CORRECTION MADE MARCH 18 2021 – Please see email below

Dear #####

Just to confirm that we stepped down from the West of Ifield project in mid-late 2019 and no longer have any involvement with the project which is led by Homes England.

From my knowledge, this is the main publicly accessible source of information about the project from the government website: –

The proposals are now for 10,000 homes with associated public facilities and all of the land is indeed in Horsham District to the west of Crawley: –

I’m not sure I can be over any more help, but I wish you all the best with your ongoing consultation.

Johnny​ Clayton
Head of Masterplanning
Carter Jonas


“Developers want to build 10,000 houses West of Ifield. CRAWLEY DEMANDS A SAY!”


Homes England first proposal

10000+ Homes 35% affordable

10000 New jobs

50% Green Space

10% Biodiversity gain

5 x2FE Primary Schools

2x6FE Secondary Schools

supporting the delivery of Crawley Western Relief Road

Maintains long term defensible boundary between Crawley and Horsham.

Homes England new proposal

The proposals are for: over 3,000 homes (of which 40% will be affordable); 1,000 jobs; three schools and a local centre; set in over 50% open space.

190 ha. site as a comprehensive urban extension of the town (Crawley)

If we break their new proposal down, we can say.

40% affordable . That will keep Crawley councillors off our backs.

So, we are going to have 2000 people unemployed living there.

Houses are being built on Horsham’s land, where is the long-term defensible boundary between Crawley and Horsham.

They are not building on the flood plain, so is this a major part of 50% open space.

No mention of supporting a Western Relief Road

It looks like they are making it up as they go along.

Next things that could happen

We do not need to build the schools in the first phase.

We have discussed with West Sussex and as we are only building 3000 houses Rusper Road could take this increased traffic.

I would go on, but I think you get my drift.

~ ‘P’ – 14/03/2021


What we need to watch for is the phasing. What is now and what will creep in later. Each phase is easier to get permission on the back of what has been done before.

50% open space. What does this mean?

If you add up the area on the latest golf course map it must include the playing fields which have no natural wildlife habitats. If it includes the area not on the map but within the relief road it only applies until that is built on later.

The golf course site, even with the relief road, still puts traffic through Ifield, it is human nature to use the most direct route.

We all know “affordable housing” is still out of reach for most local people’s pockets who might want one. You have to have a job and preferably two in the family to afford even the lowest prices.

Horsham Council or Homes England cannot say it is for Crawley’s benefit if Crawley Council and people say it isn’t.

I see on the news today that construction work is the only industry category to have increased in these Covid times.

It’s going to be a busy summer.
~ ‘R’ – 14/03/2021



Horsham Local Plan – Regulation 18 Consultation
Planning Policy
Horsham District Council
Chart Way
RH13 5AA

By email

23 March 2020

Dear Sir/Madam,

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
paragraph 96,
“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
to accommodate.”

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
and beyond.

2. Biodiversity

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.

Yours sincerely,

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