January 16 2025 [Thursday] – The Cancelled West of Ifield Hearing Day
Part 1 – The Separate Letter
Part II – Save West of Ifield Statement
Part III – Ifield Society Statement
SAVE WEST OF IFIELD – TOGETHER
Horsham Local Plan Examination
Written statement from Save West of Ifield
Submitted by Fenella Maitland-Smith on 22nd November 2024.
Matter 9, Issue 1 – Whether the strategic sites allocated in the Plan and associated
policies are justified, effective, consistent with national policy and positively prepared?
Q9. Is Strategic Policy HA2: Land West of Ifield sound?
No. The allocation of West of Ifield (WOI) is not based on a sound understanding of the natural characteristics and value of the site and surrounding area, and is inconsistent with several paragraphs of the NPPF.
We note that Natural England (NE) suggest Policy HA2 is unsound, in their Reg 19 response. In summary:
• “The masterplan does not reflect the importance of this area for an internationally significant species. A requirement of Policy HA2 is to mitigate impacts on protected species, including Bechstein’s bats”
• NE is “particularly concerned about the scale, quantum and location of development proposed, which at present will impact an area of regional importance to Bechstein’s bats. Any development here should be sensitively designed and limited in scale and this is not currently reflected in the masterplan.”
• NE would also “expect strategic sites to contribute to Horsham’s Nature Recovery Network.”
• “The site is bounded by a complex of ancient woodland and priority habitats an includes priority deciduous woodland and linear wetland features which will be of clear importance to biodiversity”, and
• Natural England “advise that the policy does not demonstrate that impacts have been avoided and does not follow the requirements of the mitigation hierarchy contained in the NPPF”.
Extracts from our Reg 19 response
The allocation of WOI is not based on a sound understanding of the natural characteristics and value of the site and surrounding area, and we’re concerned that these are being played down. This is inconsistent with NPPF paragraphs
31, 35 and 174, 179 and 180. See comments regarding lack of data under Question 9h below.
i. Nowhere in the Plan or Evidence Base is there a comprehensive and accurate list/map of the designated areas and irreplaceable habitats in close proximity to the site, despite NPPF 179a requirements.
ii. The Plan’s requirements in respect of the Bechstein’s bat are inadequate, and inconsistent with NPPF 179b and 180.
iii. The lack of cross-border collaboration into Surrey related to the bats, the River Mole and wildlife corridors is inconsistent with NPPF 174 and 179b.
iv. The Plan disregards key impacts of the development and the HA2 requirements are too weak to prevent significant biodiversity loss from the site and surroundings given the scale.
Q9a) What is the justification for the proposed number of dwellings and employment in total and over the plan period?
There is no sound justification for a development of this size at this location. HDC’s arguments for locating a development of this size on Crawley’s boundary are unsubstantiated. It’s hard not to conclude that this is a politically motivated decision by HDC to “dump” unpopular housing on the edge of the District, with the political advantage that Crawley’s services will bear the brunt, and Crawley’s roads will cope with the increased traffic.
As explained in our Reg 19 response:
1. Horsham does not need the housing. Nonetheless HDC seems determined to accommodate the housing proscribed by the Standard Method (water neutrality constraints notwithstanding), rather than arguing for a lower overall target and properly planning for sustainable growth in population and prosperity.
The Plan fails to adequately explain or address the fact that Horsham District is experiencing and will continue to experience unsustainable population growth, caused by excessive house-building, driven by the Government’s Standard Method. This contravenes NPPF paragraph 8 as well as forcing HDC to find more and more land to accommodate unnecessary housing, such as at the West of Ifield.
2. HDC claims the houses are being built to meet Crawley’s unmet housing need, despite Crawley BC strongly opposing the Plan and making clear that these are not houses for Crawley people. The most pressing need in Crawley is for social housing, but this is not mentioned in Policy HA2. If the housing West of Ifield was genuinely intended to benefit Crawley then there should have been much closer planning between the two authorities on strategic matters, and perhaps even a joint-plan on some aspects. Not least because Homes England and HDC view the site as a possible first stage of a 10,000 house development that would fundamentally alter the character of the area. The Plan, the HA2 policies and the working with Crawley BC
should all take this into account. They do not and hence NPPF paragraph 22 is contravened.
3. HDC claim that the HA2 allocation will support growth, innovation, and improved productivity. But this isn’t possible because it delivers too much housing and too little employment in an area which already needs significant additional employment land. In fact, it will only worsen Crawley’s existing need for employment land. The Plan is proposing only 17ha of new Employment Land across the District, and only 2ha of it at West of Ifield. So the creation of jobs on site will be minimal. The Plan’s reliance on Gatwick and Crawley
to drive employment is likely to be misplaced, both in terms of the numbers and quality of jobs.
Q9d) Is the allocation consistent with paragraph 99 of the NPPF, particularly with regard to the loss of Ifield Golf Course?
Our Regulation 19 response by Smith Leisure focussed on HE’s position that Ifield Golf Course (IGC) was surplus to requirements. Since then HE have published1 a WOI Draft Golf Needs Assessment and a Draft NPPF Para 103 (99) Assessment, and they now accept that “IGC cannot clearly be demonstrated as being surplus to requirements” – and so fails test (a).
HE have also published (draft) proposals to mitigate for the loss of IGC. These proposed mitigations are not sound.
1. NPPF 99b – replacing with equivalent or better in terms of quantity and quality
HE are not proposing a like-for-like replacement of IGC, but to fund basic repair and renewal works at three municipal courses in Crawley and Horsham. No sound evidence or argument is presented to show that this is “equivalent or better” than IGC, and NPPF 99b is not satisfied.
HE’s draft proposal is unsound because:
1. Supporting evidence is either missing or inaccurate. The baseline evaluation of IGC is based on subjective and unevidenced statements. See Annex A for list of inaccuracies, but in summary:
i. No evidence that all IGC’s existing members and casual players can be easily accommodated at other existing clubs within IGC’s catchment.
ii. HE focusses on IGC’s 510 full members, their subscription and demographics, ignoring the 5.500 visiting golfers.
iii. IGC’s simulator, outreach programme, and other support for those “early in their golf journey” are not acknowledged. [1 https://westofifield.commonplace.is/en-GB/news/west-of-ifield-draft-golf-needs-assessment]
iv. The loss of sport and recreational benefits for older residents is not considered, nor the community recreational benefits of IGC.
v. No acknowledgement that IGC demand is strong given the club’s uncertain future.
2. Smith Leisure’s report provides clear evidence that IGC is a popular and very high quality 18-hole golf club, considered of high sporting and community value historically and currently.
3. We note that the meaning of ‘provision’ is not specified in paragraph 99, but it is stated that the alternative provision must be ‘in a suitable location’ suggesting a single site, and not strewn across multiple locations.
4. HE’s case for not replacing IGC like-for-like is that IGC is misaligned with England Golf’s strategic aims, in contrast to the HE alternative which will encourage younger players and women, and those at the start of their “golfer journey”, and is hence “better” in an NPPF 99 sense. This is a controversial interpretation of NPPF 99, and HE cite the Mapledurham Judgement but don’t explain how this is relevant for the West of Ifield. They also don’t
explain how their proposals actually achieve the England Golf aims.
5. To support their case HE repeatedly state that there is or will be unsatisfied local demand from the target groups but provide no evidence. They mistakenly suggest that IGC does not encourage these groups. And they fail to explain the range and quantity of facilities needed by these groups. The lists of improvements provided for the municipal courses are completely unconnected to the discussion of needs.
2. NPPF 99c – replacement with alternative sports and recreation provision.
No sound evidence or argument is presented to show that “the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use” and NPPF 99c is not satisfied.
HE claim2 that “the wider sports and recreation offer unlocked by the development is significant. … both the sport and recreation offer would clearly outweigh the more limited value of IGC to the non-golfing population as both a golfing, sporting and recreation facility more generally. This would deliver a significant quantum of alternative
provision and a range of benefits that would outweigh the loss of the IGC facility and would satisfy requirement (c)”.
This misinterprets NPPF 99c. WOI is a housing development, with sport and recreational provision for the new residents. The focus of this NPPF 99 analysis should be on any facilities being offered in excess of those needed to serve the new residents – this excess could be considered as mitigation for IGC. HE’s comparison of the total “sport
and recreation offer” with the value of IGC is unsound.
Confusingly, HE’s Annex E3 (1.4) is clear that it doesn’t deal with the mitigation for the loss of IGC. Whereas the last column in Table 3 (NPPF 99/103 document) could be the mitigation for IGC (the excess), but this isn’t discussed.
In conclusion, HE’s proposals are not soundly based or evidenced, and we’re concerned that they could set a precedent for “marginal” mitigation for loss of facilities.
Q9e) Have the transport impacts of the proposed development been adequately assessed and is the mitigation proposed sufficient?
No. There are insufficient mitigations to address the effects of additional volumes on the local transport system.
The assessment conducted by West Sussex Highways was desk-based, and did not (to our knowledge) involve actual traffic monitoring. Proposals place all traffic entering and exiting the site via Ifield Avenue (already severely congested at peak times). The desk-based approach cannot be adequate to provide confidence in the ability of the
[2 Para 7.2 3rd bp of the NPPF 99/103 document. We also note that para 5.35 onwards and Table 4 compare IGS with the benefits from the sum of facilities in the Masterplan. 3 HE’s Annex E – “The West of Ifield Sports and Recreation Study” prepared by Sports Planning Consultants – which covers all the sport and recreation facilities planned for the WOI development, with a focus on the facilities needed to serve the new residents].
proposed mitigations to prevent a very significant impact on traffic flow and air pollution across many residential roads of Langley Green and Ifield.
If the assumptions currently in place prove to be wrong, it will be too late for the existing residents, who will struggle to secure a post development solution.
Our view remains unchanged from our Reg 19 submission that the development would have a major negative impact on the existing traffic issues in the Crawley area by adding additional vehicles. Crawley Active Travel forum have had discussions with Homes England in a positive attempt to understand and help to improve the proposals. No specific changes have been made, as far as we are aware, and no further meetings have taken place – probably because of the General Election.
Q9f) Have air quality impacts been adequately assessed and is the mitigation proposed sufficient?
• As outlined in our Regulation 19 response, the cumulative effects will come from the increase in traffic along Ifield Avenue (and roads that branch off it) combined with the potential air quality impacts from the expansion of Gatwick.
• There is not yet a sufficiently detailed travel plan for the pollution impacts to be assessed.
• While electric cars will reduce exhaust fumes, the additional number of cars will add to the pollution from oil droplets, and fine and ultrafine particles from wear in metal and tyres.
• HDC has already drawn attention to the potential air pollution impact of the construction phase (ref. HDC: EIA/24/0003, 15 July 2004).
• There is not sufficient joint working on this important cross-boundary strategic matter.
Q9g) Have water and flooding impacts been adequately assessed and is the mitigation proposed sufficient?
• Water supply remains a risk because of the restrictions from water neutrality. The WN strategies of reduce, reuse, offset will continue until new sources are found. Offsetting schemes are in their infancy.
Whether tapping into new ground water sources by Southern Water and private developers will supply sufficient water at a sustainable level is not yet known.
• Water quality in Ifield Brook and River Mole will be impacted from increased run-off from roads into the waterways and detritus blown into the water ways. (see Sewage also)
• Sewage: It is evident from Thames Water’s response #1193334 to reg 19, that HA2 presents a major problem for them. Another year of regular, and rigorous, water testing from the River Mole River Watch group, shows that much of the river downstream of the site is still not in a good state.
• Flooding: While SuDs and raised building levels could mitigate surface water flooding within buildings, we still have concerns about river flooding of the site in extreme weather events given that the site has three water courses through it (River Mole, Ifield Brook and an un-named water course). Risk from inundation from Ifield Mill Pond and Douster Pond is small but not negligible. Flooding downstream is also an issue. With Southern Water supplying water and Thames Water receiving it, all the water used in the development flows additionally into the Mole via the Crawley STW – and hence increases risk of flooding downstream.
Q9h) Have heritage, biodiversity, and landscape impacts been adequately addressed and is the mitigation proposed sufficient.
Heritage: As made clear in our Reg 19 response, the impacts on Ifield Village Conservation Area and on the design concept of Crawley as a post war New Town have not been adequately assessed.
Biodiversity
Extracts from our Reg 19 response
Biodiversity and habitats have not been adequately assessed and we are seriously concerned at the lack of ecological data available at the point the site was allocated into the Plan.
i. Nothing is presented in to suggest that the allocation was informed by survey data, consultation with wildlife groups, neighbouring authorities or any other sound evidence regarding biodiversity value or amenity value.
It appears to have been entirely a desk-based exercise. All surveying is to be left to Homes England (HE), which, judging by the EIA Scoping Requests (2023 and 2024) might be very partial. An FoI request to HDC failed to establish the extent of any surveying and whether HE have shared data with HDC. Our requests to HE for permission to conduct hedgerow or other ecological surveys have been refused.
ii. A historical lack of recording of the area means that its true biodiversity value is unknown. But the results released by HE so far suggest that the biodiversity, and presence of priority species, is much higher than expected.
iii. HDC’s assessment and understanding of existing and potential biodiversity value across all Strategic Sites is inadequate and so the scoring and comparison of the sites in the Sustainability Appraisal (SA) is highly questionable.
See Sussex Wildlife Trust‘s response at Regulation 18, which HDC have not actioned: “…the
plan should not be taken forward as the significant effects on biodiversity remain unquantified and poorly understood …”
New information made public since the Reg 19 consultation.
HE have made public a limited amount of survey data, and have set out their intentions in various drafts of their EIA Scoping Request, most recently in June 2024. In response, Natural England said: ‘The area likely to be affected by the development should be thoroughly surveyed’. We have urged HDC to require more of HE.
Nowhere in the EIA is there an explanation of how the ecological value of designated sites (and other features) has been or will be assessed. Designated sites are described, but without any mention of surveying. Justifications for scoping sites in or out for future study are based on distance from the site, not the presence or absence of ecological features.
The description of the ecological baseline assessment is confused and vague which doesn’t inspire confidence that it is being conducted in line with the CIEEM Guidelines, and will be adequate.
Despite the emerging conclusions about the Bechstein’s bat population (Ramboll report – annex to the 2024 draft EIA) being based on incomplete survey evidence, HE are assuming the conclusions hold and that WOI is not of particular importance for the local population. The use of the golf course by the bats is being down-played.
Is the mitigation proposed sufficient?
We note that the Horsham ecologist in their response to the HE’s 2024 draft EIA suggested that “…this site has potential to meet published selection criteria for Special Area of Conservation (SAC) designation if there is sufficient evidence to support that the Bechstein’s bat maternity roosts in this area and the surrounding area are of, or could be restored to, favourable conservation status. This is something that the Applicant will need to consider.”
The lack of understanding of impacts means the mitigations and requirements in HA2 are weak and in some cases unachievable. See Annex B for our suggestions for strengthening HA2 – as per our Reg 19 response to HA2 – Habitat and biodiversity.
In our response to the 2024 EIA Scoping Request we expressed concern that:
a. Mitigations for the Bechstein’s bats have already been designed, and will be minimal and superficial. For example, see page 11 of the Ramboll report.
b. ‘Key design concepts’ are listed on page 7 onwards but it’s hard to see how key ecological corridors, connectivity and 30m buffers can be retained around hedgerows and copses given the building density, particularly across the golf course and along Ifield Brook.
c. Figure 5 should show playing pitches and sports facilities – they’re on the edges of the site adjacent to woodland and could involve significant artificial lighting.
Other concerns we raised at Reg 19:
• No requirement to minimise the impact of the road and its effect on the habitats it crosses, particularly the River Mole.
• No policy on minimising the habitat loss and disruption during construction.
• No acknowledgement that Ifield Brook Meadows Local Wildlife Site will become isolated – surrounded by housing – with all ecological connectivity to the countryside severed. Despite Sussex Wildlife Trust raising the concern in 2020. No evidence that HDC or HE have consulted Crawley BC about Ifield Brook Meadows, Willoughby Fields LNR and other LWSs.
• The Sustainability Appraisal assumes the requirements and mitigations in HA2 will be much more effective than the requirements for other sites. based on a lack of understanding of the site, its biodiversity and the impact of the development.
Q9k) Are the infrastructure requirements identified reflective of the latest evidence, justified and effective?
• The infrastructure proposals are inadequate as detailed in our Reg 19 submission. We’re concerned that the people of Langley Green have not been included in the consultation process and therefore not had the opportunity to adequately feed in their concerns.
• Sewage: There is a clearly identified problem in many of the evidence documents that Thames Water may not be able to supply the sewage facilities in the timeframe required.
• Power: We have no evidence that the capacity of the electricity distribution network is sufficient to cope with the additional load.
ANNEX A. Errors and inaccuracies in Homes England’s Assessments – September 2024