
We have seen no evidence that HE have undertaken a valid assessment of IGC’s viability or offered proposals for a suitable replacement facility.
In spite of the Covid restrictions Ifield Golf Club is going from strength to strength unlike so many other clubs which are closing.
Clearly, the need for Ifield Golf Club as a community sporting facility is more pressing than ever.
Ifield Golf Club is a mature, parkland course, created in 1927 by Royal Birkdale designers Taylor and Hawktree and was a significant feature in the development of Ifield and Crawley.
This is a piece of local history. Not a golf course to be lightly bulldozered.
Ifield Golf Club attracts over 5,000 visitors per year!
It is also attracting applications for new memberships which are available at low cost, so it is clearly not surplus to requirements.
Ifield Golf Club makes a serious contribution to local recreation and, out of its 550+ members, it can claim nearly 100 golfers under 35 years of age, 26 of which are juniors.
Ifield Golf Club’s 2018 PGA award winning professional has devoted time to nurturing Juniors, including an England under 16 champion.
Many of the club juniors walk to the course with their clubs. They won’t be able to walk to another club!
In spite of the current COVID restrictions the golfing membership of Ifield Golf Club is constantly rising, in additional to which, there is a strong social membership, which involves non-golfing members of the community.
Ifield Golf Club has demonstrated that it provides an open space of public value; including sports facilities for local young people, some of whom have gone on to County Championship standard.
We would ask the Local Planning Authority to insist that Homes England carries out a valid assessment now which would demonstrate that any planned removal of Ifield golf course is counter to their requirement to retain sports opportunities for the population.
HE make a generalized reference to a new link road but with no detail. By reference to their earlier proposals this road is to discharge onto the Charlwood Road at the end of Ifield Green. The implications on the rush hour impact on this approach into Crawley are obvious.
HE claim that the proposals will be all within a 15 minute reach of Ifield Station on foot. By reference to the OS map the west side of the golf club would be a 25 minute walk. the north end of the proposed site would be further.
All in all, Homes England seem to be trying to bluster ahead with a flawed proposal ignoring it’s obvious faults and we hope that the local authority will not support them in this.Yours faithfully,
Malcolm and Valerie Bender
Pinewood, Rusper Road,
West Sussex, RH11 0LR
tel – 01293 516189
Two Cornwall Street
Our ref: EIA/19/0004
ref: R-1620007949_3-WOI Scoping
Line: 01403 215162
Date: 30th November 2020
Dear Mr Royal
Request for a formal Scoping Opinion for the proposed development at Land West of Ifield, Horsham
Following your email requesting a formal Scoping Opinion for the proposed development at Land West of Ifield,
Horsham, please find attached a copy of the Scoping Opinion issued on behalf of Horsham District Council. The
opinion incorporates the views of the statutory consultees and other departments within the Council. The
comments of Crawley Borough Council, Natural England, the Environment Agency, HDC Ecologist are attached.
In addition to consultation responses, we have also received 29 emails from residents. The full comments can
be viewed via our website (https://www.horsham.gov.uk/planning) using the ref: EIA/20/0004. Their comments
are summarised as follows:
Proposed road stops are Ifield are unacceptable.
The environmental impacts are unacceptable.
Base line surveys will need to redone as the development progresses.
The consultation so far from Homes England has been inadequate.
Questions are raised regarding the ‘Country Park’ and what it will entail.
Concern is raised over Homes England’s commitment to delivering the whole of the link road.
Impact on adjacent farmland and agricultural uses needs to be considered.
The scheme will have a detrimental impact on traffic.
Concern is raised regarding the loss of the golf course.
The development is too close to the airport and results in loss of greenspace.
I confirm that this letter forms Horsham District Council’s formal Scoping Opinion based on the information
submitted to date and will be placed on the public register.
Principal Planning Officer
Chapter 1: Introduction
Paragraph 1.1.1 states that ‘the planning application for the proposed Development will be in outline
with all matters reserved’. Horsham District Council (HDC) agrees with Crawley Borough Council
(CBC) that there is concern that an outline application with all matters reserved would not include
sufficient information and detail to be assessed. As we now understand any application would include
the accesses from Charlwood Road and Rusper Road in detail, with the remaining link road in outline.
This would be the absolute minimum we would likely support, noting that the overall scope of the
application has not yet been agreed.
Chapter 2: Site Context
Paragraph 2.1.3 refers Ifield Park but its location is vague stating it is the east. HDC agree with CBC in
that this section should include more detail on the site context. The importance of the relationship with
Crawley and the amenity use of this existing countryside for Crawley Town residents needs to stressed.
The potential impact on the setting of Ifield Conservation Area also needs to be emphasised in this
Reference needs to be made to the development of 95 dwellings to the north side of Rusper Road,
approved under outline permission DC/14/2132, which abuts the site. This development is near
Chapter 3: Description of Development
Paragraph 3.2.2 states that the development proposal is still evolving and that full details of what the
proposal will include has not been stated at this point. It is appreciated that the Homes England are
looking to submit an application in 2021 and that a masterplan has not been finalised. An EIA will need
to accurately state what the proposal will comprise so that its environmental impacts can be thoroughly
Reference should also be made here to the aspirations of the site to be part of a wider scheme for up to
10,000 dwellings for the land to the west of Crawley. The land west of Ifield is the first phase of this
wider development which is intended to deliver a link road joining the A264 to the south to the A23. It is
important that this narrative is outlined in the EIA so that cumulative impacts can be considered where
You should note that the land use, building height and density parameters for the development have not
yet been finalised.
Chapter 4: EIA Methodology
Paragraph 4.4.5 refers to 2020 as a ‘Current baseline’. HDC agrees with CBC that 2020 has not been a
typical year due to the pandemic and would not be an appropriate baseline.
Paragraph 4.8.3: HDC agrees with CBC that the cumulative impact for developments in the surrounding
area should be clearer and include smaller scale schemes approved nearby at HDC and CBC. It is
noted that the development at Kilnwood Vale for up to 2500 units (plus an additional 250 on its reserved
land to the west), including a neighbourhood centre and employment uses (ref: DC/10/1612) has not
been included in the list of developments. This strategic site is well advanced and nearing 1,000
occupations. Reference should also be made to the approved scheme for 95 units immediately
adjacent the site (ref: DC/14/2132) and the Novartis site (ref: DC/18/2687) for up to 300 units and
employment uses in Horsham town. It would also be important to note the potential impact of any
relevant housing allocations in the area that come forward in the Regulation 19 Horsham District Local
Plan Review due to be published and consulted on in early 2021.
Table 4.2: It is incorrect to state that ‘there are no mineral resources’ present on this site. The site is
within the brick clay consultation zone under the West Sussex Mineral Local Plan. Therefore Policy 10
of the Minerals Local Plan would be applicable.
HDC Environmental Officer has noted the proposal to scope out the land contamination as the site
comprises primarily previously undeveloped land. While it is accepted the majority of the site is likely to
be free from contamination, there will be isolated areas such as access tracks, hard standings and field
gates where imported contaminative material may be present. This issue will need to be addressed
either as part of the outline planning proposal or through a discovery strategy for each phase.
Paragraph 4.14: The full scope of the planning application and documents to be submitted as not yet
been agreed. As stated, it is important that the matters submitted with the outline are agreed and that
leaving all matters reserved would not be an appropriate approach.
Chapter 5: Agriculture and Soils
Chapter 6: Air Quality
HDC’s Air Quality Monitoring Officer has made the following comments:
– HDC has adopted the Air Quality and Emissions Mitigation Guidance for Sussex (2020). The
guidance takes a low-emission strategies’ approach to avoiding cumulative impacts of new
development, by seeking to mitigate or offset emissions from the additional traffic and buildings. In
accordance with the guidance, a damage cost calculation is required from all developments
classified as ‘Major’. Applicants are required to submit a mitigation plan detailing proposed
measures to mitigate and/or offset the impacts and providing itemised costing for each proposed
measure, with the total estimated value of all the measures being equal to the total damage costs.
– The Sussex Guidance seeks to avoid duplicating mitigation normally secured through other
regimes, e.g. Travel Plans.
– The impact assessment must include relevant receptors on major routes into Horsham town.
– The impact and exposure assessments must take account of cumulative impacts on air quality – all
committed residential development including the North of Horsham development, as well as all
committed industrial development in the north of Horsham, including Horsham’s incinerator.
– It is recommended that air quality mitigation includes measures to reduce emissions from domestic
heating as this will help the district reduce both air pollution and carbon footprint.
Chapter 7: Biodiversity
The comments of the HDC Ecologist and Natural England are attached.
It is noted that further consultation is proposed to be undertaken with the WSCC tree Officer to request
information on TPO’s and approach to tree survey and mitigation. In addition to this and the other
consultees, the HDC tree officer must also be consulted. This would include an assessment of the site
for potential Ancient Woodland.
Chapter 8: Climate Change
Reference should be made here for the requirement of this potential strategic site to be carbon neutral.
Draft policies on climate change policy under the Local Plan Review outline HDC’s approach. In the
event this site is allocated for development in the Local Plan Review the site will be required to
demonstrate the delivery of carbon neutrality or negativity within the development, including
demonstrating a fabric first approach to the construction of built development, and maximum use of
onsite renewable energy technologies.
Chapter 9: Cultural Heritage
HDC’s Archaeological Consultant has commented that the West of Ifield site has considerable potential
for archaeological remains to the present. The geophysical survey and previous fieldwork both in and
adjacent to the site has established the presence of archaeological remains including a probable large
settlement spanning the site the period between the Late Bronze Age and the later Roman period, as
well as number of other possible prehistoric / Roman enclosures.
It is therefore recommended that the proposed Cultural Heritage Chapter in the EIA should comprise: –
– A desk-based assessment of the proposed development area – this should utilise the information
available in the West Sussex Historic Environment Record and historic cartographic and
documentary sources. This should include an assessment of both the historic environment sites and
the historic landscape setting.
– A re-assessment should be made of the aerial photographic evidence for the area, including the online digital data available on GoogleEarth. This should include rectification of both archaeological
features and palaeochannels.
– An assessment should be made of the available LiDAR data for the application site and rectified
plots produced of both archaeological and historic landscape features identified.
– If a geophysical survey is being undertaken it is recommended that a trial area is undertaken on an
area of known archaeological deposits to assess its effectiveness prior to the remainder being
– An assessment should be made of the available borehole and BGS data for the site in order to
establish the potential for palaeoenvironmental deposits within the valleys of the Mole River and the
– An element of ground-truthing, in the form of trial-trenching, will be required to clarify the results of
all of the surveys.
– The results of the above will inform the development of a mitigation strategy for both preservation in
situ and/or preservation by record where this is not possible.
If planning permission is granted initially all those areas not previously trenched will require a
programme of archaeological trial-trenching at a density of 5% (4% with a further 1% available for
refining the results). This will inform the further development of the mitigation strategy.
The HDC Conservation Officer has also commented that, from his assessment it is considered that
Pockneys Farm (NHLE: 1026984) and Oak Lodge (NHLE 1180389) may be subject to potential
significant change, and should also be considered.
Chapter 10: Landscape and Visual Impact
HDC’s Landscape Officer has made the following comments:
– Ifield Conservation Area has been scoped out, however it is considered that the setting of the
conservation should also be included within the landscape assessment;
– The West Sussex Land Management Guidance and West Sussex Historic Landscape
Characterisation studies should be included to the list of existing character assessments and
– As part of the Landscape Character Assessment work, the following should be taken into
Identify any change to the Horsham District Landscape Character Areas (in the HDC landscape
character assessment) and also examine the impact of development on distinctive local
character areas within and immediately surrounding the development site.
The impact on specific landscape features should also be assessed e.g. field and boundary
trees, hedges, woodlands and other historic landscape features which contribute to the
landscape e.g. hedgerow/woodland banks, old country lanes, drove routes, old railway lines,
The EIA should include assessments of visual effects on the surrounding area and landscape
together with any physical effects on the development, such as changes in topography.
Changes in characteristic views e.g. to the High Weald AONB, to local landmarks may need to
be considered, etc
Photomontages should be prepared for key viewpoints of the development – locations to be
agreed with HDC. Any particularly tall elements of the development are likely to need to be
shown on cross sections to understand their impact.
The landscape and visual assessment should take account of the ‘worst case scenario’ in terms
of winter views and also the effects of mitigation planting in year 1 of the development and after
15 years of establishment.
The detailed design of the proposed improvements should seek to respect and enhance local
character and distinctiveness, and use appropriate materials and designs in all new built
features. This should reflect local design characteristics and wherever possible local materials.
Advance planting of perimeter buffers should be considered where possible as part of the
mitigation measures also during the construction stage
Paragraph 10.3.23: Reference should be made here to the Kilnwood Vale development for up to 2,750
dwellings just south of the site (ref: DC/10/1612). It should be noted that DC/20/0470 has been refused.
Reference should also be made here to the development of 95 dwellings to the north side of Rusper
Road, approved under outline permission DC/14/2132, which would abut the site.
Chapter 11: Noise and Vibration:
HDC Environmental Officer has made the following comments:
– 11.3.13 Construction noise: Experience of the Kilnwood Vale development showed that piling works
generated severe off site impacts. At one point this resulted in enforcement action by Crawley
Borough Council against the developer. This emphasises that the design of the development
should minimise the need for piling works where sensitive receptors are close by, either off site or
within the proposed Development boundary due to phased occupation of the proposed
development. It should be noted that the ongoing COVID situation with residents working from
home etc has challenged that the normal model of acceptability of construction noise levels during
– Table 11.2 details construction noise limit values for night time. It should be noted that HDC does
not routinely permit night time construction working and it should not be assumed that these noise
limits are accepted.
– Table 11.3 gives values for construction vibration significance thresholds. It is considered the
banding for Moderate adverse impacts is too wide. As noted above, experience of the Kilnwood
Vale construction phases showed significant level of complaints were received a much lower level
than 10mms. The significance criteria should be revised where sensitive receptors are likely to be
affected, either off site or within the proposed Development boundary due to phased occupation of
the proposed development.
– 11.3.24 Operational Plant and Commercial Development: The proposed BS4142 noise target does
not consider issue of cumulative impacts of multiple new noise sources. The target should be set
5dB below background to avoid incremental increases in background noise levels.
Chapter 12: Socioeconomic Effects and Health
HDC agrees with CBC that the one of the most significant Socio-Economic effects of this proposal will
be to the residents of Crawley, especially those residents who live to the west of Crawley and currently
enjoy the use of this countryside site. It will therefore be necessary to consider the impact of the
development on the health and well-being of the neighbouring district of Crawley in detail.
It is recommended that in assessing socio-economic impacts it would be beneficial to refer to the
analysis of any representations as part of the Local Plan Review currently been undertaken. This is in
the event that the scheme is taken forward as part of the review as a preferred site. Analysing the
representations will provide an indication of the concerns of the existing communities.
Paragraph 12.4.13: Representations received state that Rusper Golf Club is now closed.
Table 12.2: Again, reference should be made here to the Kilnwood Vale development for up to 2,750
dwellings just south of the site (ref: DC/10/1612). It should be noted that DC/20/0470 has been refused.
Reference should also be made here to the development of 95 dwellings to the north side of Rusper
Road, approved under outline permission DC/14/2132, which abuts the site.
Chapter 13: Surface Water Resources and Flood Risk
HDC Drainage Officer has commented that he is satisfied with the scope and issues raised with respect
to Flood Risk and their possible effects on the project.
The comments of the Environment Agency are attached for your information.
Further comments have been sought from West Sussex County Council as the Flood Authority. These
will be forwarded on once received.
Chapter 14: Transport:
West Sussex County Council Highways have stated that they have no comments to make on the
methodology within the EIA Scoping. As set out in the Scoping, separate discussions are progressing
with WSCC regarding the assessment of transport related matters with these to be presented as part of
a Transport Assessment. It’s understood that the TA will then feed into the EIA. Various transport
guidance documents are listed on page 144. LTN 1/20 should be added to these.
The only other comment at this stage would be in respects of the committed developments. Both
Kilnwood Vale (DC/10/1612) and the redevelopment of the former Novartis site (DC/18/2687) are
missing from the list within Appendix B.
Chapter 15: Waste and Resource Management
For the attention of Crawley Borough Council,
December 30 2020
West of Ifield – Public Engagement
Horsham District Council planning ref (EIA) /20/0
We would be obliged if you could confirm if it is still Crawley Borough Council policy that it is not in support of the Homes England’s development proposals for the land “West of Ifield”, (reference Crawley and Horsham Observer).
Is it still a requirement of the revised National Planning Policy Framework (2018) that Horsham District Council is bound by a statutory duty to cooperate and “properly” engage with Crawley Borough Council in the development of their Local Plan?
We would also be obliged if you could advise if the recently amended housing distribution proposals would require fewer houses to be built in the “West of Ifield” area.
We would appreciate your assistance.
Malcolm and Valerie Bender
The council’s position on West of Ifield has not changed and has been reconfirmed to the developer at subsequent meetings.
A statutory duty to co-operate does exist in relation to HDC helping to meet CBC’s locally assessed housing need, although this remains a very weak mechanism and essentially amounts to a numbers game.
The national debate around housing numbers doesn’t really apply here, as CBC and HDC are far enough into their Local Plan processes that we are able to use locally assessed figures rather than the national ones (which would be higher regardless of the recent changes), so long as there aren’t any major delays. There are sufficient other sites currently put forward for development to meet that demand (including the duty to cooperate) without needing to bring forward West of Ifield.
However, it is worth noting that Homes England retain the planning powers of the original development corporations, meaning they could within current law award themselves planning permission regardless of the Local Plan or the views of local authorities. Under such circumstances judicial review might provide a high cost delaying tactic, but not more than that.
Ordinarily, this wouldn’t even be a consideration, but in the last few year’s their chief executive has threatened to use these powers, including in relation to this site and they already have the site included within their housing targets. I mention this because I note you have two MPs cc’d into this email and it would be great if they could take this up with MHCLG to provide assurances that action will be taken to ensure that a government QUANGO isn’t allowed to ride roughshod over local decision-making in this way.
Happy New Year,
Cllr Peter Lamb
Leader, Crawley Borough Council
Dear Peter Lamb
Many thanks for your reply – and a happy new year to you.
You say: “Homes England retain the planning powers of the original development corporations, meaning they could within current law award themselves planning permission regardless of the Local Plan or the views of local authorities”
If that statement is accurate, we are completely wasting our time fighting to save the ancient Parish of Ifield and its Golf Course [which makes up a substantial part of Homes England’s £3bn ‘West of Ifield/Crawley Garden Village’ monstrous masterplan of 10,000 houses].
But I would question the accuracy of your statement.
If I am reading this Daily Telegraph article correctly, Homes England do not yet have the undemocratic, totalitarian powers you mention.
We fight on – legally and ferociously.
It’s two different things. The article is about the potential of setting up new development corporations, whereas Homes England already have these powers under the initial 1940s legislation. They haven’t been used in decades, so for now it’s just a threat to tell councils to let them get their schemes through (the vast majority of applications are in fact approved and where they aren’t it’s for a good reason), but in principle there’s nothing to stop them from dusting them off. As all planning powers ultimately rest with the Secretary of State for Housing, Communities and Local Government, some certainty that he would intervene in the event Homes England to act in this way would be useful.
Cllr Peter Lamb
Leader, Crawley Borough Council
ALMOST £2 million will be invested in a beauty spot to improve wildlife habitats after a transfer of ownership.
HOMES ENGLAND UPDATES – JANUARY 2021
HOMES ENGLAND UPDATES – FEBRUARY 2021
“I’m sure you’ve seen this already, clearly the questions are regarding the natural beauty as it is within this area. Homes England are totally arrogant in their answers, they also mention that farm land offers low biodiversity so this would be the preferred choice to build on. Theres a massive problem with this, that would be apart from the woodlands and ifield golf course, the remaining land is farm land so it would turn into a concrete urban area. This madness has to stop its not considering local residents wishes”
Steve Sellers to RWS February 22 2021
“A document named “SCOPING REPORT-APPENDIX A 9-1 to 9-2” (http://snafpacc.horsham.gov.uk/AnitePublicDocs/01648013.pdf); a heritage assets report by Arcadis commissioned by Homes England, is of particular interest to me. The document has multiple numbered locations and areas, but is missing a key with which to identify the assets highlighte” [‘IM’]
Horsham Local Plan – Regulation 18 Consultation
Horsham District Council
23 March 2020
Response to Horsham District Local Plan Regulation 18 Consultation
On Behalf of Ifield Golf Club, Rusper Road, Ifield, Crawley, Sussex, RH11 0LN
I am the retained Planning Consultant for Ifield Golf Club. This letter contains my client’s submission in
respect of the Regulation 18 Consultation into the new Horsham Local Plan.
Strategic Policy 14 – Options for Housing Growth
Ifield Golf Club forms part of ‘Land West of Crawley, Rusper’, listed under Strategic Policy 14 for the
development of up to 10,000 homes, employment, schools and other community facilities. The site
comprises ‘legacy land’ inherited by Homes England from the now defunct Crawley New Town
Corporation, along with Ifield Golf Club and grounds. Although it has long been common knowledge that
Homes England may seek to develop its land as an urban extension to Crawley, the inclusion of the golf
club within its proposals is neither justified nor necessary.
This letter sets out the planning reasons why Ifield Golf Club and grounds should be removed from the
1. Loss of the Golf Club Facilities
The primary objection to the inclusion of Ifield Golf Club within the strategic site is the absence of an
evidence base demonstrating that the club is surplus to requirements. Such an assessment is required to
justify the loss of the golf club land and buildings. Homes England has not offered the club alternative,
equivalent or better provision in terms of quantity and quality in a suitable location, as is required by
national planning policy.
National Planning Policy Framework (NPPF) Paragraph 97 requires that existing open space, sports and
recreational buildings and land, including playing fields, should not be built on unless:
a) an assessment has been undertaken which has clearly shown the open space, buildings or land to
be surplus to requirements; or
b) the loss resulting from the proposed development would be replaced by equivalent or better
provision in terms of quantity and quality in a suitable location; or
c) the development is for alternative sports and recreational provision, the benefits of which clearly
outweigh the loss of the current or former use.
Neither in its recent round of public consultation events nor in private communications with my client
has Homes England produced any evidence to demonstrate that it can comply with paragraph 97. The
absence of any discussion on this matter implies that Homes England has simply assumed that the golf
club is surplus to requirements, that this is a fait accompli and that the demonstration of this is nothing
more than a paper exercise.
This is far from being the case.
The last time Horsham District Council commissioned an assessment of existing sports, open space and
recreation provision was in 2012.i
This report concluded that there was ample provision for golf in the
District to meet demand. In the intervening eight years there have been significant changes in the
number and size of golf facilities in Horsham and surrounding districts. The 2012 study is now out of
date so cannot be relied upon when assessing whether the loss of Ifield Golf Club can be justified in the
light of the Framework.
Without the production of a robust study of golf provision based on accepted methodology we do not
see how the inclusion of the golf club within this strategic site could be found to be sound by an
Inspector. To wait until the planning application stage to provide the local planning authority with the
necessary evidence is clearly too late in the process.
For were an assessment to be undertaken by Homes England at the planning application stage, and it
was found that Ifield Golf Club land and buildings were not surplus to requirements, then alternative,
equivalent or better golf course in a suitable location would need to be provided by Homes England and
offered to the golf club at the time. Golf courses take years, if not decades, to establish. The developer
would quickly find that replacing the golf club in accordance with paragraph 97(b), in the timeframe
required to ensure delivery of this strategic site, would be an impossible task.
The 2012 Update report lists nine golf courses in the district. It did not assess golfing facilities in
adjoining districts. In the past eight years there have been significant changes in the provision of golf
clubs in Horsham and the surrounding area. Below is a summary of known changes in golfing facilities in
Horsham and surrounding districts since the last sports and recreation assessment:
Rusper Golf Club: purchased by speculative developer and due to close September 2020
Horsham Golf & Fitness: plans to reduce from 18 holes to 9
West Chiltington: closed and the land sold to a local vineyard
Wildwood Golf and Country Club, Cranleigh: permanently closed
Redhill & Reigate Golf Club: closed 2019
Cottesmore Golf Club: reduced from 36 to 27 holes two years ago
Mannings Heath Golf Club: reduced from 36 to 27 holes
Waterhall, Brighton: closing March 2020
In addition, two clubs in are now identified as redevelopment sites in the emerging Horsham Local Plan
(Ifield and Rookwood), and slightly further afield, Haywards Heath Golf Club was the subject of a
Scoping Opinion submitted to the Council by developers Fairfax in April 2018 (DM/18/0992) so is clearly
at risk of being lost to redevelopment. It is understood that Fairfax have been in discussions with the
club to secure alternative provision under the terms of the NPPF, including pre-contract agreements to
purchase Lindfield Golf Club or build an entirely new course for the club. This is in stark contrast to the
situation at Ifield, where Homes England has made no approaches to the club regarding alternative
Golf is the sixth most popular sport, by participation, in the UK. To allow the continued demise of golf
courses, a process that is exacerbated by including them as redevelopment sites in Local Plans without
robust assessment of need, is short-sighted. It fails to account for the fluid nature of demand for
different leisure activities. Demographic change, including a projected increase of 8.6 million people in
those aged 65 years and over by 2041, will have a direct effect on the demand for different leisure
The Draft Horsham District Local Plan confirms that the highest growth in population in the district over
the Plan period will be in those over 65, and especially the over 75s (para. 6.1). Golf is one of the few
leisure activities in which the over 65s can participate. It is not only suitable housing that the elderly
need; their health and well-being depend on opportunities for recreation and socialising. Golf is popular
with those of retirement age because it is one of the few activities available to them that provides both
social and physical benefits. Faced with a steep increase in the elderly population, it is ill-considered for
the Local Plan to propose redeveloping two of the eight remaining golf clubs in the district.
Furthermore, any study that assesses need solely, or even partly, on club membership levels, will not
provide an accurate measure of participation in golf. The Horsham District Assessment 2012 Update
study states that because only one of the clubs in the district had a waiting list for membership, this was
a signifier of “ample provision”. ii A reliance on membership figures as a metric for the demand for golf
facilities fails to consider that many recreational golfers are not members of a particular club, but play a
variety of different courses as non-members. This trend away from club memberships to a more flexible
type of play is revealed by the fact that most golf clubs now offer day and half day tickets to nonmembers. In addition, non-members are more likely to travel further to play a round of golf on a course
they have not played before.
It is not clear that the 2012 Update Assessment took account of the total amount of golf played at each
club, or focused solely on membership figures when assessing participation rates and spare capacity.
This is important because an assessment based on club membership will underestimate the demand for
golf, the number of people who regularly participate in the sport and the distance that people are willing
to travel to play a round.
As a reflection of this trend, Ifield Golf Club alone entertains over 5,000 visitors per annum, who play in
addition to its 509 members. In total, 30,000 rounds of golf are played at the club every year.
In sum, proposals in the Local Plan that result in the loss of golfing facilities must be informed by a
fresh, up-to-date, district level assessment of golf provision. The study of recreation provision
commissioned by Horsham District Council in 2012 is now out of date, particularly where it relates to
golf facilities. A new, up to date study should assess existing and future provision and how this would
meet projected demand for golf over the 15 year Plan period, taking into account demographic
projections and different participation rates based on age and income. This is a requirement of NPPF
“Planning policies should be based on robust and up-to-date assessments of the need for open
space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and
opportunities for new provision. Information gained from the assessments should be used to
determine what open space, sport and recreational provision is needed, which plans should then seek
In addition to the district wide study, Homes England should be required to carry out its own paragraph
97 assessment of golf provision specifically in relation to Ifield Golf Club. If this assessment is not carried
out as part of the Plan preparation process then it is not clear how the strategic allocation ‘land West of
Crawley, Rusper’ can be considered by an Inspector to be deliverable and in accordance with the
Framework. Further, the assessment needs to be based on an accurate measure of current and
projected future levels of participation in recreational golf and the quantum of golf courses in the district
Strategic Policy 15 requires all strategic site masterplans to demonstrate 10% biodiversity net gain can
be achieved and Homes England has committed to this target for its site Land West of Crawley.
Ifield Golf Club grounds are rich in wildlife and habitats, and far more biodiverse than surrounding
agricultural land. The club has planted thousands of deciduous trees on their land under the Forestry
Commission’s Woodland Grant Scheme, the vast majority of which would be felled were the site to be
developed as part of a new settlement. This says nothing of the wider strategic site containing Ifield
Brook Meadows, a Site of Nature Conservation Importance (SNCI) and a number of parcels of Ancient
An ecological appraisal of the golf course grounds has not been carried out in the past twelve months.
There exists no up-to-date evidence base of its ecological value, without which aspirations to provide a
10% biodiversity net gain are empty platitudes. Indeed it is difficult to see how the developer could
achieve a 10% biodiversity net gain when the strategic site as a whole clearly has significant ecological
value. The Council makes very point when it states in its ‘Site Suitability Summary’,
“further information is required to understand how (biodiversity net gain) will be achieved particularly
as there are a number of parcels of land in this area that are already designated for their wildlife
importance.” (p. 75)
With the introduction of a new metric from Defra for calculating the quantum of biodiversity, and the net
loss/gain resulting from a development project, it is all the more important for the Council to insist on
robust and accurate data on current biodiversity value of all strategic sites before they are included in
the Local Plan.
It is considered that the development of ‘Land West of Crawley, Rusper’ for a new settlement would lead
to the destruction of protected habitats and, – even with mitigation, – would result in a net loss of
biodiversity. It would therefore be contrary to draft Horsham Local Plan Strategic Policy 15, NPPF
paragraph 175 and emerging legislation in the Environment Act.
Strategic Policy 45 – Inclusive Communities, Health and Wellbeing
Draft Plan paragraph 10.29 advises,
“(d)evelopment proposals must take positive measures to create socially inclusive and adaptable
environments to meet the long term needs of a range of occupiers and users and to ensure they are
accessible to all members of the community. New development must be designed to achieve healthy,
inclusive and safe places, which enable and support healthy lifestyles and address health and
wellbeing needs. Development should address requirements stemming from … (t)he needs of an
ageing population, particularly in terms of housing and health”
The loss of Ifield Golf Club, set against a background of a growing elderly population, will undermine the
aims of Strategic Policy 45. Recreational facilities whose main target market are those over 65 need to
be retained, not lost to development. Policy 45 continues by stating that development needs to “protect
and enhance existing community facilities, services and open spaces”.
It is demonstrably clear that losing Ifield Golf Club to development would be in direct opposition to this
Strategic Policy 46 – Community Facilities and Uses
Mirroring NPPF paragraph 97, Strategic policy 46 resists the loss of outdoor sports facilities unless
appropriate replacement facilities are provided or there is sufficient evidence to demonstrate that the
facility is no longer feasible. The inclusion of Ifield Golf Club in the strategic site is not compatible with
Strategic Policy 46. Proper assessment cannot be left to the planning application stage, for the reasons
stated earlier this letter.
Golf course provision is not included in the table of local minimum standards of size for community
spaces. Golf has a higher participation rate than bowls and yet bowls is included in the table. A robust
metric for golf should be included in the table.
We consider that Potential Housing Allocation Options site ‘Land West of Crawley, Rusper’ does not
accord with wider sustainable development principles that balance the need for economic growth with
social and environmental requirements as identified in the NPPF.
The strategic site ‘Land West of Crawley, Rusper’, would lead to the permanent loss of an established
recreation and leisure facility, with a healthy membership and financial accounts. There has been no
analysis of golf provision, nor has the developer approached the club to offer equivalent or better
provision in a suitable location, as required by the NPPF.
Ifield Golf Club objects to this strategic site being included in the draft Local Plan. It should be removed
from the Local Plan as its development cannot meets social, environmental sustainability objectives, as
required by the NPPF.
Ms Debbie Marriage BSc MA MRTPI
On behalf of Ifield Golf Club
The Horsham District Sport, Open Space and Recreation Assessment, 2012 Update, Kit Campbell Associates (February 2014)
ii Ibid, para. 8.4