HORSHAM LOCAL PLAN – WEST OF IFIELD [HA2] SUBMISSIONS

Richard W. Symonds – West of Ifield [HA2] Submission – Horsham Local Plan

Q3 – I consider the Local Plan non-legally compliant, unsound and in breach of the duty to co-operate, for the following reasons:1. HDC’s disturbing over-reliance on Homes England’s flawed promises to make the West of Ifield allocation viable and deliverable

Homes England do not appear to have the capacity nor competence to deliver on their promises. Woeful stewardship of public land [and ‘land-grab’] west of Ifield has led to deep lack of trust in this government quango [I can provide specific evidence of this poor stewardship which has created this distrust if required].

2. HDC’s staggering disregard for the duty to co-operate which will lead to a monstrous destruction of the ancient Parish of Ifield“. How dare they.

West of Ifield Rural Fringe – Crawley Local Plan. Policy CL7/CL8: Important Views and Valued Landscape/Development Outside the Built-Up Area – Page 60: “Proposals which respect this area of locally special rural fringe, its nature conservation and recreation value, its positive relationship with the urban edge and links to the wider countryside will be encouraged”

3. Transport and Traffic  Crawley Western Link Road [CWLR]: HDC’s ‘make-it-up-as-we-go-along’ policy in this regard doth not a sound plan make. There is no ‘joined-up thinking’ by any of the parties concerned. It’s an unviable, unworkable plan with no infrastructure in place. The CWLR should be shelved in the same way HA2 should be deemed unsound.

4. Water Neutrality/Water Supply/Wastewater/Sewage/Flooding/Pollution/Contamination. Natural England’s statutory directives regarding Water Neutrality are clearly not being met – with disgraceful circumventing of such clear directives. More examples/details can be provided if required.

5. Biodiversity/Wildlife/Habitats/Rare species. HDC’s policies on biodiversity and nature recovery are unsound and the NPPF requirements on the issue are contravened. More detailed information can be provided if required.

6. Ifield Golf course: NPPF 2023 [para 99] states that a sports facility cannot be built on unless there is sufficient proof  it is surplus to requirements – or the loss resulting from the proposed development would be replaced by equivalent or better provision. These requirements are clearly not met regarding Ifield Golf Course.

7. Heritage assets – preservation, protection & conservation. Heritage assets are highly valued in this community – but totally disregarded by both HDC and Homes England. Both are in direct contravention of NPPF 190b 92. Such assets include those associated with the ancient Parish of Ifield. More information can be provided if required.

Q4 – I consider the modifications necessary to make the Local Plan legally compliant, sound and meeting the duty to co-operate is to make the whole area [HA2] a Local Nature Reserve under a Joint Area Action Plan [JAAP].

This proposal has already been made to the  – but ignored by the parties concerned.

We in the community took CBC seriously when they stated, with regard to the West of Ifield Rural Fringe [Crawley Local Plan. Policy CL7/CL8]: : “Proposals which respect this area of locally special rural fringe, its nature conservation and recreation value, its positive relationship with the urban edge and links to the wider countryside will be encouraged”

With that official encouragement, the local community took action, including:

1. ‘Making the Case for a Local Nature Reserve and Heritage Site on the West of Ifield Rural Fringe’ – A detailed report, with introduction and conclusion by Crawley Community Awards Winner David Moon.

2. A Local Nature Reserve Exhibition.

3. Kingfisher Nature Conservation and Heritage Park [a proposal based on the 1996 brochure ‘Ifield & Beyond – A Taste of the Sussex Countryside’ – funded by Horsham District Council, Crawley Borough Council and West Sussex County Council].

4. Regular Saturday MorningWalks [‘Ramblettes’] around the ancient Parish of Ifield – including ‘Beating the Bounds’. These walks have been organised by the Ifield Society for the last 24 years [ever since the area – with its 1000-year+ history – was deemed to be “lacking in heritage and character” as a pretext for developing this historical site into a building site].

5. An Ifield Parish Map Project [based on the West Sussex Parish Map Millennium initiative]

Horsham District Local Plan 2023-40 Consultation (Regulation 19)
CPRE Sussex response, objecting to:
STRATEGIC POLICY HA2: LAND WEST OF IFIELD

CPRE Sussex objects to Strategic Policy HA2: Land West of Ifield for the reasons explained below.
1. The proposed scale of development would result in the loss of a considerable area of countryside in which there are habitats of principle importance, including designated Ancient Woodland, a designated Local Wildlife Site, and an extensive network of hedgerows providing vital biodiversity connectivity across and beyond the site.
2. HDC’s Regulation 18 site appraisal stated that
– “There are a number of constraints in this area that could lead to the development impacting on biodiversity, flooding and heritage, and it is affected by noise impacts from Gatwick Airport”.
= “Whilst there is potential for mitigation, these issues will need to be resolved and together with the proposed scale of development in this location, the rate at which the scheme can come forward and be delivered may slow the rate at which development can initially commence”.
– And that “a development of this scale will have very significant changes on the settlement pattern and the wider rural character in this area, and a particular concern is the potential for coalescence between Horsham and Crawley”.
2.1 These are all critical issues in respect of Regulation 19 HDLP Policy HA 2: Land West of Ifield.
Efficacy of Sustainability Appraisal Update is questionable
3. According to the Sustainability Appraisal (SA) Update, December 2023: (at page 93) Table 5.9 ‘Findings for policies allocating strategic sites in the 2021 draft’ the appraised (–/?) ‘significant negative effects likely’ for the site’s (SA objective 6) Biodiversity and Geodiversity reduces to the ambiguous (++/–?) ‘mixed minor

or significant effects likely’ with mitigation. With mitigation, too, the appraised impact of the development on both (SA objective 7) Landscape and the (SA objective 8) Historic environment reduces from (–/?) ‘Significant negative effects likely?’ to (–/+?) ‘minor negative effect likely’, and the appraised effects for (SA objective 14) Air quality is the ambiguous ‘mixed minor or significant effects likely’ (++/–?) without and with mitigation.
3.1 The meaning of the ‘?’ is not explained in the ‘Key to symbols and colour coding used in the SA framework’ detailed at page 168 of the Sustainability Appraisal Update.
3.2 However, if as seems likely the ‘?’ denotes not known, or uncertainty, the Appraisal’s efficacy is questionable – and in doubt.
3.3 And why is the Appraisal appraising the effects on Biodiversity and Geodiversity as a single entity, instead of Biodiversity and Ecology?
4. ‘Horsham District Council Interim Sustainability Appraisal of Growth Options for Horsham District Local Plan Regulation 18 Consultation, at paragraph 2.58 advises that “The effects of development in relation biodiversity and geodiversity assets in Horsham will depend in part on the design, specific location of development and as well as the sensitivities of nearby biodiversity designations and other undesignated habitat areas. This is currently unknown and therefore all effects recorded in relation to SA objective 6 (Biodiversity and Geodiversity) are uncertain”.
4.1 The continued use of the ‘?’ the Sustainability Appraisal (SA) Update, December 2023, questioned at paragraph 3.1 above, indicates that all effects recorded in relation to SA objective 6 are uncertain and have yet to be determined.
5. ‘The State of Nature 2019’ report advises that “Ancient woodland, highly important in terms of biodiversity value and supporting a wide range of specialist species is estimated to cover only around 2.4% of UK land” – and that “Recreational use, particularly in woodland close to urban areas, has detrimental impacts on soils, invertebrates and flora through trampling and compression”.
5.1 How the scheme would impact on the area’s designated Ancient Woodland, and whether these detrimental effects can be prevented must be determined and considered.
CPRE Sussex cntd….
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6. NPPF policy 31 requires that plan policies should be underpinned by relevant and up-to-date evidence, which is adequate and proportionate, focused tightly on supporting and justifying the policies concerned.
6.1 What is the evidence base for the Appraisal?
6.2 Does the Appraisal’s appraisal of the effects on biodiversity consider and
assess the effects on priority species and habitats?
6.3 Is the Appraisal’s appraisal informed by an up-to-date on-site 4-seasons survey of the site’s fauna, including bird species (breeding, nesting and foraging there), bats and other small mammals, reptiles and amphibians and invertebrates, and flora?
Wastewater Treatment Works could take up to 10 Years to plan, design, obtain approvals and build
7. Strategic Policy HA2: 10 states that ‘Close liaison with water treatment utilities companies must be undertaken, including clear agreements on the phasing of development, to ensure that a new or expanded Wastewater Treatment Works (WwTW) is provided to provide timely additional capacity for the sewerage network’, but does not consider how long it would take to plan, design, obtain approvals, and build.
7.0.1 And neither does the Sustainability Appraisal (SA) Update’s appraisal of the proposed development.
7.1 Helpfully, however, Draft Crawley Borough Local Plan 2024 – 2040 May 2023 for Submission Publication Consultation: May – June 2023, paragraph 8.11 advises that:
– ‘The Water Cycle Study Crawley Addendum Report (January 2021) identifies that the flow permit for Crawley Wastewater for Crawley Wastewater Treatment Works is likely to be exceeded towards the end of the 2025-2030 period’.
– ‘Thames Water has confirmed that the works is close to its treatment capacity, and will exceed its permit during the Local Plan period’.
– ‘Wastewater/Sewage Treatment Works upgrades take longer to design and build. Implementing new technologies and the construction of a major treatment works extension or new treatment works could take up to ten years to plan, design, obtain approvals and build.
CPRE Sussex cntd….
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– ‘in the event of an upgrade to sewerage network assets being required, up to three years lead in time is usual to enable for the planning and delivery of the upgrade’.
– ‘As a developer has the automatic right to connect to the sewer network under the Water Industry Act, the Infrastructure Provider may request a drainage planning condition if a network upgrade is required to ensure the infrastructure is in place ahead of occupation of the development. This will avoid adverse environmental impacts such as sewer flooding and/or water pollution’.
– ‘In case of major development, it is strongly recommended that developers engage with Thames Water, as the wastewater infrastructure provider, at the earliest opportunity to establish: • the development’s demand for wastewater/sewage treatment and network infrastructure, both on and off site, and whether it can be met; and; • what loading/flow from the development is anticipated’.
Affordable Housing: will the development deliver a minimum of 40% affordable homes?
8. Will the development deliver a minimum of 40% affordable homes, as stated at HA2: 2 a)? Might viability be an issue for developers, as it was and continues to be for Land North of Horsham, which instead of the HDPF requirement for 35% affordable housing is delivering around 18% – on grounds of viability?
Gatwick Airport: Noise and Pollution
9. The ‘CPRE Aircraft Noise Study Findings Report’, July 2019, shows that the northern part of the proposed site is within the Gatwick Airport noise contours 45db to 60db. Exposure to noise at these and higher levels are associated with adverse effects on health and sleep.
9.1 Exposure to air pollutants resulting from aircraft emissions, and from road traffic, which the airport attracts, with consequent harming impacts on health, is also a critical issue (‘CPRE Flight Blight: the social and environmental cost of aviation expansion’, 2019).
9.2 Strategic Policy HA2:6 states that ‘A full noise impact assessment and mitigation strategy is submitted and agreed by the Council, which demonstrates that aircraft noise has been assessed and its impacts mitigated across the whole development. No residential or other noise sensitive uses are permitted anywhere on the site considered to be exposed to current or potential future
CPRE Sussex cntd….
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aircraft noise level, which is above 60dB LAeq, 16hr; Gypsy and Traveller accommodation should be located where noise impacts are not in excess of 57 decibels reflecting the lower level of acoustic attenuation provided by caravans’.
9.3 Has a full noise impact assessment and mitigation strategy, which demonstrates that aircraft noise has been assessed and its impacts mitigated across the whole development, been submitted and agreed by the Council?
9.4. Does the proposed scheme, in respect of noise and air pollution in consequence of Gatwick, meet the requirements of Strategic Policy 27: Inclusive Communities, Health and Wellbeing: 2 stipulation ‘New development must be designed to achieve healthy, inclusive and safe places, which enable and support healthy lifestyles and address health and wellbeing needs’?
Ecosystem Services
10. How the loss of this extensive area of countryside, in effect a green lung, would impact on the residents of Crawley and their wellbeing seems not to have been considered. It should be considered.
11. The impact that the development would have on ecosystem services within and adjoining the site and for Crawley has not been assessed or considered. It should be assessed and considered.
Conclusion
12. We question the viability of Policy HA2: Land West of Ifield and consider that the policy should be rejected.

Dr RF Smith – Trustee CPRE Sussex

For and on behalf of CPRE Sussex

 

 

 

 

 

 

Save West of Ifield believe that the HDC Local Plan is unsound because the allocation of the West of Ifield site is unsound. We are submitting reports on several topic areas as part of our representation, with reference to NPPF paragraphs and HDC Policies that we believe are breached.
Please find attached our reports.
Attachments
1. SWOI Reg 19 – Policy HA2 – Biodiversity+Suppdocs. The allocation of the West of Ifield site is unsound in respect of NPPF paras 31, 35, 174, 179 and 180
2. SWOI Reg 19 -Policy HA2 – Air Pollution. Allocation of West of Ifield is unsound in respect of cumulative effects of air pollution NPPF 185,186
3. SWOI Reg19-Policy HA2- Heritage. The allocation of West of Ifield is unsound in respect of NPPF 197 and 200
4. SWOI Reg 19 – Policy HA2 – Water. The long term provision and maintenance of the necessary infrastructure is too uncertain; hence the site is not deliverable.
5. SWOI Reg 19-Policy HA2 – Health. The West of Ifield proposals cannot provide the health infrastructure required by the NPPF
6. SWOI Reg 19-Policy HA2 – Golf Main. Independent Report.The loss of Ifield Golf Course and lack of suitable alternative fail the tests in NPPF paras 99a and b
7. SWOI Reg 19-Policy HA2 – Golf appendices 1 of 2. Appendices to Golf Main.
8. SWOI Reg 19-Policy HA2 – Golf appendices 2 of 2. Appendices to Golf Main.

9.SWOI Reg 19 – Policy HA2 – Golf NPPF 99c FINAL.The loss of Ifield Golf Course and lack of suitable alternative fail the test in NPPF para99c
10. SWOI Reg 19-Policy HA2 – Landscape. Independent Landscape Report

files.
SWOI Reg 19 – Policy HA2 – Biodiversity+Suppdocs FINAL.pdf
SWOI Reg 19 – Policy HA2 – Air Pollution.pdf
SWOI Reg 19 – Policy HA2 – Heritage FINAL.pdf
SWOI Reg 19 – Policy HA2 – Water FINAL.pdf
SWOI Reg 19 – Policy HA2 – Golf appendices 1of 2 FINAL.pdf SWOI Reg 19 – Policy HA2 – Golf appendices 2 of 2 FINAL.pdf SWOI Reg 19 – Policy HA2 – Golf Main FINAL.pdf
SWOI Reg 19 – Policy HA2 – Golf NPPF 99c FINAL.pdf SWOI Reg 19 – Policy HA2 – Landscape FINAL.pdf SWOI Reg 19 – Policy HA2 Health FINAL.pdf

 

Save West of Ifield believe that the Horsham District Council draft Local Plan is unsound as policy HA2 is unsound. Please remove allocation HA2 from the plan
Attachments.
Attachments added to question 4 here are overspill documents/reports for question 3, as we have more than 10 files we need to support our arguments in q.3.
1.SWOI Reg 19 Policy HA2 Exec Summary and Spatial Strat Final. Independent report. Executive Summary, Plan policy review and Plan Spatial Strategy review.
2.SWOI Reg 19 Policy HA2 Transport Final. The allocation of West of Ifield is unsound in respect of transport provision that would be needed by the HDC HA2: Land West of Ifield site proposals
3.SWOI Reg 19 Policy HA2 Highways and Transport Tecnical advice. Independant Transport Report ( originally commissoned for Rusper Parish Council)
4.SWOI Reg 19 Policy HA2 Transport Modelling Final. Independent assessment of Transport modelling.
5. SWOI Reg 19-Policy HA2 – Gatwick noise. The allocation of West of Ifield is unsound in respect of NPPF 174 and 185
6. SWOI Reg 19 Policy HA2 Housing Final. The allocation of West of Ifield is unsound in respect of NPPF 8.

SWOI REG 19 Policy HA2 Highways and Transport Technical Advice.pdf
SWoI_Reg19_PolicyHA2_Transport_FINAL (2).pdf
SWOI Reg 19 – Policy HA2 – Exec Summary+Spatial strat FINAL.pdf SWOI Reg 19 – Policy HA2 – Transport modelling FINAL.pdf
SWOI Reg 19 – Policy HA2 – Gatwick noise FINAL.pdf
SWOI Reg 19 – Policy HA2 – Housing FINAL.pdf

 

 

 

 

 

 

 

FROM THE ARCHIVES [JULY 29 2019] – “HOMES ENGLAND PLAN £3BN CRAWLEY GARDEN VILLAGE” – WEST OF IFIELD – ESTATES GAZETTE INTELLIGENCE [EGI]

 

JANUARY 26 2024 – “STAGGERING DISREGARD FOR, AND MONSTROUS DESTRUCTION OF, THE ANCIENT PARISH OF IFIELD” – RICHARD W. SYMONDS – THE IFIELD SOCIETY