SA 101 – LAND WEST OF IFIELD: “WHICH PART OF ‘NOT CURRENTLY DEVELOPABLE’ DID HORSHAM DISTRICT COUNCIL CABINET FAIL TO UNDERSTAND TWO WEEKS AGO ON JULY 15TH ?”
SHLAA Reference: SA 101 Site Name: Land West of Ifield
Years 1-5 Deliverable [Box not ticked] Site Address: Ifield, Crawley – Strategic Site Option
Years 6-10 Developable [Box not ticked]
Years 11+ [Box not ticked] Site Area [ha]: 170.3 Suitable [Box not ticked]
Not Currently Developable [Box ticked] Greenfield/PDL: Greenfield Available [Box ticked]
Site Total: 0 Achievable [Box not ticked]
This is a strategic scale site located in Horsham District, but directly adjoining the settlement of Crawley. The land has been proposed by Homes England, and a consortium of other landowners, meaning the site is available for development. The site has been proposed for a development of around 3000 homes and associated infrastructure. A small proportion of this land falls within the administrative boundary of Crawley Borough Council, and there is the need for cross boundary working in the consideration of this site.
There are a number of constraints which impact the suitability and achievability of development on this site. This includes impact on flooding, and the setting of Ifield Conservation area. The northern part of the site is within the Gatwick Airport Safeguarding area and noise contours. There are also a number of infrastructure issues which would need to be addressed, including sewerage and impacts on the existing road infrastructure.
Unless allocated for development through the review of the Horsham District Planning Framework, this site would be contrary to policies 1, 4 and 26 of the HDPF in particular. The site is therefore assessed as ‘Not Currently Developable’.
Housing Report 2018
Horsham District Council
Published January 2019
JULY 20 2021 – ‘SAVE WEST OF IFIELD – TOGETHER’ – OVER 1000 MEMBERS ON FIRST WEEK OF LAUNCH – The Ifield Society
JULY 26 2021 – LETTERS TO/FROM THE DEPUTY LEADER OF HORSHAM DISTRICT COUNCIL
Dear Mr Hogben,
West of Ifield
Further to my email dated 19.07.21, I would be obliged if you could confirm if you were able to make your views known to the planning group in your absence on 15.07.21, in support of our reasoned objections.
Indeed, was there anyone at that meeting who advised the planning group of the objections that had been raised by the public to the West of Ifield proposals?
If no one presented opposing views, can It be argued that West of Ifield has been democratically presented for discussion at the committee meeting?
I think that the Council’s constituents are entitled to know that their views are being given consideration by their representatives.
We do appreciate that you have been fighting the battle to save Ifield for the past three to four years and hope that you will continue to do so.
That being said, we assume that the reason for the meeting on 28.07.21 is to consider, discuss and vote on the proposal for West of Ifield and not to simply rubber stamp it. I don’t, therefore, think it can yet be said to be a fait accompli. After all, it could still, presumably, be voted down by a majority of the Councillors. That would be in the nature of democracy.
In any case, I would be obliged if you could confirm that you and hopefully others, would raise the numerous fact-based arguments with which the Councillors have been bombarded and which, if West of Ifield were being given objective consideration, would have put this option straight out of court.
These arguments include:–
The Campaign to Protect Rural England response dated 30 Mar 2020 advised that the scheme is not sustainable and should be rejected.
The development is not contained within an existing defensible boundary and the landscape and townscape character features would not be maintained and enhanced, which is contrary to Policies 4 and 26 of the Horsham District Planning Framework.
Crawley Borough Council stress that it does not support additional development on its border that would unfavourably impact pressure on its roads, town centre and other facilities.
Loss of Greenfield in contravention of Ministry of Housing, Communities and Local Government report 03.06.21
Failure to protect sites of biodiversity in contravention of MHCLG report 03.06.21.
Failure to direct homes to where they are better served by infrastructure in contravention of MHCLG report 03.06.21.
Wildlife-rich habitat decimated by the relief road
Relief road surcharging unsuitable Crawley and Rusper minor roads.
Detrimental environmental effects on Ifield Brook Meadow/Conservation Area.
Unacceptable Airport noise and exhaust pollution.
Hospitals/doctors – inadequate infrastructure.
Loss of a 100 year old golf club, a thriving sporting facility and a piece of local history in defiance of NPPF Clause 97.
We are, belatedly, in receipt of the long-awaited Golf Supply and Demand Assessment document which reads like a work of fiction and which we will challenge in detail up to the Inspector’s review. This clearly does not obviate the need to satisfy NPPF 97
Ifield Golf Club is used by an average of more than 100 people per day of all ages, from the very young to the very old. The over 65 players would find it impossible to find a sporting facility of equivalent physical value. The two existing local sports pitches are used largely by younger people, at best 100 people per week. A similar facility West of Ifield could not come anywhere close to replacing the golf course!!
Since the National Planning Policy Framework must be taken into account in preparing the development plan, we do not believe that there can be any legal justification for Homes England’s failure to comply.
Availability for golf in West Sussex has already significantly diminished with recent course closures (up to about 130 holes of golf lost) so IGC is vitally needed.
There would be a loss of established oak trees on Ifield Golf course, many of which are over 100 years old. This when Boris Johnson and the Government want to plant millions of trees to help combat climate change.
How bizarre it is that in the year of The Queens Green Canopy, whilst we are encouraged to be planting saplings, we are proposing to fell almost 100 year old hardwood trees, releasing all of their captured carbon into the air. What hypocrisy
I trust that you will be able to ensure that your constituents’ concerns and objections are adequately considered by the Council.
Pinewood, Rusper Road,
The Cabinet meeting on the 15th July was called with three weeks’ notice and I have pre-arranged holiday. The council undertakes are regulation 18 consultation with all objections logged and noted, there is a formal legal process that is followed and every objection on planning grounds must be considered. I am afraid to say the outcome of this meeting is likely to have been the same if I had been in attendance or not.
The Council does not initiate where development takes place. Developers and promoters do that and then they come to Council with schemes and plans. We then analyse these and try to pick the best- or least bad of the bunch. However that selection is based on a raft of evidence collected and collated by officers and experts. In addition, we are constrained to meeting certain numeric targets imposed on us by Central Government.
In the case of Ifield the land promoter Homes England have put forwards a scheme. Homes England owns a lot of the land there and this ties in, in part, into the Crawley New Town days of the past. This is not our doing but that of a third party. We must assess this site like the others in the same way as the others.
I am aware that many(if not all) of the residents and golfing members of Ifield golf course are firmly against this scheme, however the Homes England has acquired the land I believe from Ifield golf course limited if I am correct. I do understand that with the land sold to the developer we now must legally consider the plan put before us.
In the case of Rookwood the promoter is HDC it is our land. Therefore we are free to put it forwards or not for development in this plan period. We decided to withdraw it as maybe we can do something else with it. That remains to be seen.
The parallels you draw to Rookwood I am afraid are not valid as the basis of discussion is very different in terms of land ownership. I would further add that the Housing minister comments notwithstanding as we have no brown field sites of note in the district we are forced to develop green field sites. It grieves me a lot that we have to do this, but we have no choice. We almost have a government quota to meet. I am sorry that this is not the answer you might want.
Cabinet member for Horsham Town, Parking and communications.
West of Ifield
Many thanks for your prompt reply.
You say that the Council does not initiate where development takes place but of course you do, once you have put it into your Local Plan!
Whilst I understand the constraints put upon you by the Conservative Central Government’s numeric targets, this does not justify electing to include in your Draft Local Plan a site which does not comply with Government Policy on environmental or infrastructural constraints, and which breaches the intent of the National Planning Policy Framework, as outlined in my email dated 26.07.21, copied below.
I can certainly understand that you can’t be expected to attend a suddenly called meeting when you are away. However, we might have hoped that there would have been some representatives of the constituents’ objections to the proposal, aired at the Cabinet Meeting.
I believe that there were 5 guest Councillors at the meeting who were from minority parties, however, it would appear that there was no invitation for any Officers to voice opposing views.
My apologies if there were minutes of the meeting which I have missed.
Were there opportunities for the Conservative members to jointly discuss the proposal prior to the meeting? If so, I would appreciate sight of any minutes of the discussions.
I attach what I believe is an excerpt from the Officers report for the Cabinet meeting where it refers to West of Ifield, which I understand to be public information.
By reference to this document, it confirms that Ifield Golf Club course makes up about one third of the site.
In fact this area would accommodate in excess of 50% of the proposed built area and yet it receives the rather paltry contribution of 2 lines out of a more than 2 page document!
Whilst you say that all objections are logged and noted and every objection on planning grounds must be considered, there is no indication in the Report that that is the case.
It would be useful to know if the Officers could confirm for us, for example, how many public objections were raised to the destruction of the golf course and on what grounds were they dismissed.
We consider that the briefing for the meeting was totally biased in favour of the developer, Homes England, whilst there was no reference to any opposing views.
This is supposed to be part of a democratic process but the Report was not in any way balanced, concentrating solely on the case of the developer and disregarding the views of the local constituents.
As the opposing case appears to have been excluded from the business of the meeting, I think this lack of balance could be said to be grounds for referral of the decision at the forthcoming Extraordinary Meeting until the next Council Meeting to allow for presentation of a properly balanced report.
Otherwise we feel that we will have good grounds for objecting at the forthcoming Inspector’s Review on the grounds of an unfair and biased presentation of the case and, thereafter, to legal action.
Pinewood, Rusper Road,
JULY 25 2021 – LETTER TO THE LEADER OF HORSHAM DISTRICT COUNCIL
FAO Councillor Clarke, Leader Horsham, District Council
Dear Councillor Clarke
I despair at ever getting a substantive response to the serious issues which I have raised several times in letters to you personally and to your fellow Councillors.
Your colleague, Councillor Donnelly – Chairman, Planning Committee South – has been most vocal in his condemnation of the Housing Minister, Robert Jenrick MP, claiming that the Council do not want to build thousands of houses in the area, but that they are being instructed to do so by the Housing Minister. Mr Donnelly continued that the Council was very aware of local concerns over this massive house building in our lovely area, and that under the Government’s Duty to Cooperate Protocol, houses had to be built also for neighbouring Crawley Borough Council. Therefore I should send my objections to the Housing Minister as only he could stop this onslaught on Horsham District.
Taking Councillor Donnelly’s advice I did write to the Rt Honourable Robert Jenrick MP, Minister for Housing, Communities and Local Government. While I did not receive a reply from the Housing Minister personally, his Senior Planning Officer, Jonathan Blathwayt wrote to me on 3rd June 2021 as follows:
- With regard to the proposed allocation at Ifield, I understand this was identified in the previous Horsham Local Plan consultation. I am also aware that further consultation of the Horsham Local Plan Review is scheduled for pre-submission (Reg 19) consultation later in 2021. At that time, you will be able to respond to the council directly and make your concerns known formally. A wide section of the community should be proactively engaged so that Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area. The Plan will later undergo an independent examination in public by the Planning Inspectorate. The Inspector will consider all the comments made on the plan during the public consultations and those who have made representations can apply to speak at the examination. Only if the Inspector is confident the Plan is legally compliant and meets the tests of soundness as set out in the National Planning Policy Framework (NPPF) can it be recommended for adoption. The Government does not approve plans. The decision of whether to adopt a plan is made by the local planning authority following the recommendation from an independent inspector. The Government is clear that councils and their communities are best placed to take decisions on local planning matters in their area without unnecessary interference from central government.
You will note his comments that a wide section of the community should be proactively engaged so that Plans, as far as possible reflect a collective vision and a set of agreed priorities for the sustainable development of the area. Also that only if the Inspector is confident the Plan is legally compliant and meets the tests of soundness as set out in the National Planning Policy Framework (NPPF) can it be recommended for adoption.
The actions to date by Horsham District Council, and more importantly by you as leader in particular, make a mockery of the information given out on behalf of the Government by Mr Blathwayt. Rather than engaging with the community, the concerns that my fellow Ifield residents and I have put in writing to Horsham District Council have been completely ignored, with both the Council and Homes England prepared to ride roughshod over any opposing views regarding this monstrous development. In spite of being elected members of Horsham District Council, those Councillors who are NOT Conservatives are excluded from details and discussions on the Local Plan. The shortlist of sites for the Local Plan has been chosen entirely between the Conservative group and Planning Officers. Opposition Councillors have no input in the matter. To borrow from Animal Farm ‘All Councillors are equal but some are more equal then others’. If that was not undemocratic enough we now learn that you have issued a diktat to Conservative Councillors that, that irrespective of their own views or concerns, or those of the people they purportedly represent, failure to vote for your Local Plan at the Council Meeting next week will have serious consequences for their futures. Where does that align with Government policy on proactive engagement? Or indeed democracy?
Mr Blathwayt also wrote that a Planning Inspector will consider all the comments made on the plan during the public consultations and those who have made representations can apply to speak at the examination. Only if the Inspector is confident the Plan is legally compliant and meets the tests of soundness as set out in the National Planning Policy Framework (NPPF) can it be recommended for adoption. Why then is Horsham District Council allowing Homes England, a government agency, to flout the National Planning Policy Framework in respect of the thriving and long established facility that is Ifield Golf Club and replacing this with a muddy sports field on a flood plain? At the risk of repeating myself, why did Horsham Council NOT support Rusper Parish Council’s application to declare Ifield Golf Club an ‘Asset of Community Value’, a question I have asked of you and your colleagues no less that FIVE times but have yet to receive an answer.
Councillor Donnelly wrote also that under the Government’s Duty to Cooperate Protocol, houses had to be built also for neighbouring Crawley Borough Council. I understand that this requirement is for 150 house per year. While no mathematician, even I cannot understand how this could equate to the some 3,000+dwellings proposed by Homes England.
I look forward to your response to this letter, and my previous correspondence to you, with interest, and preferably before the Council Meeting on Wednesday next.
G S Flett
JULY 27 2021
Finally a reply from Paul Clarke.
‘In summary we were unable to confirm the number of members at Ifield golf course, with different figures provided by the Parish Council and the landowner; there was no supporting evidence provided from the local community who use the golf course or from the golf course leaseholders themselves or the wider local community to demonstrate use. We were also informed by the owners that they would not be renewing the golf course lease when it expires in 2022’
In my various e-mails regarding the adverse decision by Rob Jarvis, Head of Housing and Community, I have queried why in the interests of natural justice he made no attempt to clarify the discrepancies or involve Ifield Golf Club, simply finding in favour of the owners.
Living opposite the golf course, and part of the wider community, , I have no recollection of being asked to demonstrate use. Regular photos of the often overflowing car park could have been provided.
Dear Mr Flett,
Thank you for your letter and emails.
The National Planning Policy Framework requires that Council’s deliver against housing targets set by the Government. Horsham must also meet unmet needs for Crawley as part of the legal Duty to Co-operate. This means that the Council must make difficult choices as to where new development must be located. As we have no brown field sites to speak of we must regretfully look at green field sites.
The draft local plan document will be considered this Wednesday will be considered by all Councillors.
The NPPF does not state that existing recreational uses can never be re-used or redeveloped – for example this can take place if an assessment has been undertaken that the land is surplus to requirements. The Council has prepared evidence to consider the impact of the loss of a golf course, and is of the view that there is sufficient capacity for golf provision in and around the area.
If Council agrees to publish Local Plan for regulation 19 consultation at the Council meeting next on the 28th there will be an opportunity to formally submit your views on this matter and to have them heard in due course by an independent planning inspector.
In the case of the question on Rusper I have been given a response from officers as follows.
“A nomination to list Ifield Golf Course as an asset of community value was considered in November 2019, the application was made by Rusper Parish Council.
The main difference between the application for Rookwood Golf course compared to Ifield Golf course was the amount of evidence provided to actively demonstrate that the asset meet the criteria as set out in the Localism Act 2011 (as set out below).
(1) Is there an actual use of the building or other land that is not an ancillary* use which furthers the social wellbeing or social interests of the local community?
(2) Is it realistic to think that there can continue to be non-ancillary use of the building or other land which will further (whether or not in the same way) the social wellbeing or social interests** of the local community?
(1) Is there a time in the recent past when an actual use of the building or other land that was not an ancillary use furthered the social wellbeing or social interests of the local community?
(2) Is it realistic to think that there is a time in the next five years when there could be non-ancillary use of the building or other land that would further (whether or not in the same way as before) the social wellbeing or social interests of the local community?
In summary we were unable to confirm the number of members at Ifield golf course, with different figures provided by the Parish Council and the landowner; there was no supporting evidence provided from the local community who use the golf course or from the golf course leaseholders themselves or the wider local community to demonstrate use. We were also informed by the owners that they would not be renewing the golf course lease when it expires in 2022.
The Rookwood application provided a wealth of supporting information including letters of support from both golfers and the wider local community, details from a local survey and petition and details of membership and usage of the golf course as well as comparisons of similar local amenities.
Details on how the decision was made in both cases can be found on the relevant decision notices which can be found here: https://www.horsham.gov.uk/community/assets-of-community-value/view-current-assets-of-community-value
Although the application in 2019 was not approved that does not mean that further applications to list Ifield Golf Course could not be made, it would however have to look to demonstrate sufficiently how it met the criteria, which would mean the application should include additional supporting evidence of it local community use to ‘improve the social wellbeing or social interest of the community.’
Details of how to apply can be found here:
It is worth noting that having asset of community value status does not stop the asset from being sold but does allow for a moratorium period of 6 weeks from the time the landowner notifies the council of its intent to dispose of the asset.
If during this moratorium period a local community interest group expresses an interest in bidding for the land an additional 6 months (from the date of notification) is given to them to put together a bid to buy the asset. During this time the owner may continue to market and negotiate sales but may not exchange contracts.
After the moratorium period – either the six weeks if there has been no community interest or the full six months if a community interest has been registered– the owner is free to sell to whomever they chose and at whatever price and no further moratorium will apply for the remainder of a protected period lasting eighteen months (running from the same start date of when the owner notified the Council of an intention to sell).”
another reply From Paul Clarke. I have sent an e-mail to Homes England seeking to register for the meeting but no response as yet. No idea how many others have applied.
Dear Mr Flett,
In a separate email I responded on Rusper golf club. As for Homes England’s approach to things I would agree it seems presumptive of that body to assume the plan will go though which It may very well not.
Leader & Councillor for Pulborough, Coldwaltham & Amberley
Telephone: 07740 707310
“As for Homes England’s approach to things, I would agree it seems presumptive of that body to assume the plan will go through, which it may very well not”
Horsham District Council Leader – July 27 2021 [in an email to George Flett]
Forgive me for stating the *****ing obvious, but are the owners of the GC [Golf Club] not Homes England themselves?
As I understand it they bought it last year from a consortium which was mainly made up of, wait for it….. house-builders! No vested interest in selling it for development at all there then………
It is obviously not in their interest to declare how well used this asset is, as the last time we spoke to them they were not even aware that Rusper GC was due to close ( and since has), that Cottesmore is also under consideration for development, whilst Rookwood was as well – and that has at least since earned a temporary reprieve.
It is also facile to declare no “supporting evidence” when a call to the club Captain or Committee would surely have yielded an accurate answer, in addition to George’s offer of photographic evidence. Perhaps a look at the numbers of supporters of the “Save Ifield Golf Course” petition would not have helped support the HE case for development. Only 2090 signatures so far – not enough for HE to notice?
JULY 26 2021 – EMAIL FROM ‘GT’ TO ‘RWS’
1. The National Planning Policy Framework, revised on 20 July 2021, introduces a new element into the situation. It seems to me a
document of stunning vagueness:
Its interpretation is of course as yet untested in the courts. It may give the local authority cover for its plan. I don’t know.
2. There is a promised referral to the M of H’s Planning Inspectorate. The inspector will need to work within the framework
of the NPPF. The vagueness of that framework does not, it seems to me, constrain the inspector very tightly; shortly
and crudely, he or she can bring whatever decision they like within the requirements of this highly flexible document.
3. NPPF 97 is now an out of date reference – see new document. A new reference is needed.