What might a 30 year plan for Horsham Look like?


The Government announced changes to the National Planning Policy Framework (NPPF) on Tuesday 20 July, without notice. These changes have significant implications on the Horsham District Local Plan.

Horsham District Council is now required to prepare a Local plan detailing 30-year vision.  The current draft Plan prepared under the previous requirements sets out planning policies and proposals to guide development up to 2038 only.

We have sought legal advice and it is clear that we will need to commission some additional work to support this new 30-year vision requirement. Consequently, we have been recommended to delay the development of the Local Plan.

As a result of the changes required and the legal advice sought, the meeting of full Council on 28 July to approve the Regulation 19, Pre-Submission Horsham District Local Plan document will be postponed.

Leader of the Council Cllr Paul Clarke said:

This is hugely disappointing news. We have sought help from MHCLG to reduce our housing requirements without any substantive success. As a result we have worked hard to prepare a plan that would pass muster with a Planning Inspector in order to protect the District against speculative development.

The Government consulted on the possible requirement for Local Plans to include a 30-year vision some months ago and we responded asking for guidance on how this could be evidenced. We received no feedback and had no advance warning of this substantive change in the NPPF. Worse still, no guidance has been published alongside the changes to the NPPF to explain what Local Authorities need to do to meet this new requirement.

Our legal advice is clear that we have no choice but to delay our Plan.”

The reference is to Para.22 of the new NPPF. Without notice errr it was in the consultation draft.

Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.

Which is subject to the following footnote, which wasnt in the consultation draft.

For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published (for Spatial Development Strategies this would refer to consultation under section 335(2) of the Greater London Authority Act 1999).

This seems a major cock up by the ministry in not giving a period of grace post NPPF amendment.

The policy change of course cam about because of the North Essex Garden Communities fiasco where units planned beyond the end date of the plan counted for nothing.

Lets out this into context. The Gatwick Diamond area, apart from being the least constrained area in the London to Brighton corridor is also an area of major growth. Horsham and Crawley then are going to have to mop up growth constrained by the sea and South and North downs.

Oddly Horsham itself was planned for no new strategic allocations (other than redevelopment of a retail park and adjoining land)- bizarre, and the only rail based strategic site was a relatively small one based at Billinghurst. Eastwards expansion of Crawly was put in as a major area of search for long term growth, which seems much better than a car based new settlement at Buck Barn, based at the interection of the two major roads in the district it would be entirely car based, and at 3-3,500 units far too small to be relatively self contained or meet overspill needs of the South Coast.

A 30 year vision needs to be looking at a new settlement or major expansion of Crawley or Horsham of at least 25,000-30,000 homes, rail based at Christs Hospital, Billinghurst or Faygate. Buck Barns, very controversial, is only in because members blocked a site at Rookwood Golf Club within the inner ring road.

What is needed is a strategic study across Sussex for 30 year horizon zero carbon locations for development.

Just how much frontloading is needed for Zoned Sites?

An issue that frequently comes up is that more frontloading is needed for zoned sites.

I would frame the issue like that. Is any more frontloading required for a zoned site, where only the principle of development and number of units is in a local plan compared to avoiding costs on an appeal on an outline application refused despite being allocated in a conventional local plan.

Less – probably.

In order to be sure that the number of units in a draft allocation is ‘deliverable’ the LPA and the site promoter need to put in a minimum amount of work. If there are habitats issues they need to be sure conditions on SANG etc. can be delivered. They need to know how much of the site may be undevelopable because of protected species etc. They need to know the access to the site can deliver the number of units.

On a large site in outline only it is normal not to reserve the main site accesses in order to test and prove the site capacity. The highways authority should be giving advice on this anyway.

If you have allocated a site where the sequential flooding test applies you don’t need to do it again.

A minimum of habitats work needs to be done anyway as part of the AA of a development plan.

So some additional work is needed but no more than good practice in determining if a site is deliverable, and probably less in cost if an LPA refuses an allocated site and is awarded costs against them on an appeal.

Of course you could really front load costs and work with LPA funded masterplanning, but that is an optional extra, masterplans and design codes can and should be required by LPAs for large allocated sites prior to outline approvals come forward.

The concern I fear about frontloading comes from poorly resourced authorities who are unable to do the work on many small and medium size sites to demonstrate they are deliverable, and so are forced to allocate a large buffer of sites in the expectation that many of them will not be.