Draft Horsham District Local Plan 2019-2036

Chapter 6 Housing (Key Questions)

This document will address the following issues:

The median house price in Horsham District is around 14 times higher than average annual earnings. The cost of private renting also remains high. This creates a high demand for affordable housing, which is available at less than market value. The high cost of housing can act as a barrier to suitable housing for those who wish to live and work in the District (e.g. young people). Housing needs to be available to all. This includes providing higher levels of social/affordable rented housing whilst looking at measures to ensure that housing is more generally affordable (e.g. to first time buyers) and through other mechanisms including self and custom build.
Although there is a high percentage of elderly residents, there are also a large number of families. Housing that is provided must also meet the needs of families. There is a higher than average proportion of 4-bedroom homes in Horsham District, whereas the significant need for family and single-person homes is better met by less expensive 1-3 bedroom homes. Therefore, more homes of a more modest size are needed in future.
There will be significant growth in the population of older people, and in particular, the number of people aged 75 or over. There will also be growth in the number of people with long-term health problems or disabilities. There is a need to plan for the specific needs of an increasingly elderly population, including a growing requirement for retirement homes, residential care homes and smaller units.
The Government is seeking to deliver a step change in housing growth. This means that the District’s population will continue to rise over the next 20 years. There is a need to ensure that everyone can access good quality housing to meet the needs of a mixed population and support the economy.
The settlements of Horsham, Billingshurst, Broadbridge Heath and Southwater have accommodated large developments in recent years, but pressure for housing development remains. Care needs to be taken to ensure communities can absorb changes that have taken place to allow stable, cohesive communities to thrive and that development can be built out at a rate that is in keeping with market demand.

Housing Need in Horsham District

6.1 In 2019, the population of Horsham District has been estimated at 141,717. This compares to 131,300 at the time of the 2011 Census. The Government is committed to delivering a step change in the number of houses that will be built in the coming years, and it is predicted that the population will grow by another 17,658 or 12.5% over the 20-year period to 2039. The main elements that make up the changes to population are natural changes (the number of births and deaths) and migration, where people move both in and out of the District. Most of this movement is relatively local, from within and around Sussex and the south east / London but a smaller amount is from further afield. The population estimates indicate that the population in all age groups will grow, but by far the highest growth will be seen in the over-65 population (and especially in the over-75s). There will also be strong growth in younger age groups including those of working age. This will mean that the District will need to provide more jobs in future to ensure there are new job opportunities available for the growing population.

6.2 To ensure that the Government commitment to delivering more homes is met, national planning policy has introduced a new method of calculating housing need and provision has changed since the adoption of the Horsham District Planning Framework. All local planning authorities are required by the Government to calculate a ‘local housing need’ figure, based on a 'standard methodology'. This consists of the following:

Calculate projected household growth over a ten-year period (i.e. the total number of new households expected to materialise), then
Apply an adjustment based on affordability (this is done by comparing average incomes to average house prices).

6.3 As the projected household growth numbers are set out at a national level by the Office for National Statistics, local planning authorities do not have discretion to change this calculation, or in any way influence its outcome. Furthermore, national policy makes clear that local planning authorities are expected to provide enough new housing each year to meet at least this number, in order to be considered a ‘sound’ Plan.

6.4 The standard methodology calculation for Horsham District is calculated as 965 dwellings per annum. This is equivalent to providing a minimum of 17,370 homes in the period between 2019 and 2036.

Wider Housing Need and the Duty to Co-operate

6.5 Horsham District does not exist in isolation and the vast majority of the District falls within an area known as the North West Sussex Housing Market Area. This area includes the whole of Crawley Borough, much of Mid Sussex District and a small area of Reigate and Banstead Borough in Surrey. The legal Duty to Cooperate requires the District to consider how much additional development can be accommodated in a way that helps address the unmet housing need of other districts in the surrounding area.

6.6 Through a long history of joint working, commencing prior to the legal 'Duty to Co-operate' requirements, the authorities in this area have worked together to ensure that the housing need in the housing market area has been met. Under the current Local Plan, we are providing 150 homes a year to meet housing needs that cannot be met within Crawley's administrative area. The ongoing housing development at Kilnwood Vale to the west of Crawley was developed in partnership with Crawley Borough Council as part of a Joint Area Action Plan.

6.7 The standard housing methodology calculation has resulted in increased housing requirements not only in Horsham District, but also in Crawley Borough and in Mid Sussex. This places an increased challenge on all three authorities in seeking to accommodate these additional housing requirements. Crawley Borough Council is currently reviewing its Local Plan, and due to the constrained nature of the borough, which is built up to its administrative boundaries, they have identified that they will not be able to meet a significant proportion of their identified housing needs in their Plan period. The precise amount of unmet need will need to be confirmed through the Examination of the Crawley Local Plan but is potentially around 400 homes per year. However, this Council will continue to work with the authorities in the North West Sussex Housing Market Area through the Duty to Co-operate process to determine how this challenge can best be met.

6.8 A small part of Horsham District also falls within another housing market area – the Coastal Housing Market Area. This housing market area is primarily focused on the settlements of Brighton & Hove, Shoreham and Worthing but extends northwards into the southern part of Mid Sussex District, and covers the settlements of Steyning, Upper Beeding and Henfield in the south east of Horsham District. The settlements on the south coast have identified that they have unmet housing needs as they are constrained by the coast to the south and the South Downs National Park to the north. Whilst the precise level of unmet need is still the subject of Duty to Co-operate discussions, the evidence suggests that there is an overall unmet housing need of around 2,000 homes per year in the wider Coastal Area. It should be noted that nearly all of this need arises from the seaside towns, which are some distance from the southern boundary of Horsham District and separated from most of Horsham District by the South Downs National Park. Nevertheless, opportunities for helping to meet the unmet housing need arising from neighbouring districts and boroughs to the south will need to be considered.

6.9 In addition to the unmet housing needs from Crawley and the South Coast, other authorities in Surrey and the south London Boroughs have indicated that they also have unmet housing needs. In total, the unmet housing needs across the different authority areas comes to around 3,000 per year in addition to the requirement of 965 homes each year for this district. At the current time, this Council has a good track record of housing delivery and we have been able to meet our current housing target of 800 homes per year. The first requirement for the preparation of our Local Plan is to meet our own housing requirement derived from the standard housing methodology. Market forces, the need to deliver additional infrastructure and the physical availability of land for development mean that it will not be possible for this District to accommodate all of these unmet needs. In seeking to determine the amount of additional housing that this District may be able to deliver, it will be necessary to prioritise meeting the needs of authority areas with the closest links to this District in the first instance.

House sizes, types and affordability

6.10 In addition to understanding the number of homes that it is required are built in the District in the Plan period, it is important that the homes are the right size, type and price. To understand more about the housing needs of our District, a study known as a Strategic Housing Market Assessment (SHMA) has recently been undertaken.

6.11 The SHMA has assessed the level of affordable housing need in the District. The median house price in Horsham District was £380,000 in 2018 – this is around 14 times higher than average annual earnings. The cost of private renting also remains high, with median monthly rents of around £1,000 per month. It is considered that the high cost of housing in the District is a significant barrier to younger people and families being able to work and live in the District. There is therefore a high need for a range of different types of affordable housing. There is also a need to ensure that the types of homes that come forward are a mix of sizes and include smaller dwellings.

6.12 Horsham District has a relatively high proportion of the population aged over 65. In 2017, the percentage of over 65s was estimated to be 18.4%. This is likely to increase to just under 30% by 2039. As we age, there is an increased chance of a long-term health problem or disability, and the number of older people who have mobility difficulties and conditions such as dementia will rise. It is therefore important that housing provision meets the needs of the older population. Some of these homes will need to provide specialist support. For example, sheltered housing has an on-site warden, and extra-care housing has tailored clinical services on-site. Others may simply be designed to be smaller and suited to those with limited mobility.

Policy 14 - Housing Provision (Key Questions)

6.13 As well as working to meet increased housing demand, we will continue to promote economic growth and discourage long-distance commuting. Additional homes will be provided to meet this need and in order to support the wider economy of the Gatwick Diamond and beyond.

6.14 Horsham District has an objectively assessed ‘local housing need’ of 965 homes per year. However, as explained in earlier paragraphs, the Duty to Cooperate requires the District to consider how much additional development can be accommodated in a way that helps address the unmet housing need of other districts in the surrounding area. It is considered appropriate to test the deliverability and impacts of three potential overall level of housing growth. These are explained in the table below:

1,000 homes per year	This would meet the minimum local housing need as determined using the Government’s standard formula. This would fully address the housing need in Horsham District, together with the 5% buffer that is required to provide flexibility, but would not provide any additional housing towards the unmet housing needs of Crawley and the Coastal Sussex area.
1,200 homes per year	This would meet the local housing need and 5% buffer. It would also provide around 200 homes each year to help meet the unmet housing needs of Crawley in particular, and a small element in the Coastal Sussex area.
1,400 homes per year	This would meet the local housing need and 5% buffer and provide around 400 homes each year to help meet the unmet housing needs of Crawley and the Coastal Sussex area.

6.15 This ongoing level of growth is unprecedented, and it will be important to test how these homes could be delivered on an ongoing and sustained basis for the whole plan period. Each of these figures is being tested through a range of assessment processes including the following:

Strategic Housing and Employment Land Availability Assessment (SHELAA). This tests the suitability, availability and deliverability of individual sites
Environmental, economic and social sustainability through the Sustainability Appraisal and Strategic Environmental Assessment Process
Infrastructure requirements including Strategic Transport modelling and the scope for mitigation
Deliverability, in relation to both infrastructure requirements and the market’s ability to bring forward the required number of homes each year.

6.16 The long term deliverability of housing over the plan period is a significant challenge for the District. Firstly, the level of housing growth will require a high degree of additional infrastructure, such as road improvements or sewage treatment works in order to meet the needs of the new population. (It should however be noted that this infrastructure will not resolve existing deficits, as development need only provide infrastructure to meet the needs of the new development). These upgrades often have long lead in times which may therefore limit the amount of housing which can come forward until these upgrades have been provided. In addition, the Council does not have any direct control over housing delivery rates. It will therefore be necessary for the Council to consider whether there will be sufficient market demand for very significant levels of housing delivery either in the district as a whole, or in / around particular villages and towns. There is also no guarantee that there will not be issues outside our control (such as a national economic downturn) which would limit the delivery of homes.

6.17 It will be necessary to allocate new sites for housing to meet our future housing numbers. This is important because when sites are allocated for housing development, they can take time to be completed. All sites need to gain planning permission, and undertake site preparation works, as well as delivering any infrastructure that might be needed before houses can be built. In addition, if too many houses are built on a site in one year, they will not sell. This means that the total number of homes that will be built on a sites of more than 50 to 100 homes do not all take place in one year. The number of homes that are completed each year varies between 50 and 300 homes each year, depending on the site. To meet our housing target options of 1,000 to 1,400 homes each year the Council will therefore need to identify a number of housing sites rather than just one strategic site. This will include a mix of very large strategic scale sites together with smaller scale sites. This types of different housing site are identified in policy 14 below.

Housing Number Options

If you think the number should be different to the above what level of growth do you think we should provide. What evidence do you have for this?
The work to understand the suitability, sustainability, delivery and infrastructure implications is ongoing and your views on these issues are important to us and will feed in to the options that are taken forward for examination.
Which of the housing options above do you think the Council should set as our housing number?
What do you consider to be the challenges to this Council in bringing forward the increase in housing development to meet the Government’s unprecedented change in housing growth?

Strategic Policy 14 - Options for Housing Growth

The Local Plan will make provision for a significant number of homes and associated infrastructure within the period 2019-2036. The options for overall housing growth being tested as part of the preparation of the Local Plan are:

1,000 homes per year, to meet the objectively assessed local housing need;
1,200 homes per year, to meet the local housing need and also meet some of the unmet housing need in neighbouring authorities;
1,400 homes per year, to meet the local housing need and make significant inroads into the unmet housing need in neighbouring authorities.

The figure to be determined will be achieved by:

Homes that are already permitted or agreed for release, including previously allocated strategic sites at Land North of Horsham (2,750) and Land West of Southwater (600), Land at Kilnwood Vale (2,500) and Land South of Billingshurst;
Housing completions (which will be known at the time the Local Plan is submitted);
Allocation of large Strategic Sites that provide 800 homes or more
Smaller Scale allocations to be allocated in this Local Plan or in Neighbourhood Plans and
Windfall units, including 10% provision on land less than 1ha.

Potential Housing Allocations

6.18 To understand what sites may be available for housing development, the Council held a 'call for sites' in 2018, with an update to the Council’s Strategic Housing and Employment Land Availability Assessment (SHELAA) published in January 2019. Some 500 sites were put forward to the Council for consideration for a range of different types of development, although the vast majority (around 450) indicated that the site should be considered for residential development, either in whole or in part. These sites range in scale from those promoting development of five homes up to large scale developments of several thousand homes.

6.19 The SHELAA that was published in early 2019 gave an indication of the sites that were considered to have potential for development when assessed under the policy requirements of the current Horsham District Planning Framework. As this Plan has to be reviewed every five years, it was considered that the proposed development sites needed further consideration but without the existing local policy constraints.

6.20 A set of Site Assessment Criteria were devised to ensure that each proposed development site could be assessed in more detail, on a consistent basis. A key requirement of the Site Assessment criteria was that they took account of the suitability, availability and deliverability of the land. These criteria were shared with site promoters and a further opportunity was provided for site promoters to submit information to the Council to help support the assessment of land against the criteria. The results of the site assessment are set out in more detail in the Horsham District Regulation 18 Site Assessment Report. The key considerations as part of this process are summarised in the following paragraphs.

Site Suitability

6.21 Paragraph 8 of the National Planning Policy Framework (NPPF) sets out the definition of sustainable development in relation to the planning system. It makes clear that development should pursue economic, social and environmental objectives in mutually supportive ways and that opportunities should be taken to secure net gains in each area. Sites were therefore assessed against fourteen criteria derived from these NPPF criteria in order to attain an overall assessment of site suitability.

6.22 The NPPF states that certain assets, including Areas of Outstanding Natural Beauty, Sites of Special Scientific Interest and irreplaceable habitats such as ancient woodland should be protected. Sites located fully within such areas were therefore considered not to be suitable and were excluded from further assessment.

6.23 The NPPF is also clear that planning policies which lead to isolated developments in the countryside should be avoided. The Council is of the view that development on land which does not adjoin existing built-up area boundaries and is not of a sufficient scale to bring forward new services and facilities on site, would lead to isolated rural development which perpetuates unsustainable lifestyle patterns. These sites were also excluded from further assessment. The suitability of sites was assessed using a Red/ Amber/ Green rating as follows:

	Very Positive Impacts
	Favourable Impacts
	Neutral Impact
	Unfavourable Impacts (where there is potential for mitigation)
	Very Negative Impacts (impacts unlikely / unable to be mitigated)
	Impact unknown / no information

Site Availability

6.24 The vast majority of sites that have been proposed to the Council can be considered ‘available’ for development during the plan period. There are however a small number of sites that are held on the Council’s SHELAA database that have not been actively promoted for a number of years and for which the Council has not been able to obtain up to date information. These sites have therefore been considered not to be available over the Plan period and were excluded from further assessment.

Deliverability and Viability

6.25 Where sites were assessed to be available and suitable for development, the deliverability of the development was also considered. It will be necessary to bring forward housing development across the whole Plan period (i.e. to 2036), and sites were not excluded simply because they were not available for development in the short to medium term. Factors such as the complexity of land ownership and the extent of site assembly when determining when land could be brought forward were considered. The assessment process also took into account the scale and type of the site. Previous experience in Horsham District has demonstrated that larger scale strategic sites can take a number of years to allocate, gain planning permission and then build out, whereas smaller scale greenfield sites can often come forward much more quickly as they are less complex to develop. Brownfield land can also be more challenging to deliver if there are existing uses on site that have to be relocated or where past uses have led to issues such as ground contamination, which needs to be remediated.

6.26 The viability of sites is also important – in the current financial climate, on sites where there are not considered to be significant complex issues such as ground pollution or contamination, sites are likely to be financially viable. Further work will however be required to test all sites for their viability, taking account of the level of infrastructure provision that will be needed to support development together with other policy requirements, which will emerge through this Local Plan Review. This element of work will continue as the Local Plan progresses.

Development Quality

6.27 Where sites are judged to be suitable, available, deliverable and viable, the selection of sites for inclusion in the Horsham District Local Plan will also take account the ability of the development to bring forward a scheme that is of high quality. It is recognised that what different schemes can deliver will vary – a site for 10 homes will by its nature have a different ‘offer’ to that of a large scale strategic site. However, the Council has sought to understand the high level vision that is being proposed for each site and to understand the potential for sites to bring forward aspects such as high quality design, the key components that a site will bring forward and the benefits that may be provided to both new and existing residents.

Sustainability Appraisal

6.28 A sustainability appraisal has been undertaken to consider the relative sustainability of sites that were not 'screened out' at an earlier stage of the site assessment process. The appraisal considers how each site performs against 17 sustainability objectives, each of which relates to social, economic or environmental aims. The outcome of this is set out in the Preferred Options (Regulation 18) Sustainability Appraisal.

Shortlisted sites

6.29 Following the completion of the site assessment process, a number of larger scale strategic sites or locations (800 homes or more) have been identified which may have potential for housing development either as urban extensions or as new settlements, together with a number of smaller scale sites (up to around 500 homes) at locations across the District. Further detail on these sites is set out on the following pages, focusing first on the strategic scale sites, followed by smaller scale development.

Potential Housing Allocation Options

What are your views on the site assessment process, and the potential development sites that are identified in this and the supporting documentation?
How do you consider these sites would bring forward development that accords with wider sustainable development principles that balances the need for economic growth with social and environmental requirements as identified in the NPPF?

Land at Adversane, West Chiltington Parish (Kingswood)

SA567_A4_portrait

Site Name: Land at Adversane, West Chiltington Parish (Kingswood)		SHELAA Reference: SA597
Site Area	150 hectares
Site Description	The site is currently greenfield, and comprises primarily pasture and arable land interspersed with hedgerows and some smaller areas of woodland. The landscape is gently undulating, and is open in nature on the west of the proposed site close to the A29.
Summary of Proposal	Land at this site has been proposed as a strategic scale allocation for around 3,500 to 4000 units, of which approximately 2,000 could be delivered in the Plan period to 2036. The site promoters have indicated that they anticipate the delivery of 35% affordable housing. No specific land has been identified for Gypsy and Traveller accommodation at this stage. One new job is proposed per new dwelling with a new high street, library and country club/hotel that would be delivered in phases as the development increases in size. The site would be linked in employment and educationally to Brinsbury College to the south. Proposals for the site indicate that the scheme could provide funding towards school provision including Special Educational needs (SEN), health care provision and a range of community open spaces including parks, playing fields, community gardens and allotments. It is suggested that biodiversity net gain can be achieved through the provision of trees, hedgerows, habitats, watercourses, SUDs and the enhancement of existing assets on the site. The promoter has outlined that carbon impact could be minimised through a range of means from design, domestic Photo Voltaic cells, car clubs and electric car charging points. Although adjacent to a railway line, no new railway station is proposed although land would be safeguarded to allow this to come forward in the future. Enhanced bus services are proposed to Billingshurst and Horsham. Upgrades to the road network around the site are proposed – a new bridge over the railway removing the need to traverse the level crossing enabling its closure (part of the re-routing of the B2133) and a new roundabout junction between the B2133 and A29 (potentially a safer, part of the re-routing of the B2133)
Site Suitability	Red /Amber /Green Rating
Landscape
Biodiversity
Archaeology / Cultural Heritage
Environmental Quality
Flooding / Drainage
Climate / renewables / energy efficiency
Housing
Education
Health
Leisure / recreation and community facilities
Transport
Other Infrastructure
Economic impact
Retail
Site Suitability Summary	Overall, much of the site is free from key environmental constraints. The land is not identified as being at specific risk from flooding, although any development that comes forward will need to ensure that no further risks are generated because of the development either on site or in the surrounding area. Although attractive, the landscape in the area has not been designated as being of importance. Nevertheless, it is recognised that a development of this scale will have significant changes on the settlement pattern and the wider rural character in this area. The potential for the coalescence of development between Billingshurst and Pulborough has been identified as a particular concern. The site is also located on the A29, which is of known importance for Roman archaeology, and there is also potential to impact on the listed buildings / Adversane conservation area. The site promoter has indicated that biodiversity gains could be provided on this site, and that existing key habitats and ancient woodland would be protected. Further work to understand the impact of this site on the Barbastelle bat - a protected species that roosts in the Mens Woodland, a designated Special Area of Conservation (which is of international importance) will however be required. The site promoter has also considered means to minimise impact on climate change with a range of measures proposed. However, further detail as to how this will be delivered would need to be explored. From an economic perspective, the promoters have identified clear links with Brinsbury College and have stated that the development will provide one new job per home, which would help to minimise additional commuting. However, there is a risk that development in this location may have an adverse impact on the vitality and viability of existing villages, including Billingshurst. It is clear that a strategic scale development has the potential to deliver a large proportion of the Council’s housing requirements and at this stage, it has been indicated that the level of affordable housing which can be provided would be around 35%. The ability to provide contributions towards a new school and SEND provision has also been identified, together with a range of other community benefits including healthcare provision. Further work is required to understand in more detail how the educational needs arising from this new development could be met, although it is recognised that this will to some extent depend on feedback from West Sussex County Council (WSCC). The potential of this location to deliver district-wide leisure requirements is not yet known, and further work to understand this wider offer will be required. A positive of this location is the potential in the longer term to explore the provision of a new train station, although at this stage it is by no means certain that this could be delivered. The site is relatively close to two existing stations (Billingshurst and Pulborough) with the potential for a shuttle service identified. It is considered that development in this location would have some traffic impacts upon the A29 and B2133 and within Billingshurst, Pulborough, Adversane, West Chiltington and surrounding area and there is currently a lack of endorsement from Network Rail for the provision of a new bridge over the railway which forms part of the re-routing of the B2133 and may potentially prejudice the vibrancy of the proposed new High Street.
Deliverability	The site promoters own much of the site outright. Where the land is not in direct ownership, the site has the necessary legal agreements in place to deliver this scheme. It is not considered that the total number of homes proposed could be delivered in the Plan period - at the current time it is considered that a more realistic level of delivery is around 2,000 homes. At this stage, the promoter has stated that essential infrastructure would be delivered early or at a pace with the housing development. There is a risk that as this site is in close proximity to Billingshurst, which is currently experiencing expansion and where additional land is being proposed for further development. There is therefore a need to understand in more detail any potential for this to affect market absorption and delivery of housing in this area.
Viability	At this stage, it is considered that there is potential for the development on this site to be viable. The site promoters are established developers with a track record of delivery. However, this development will as a new settlement need to provide new infrastructure and the cost of this together with other mitigation measures will need to be carefully tested to ensure the scheme can be delivered effectively.
Development Quality	The promoters have a clear vision to provide a high quality new settlement, which has a clear sense of place. Proposals include the delivery of housing and of supporting infrastructure, which keeps pace with the housing growth. Work on the detailed design has not yet been finalised, but the promoter has indicated that it would draw on local materials and make use of design codes.

Land East of Billingshurst (Little Daux)

SA118_A4_portrait_2

Site Name: Land East of Billingshurst (Little Daux)		SHELAA Reference: SA118
Site Area	Up to 90 hectares
Site Description	The site comprises agricultural fields bounded by hedgerow and trees, which contains a number of paths used by residents of Billingshurst for informal recreation. To the west of the site lies the village of Billingshurst although this is largely screened by a tree belt. It also wraps around Rosier Business Park, which lies adjacent, and the railway line. The site is bounded to the west by the A272, and to the north land is currently being brought forward for a development of around 475 homes
Summary of Proposal	Land at this site has been proposed for up to 1,200 units as an urban extension of Billingshurst. The site promoters have indicated that the site could come forward in two phases-up to 800 north of the railway line and a further 400 to the south. The site promoters have indicated that they anticipate the delivery of 35% affordable housing. No specific land has been identified for Gypsy and Traveller accommodation at this stage. Proposals for the site indicate that the development could contribute towards the provision of the primary school, which has been identified on land to the north and land made available for a pub or restaurant. There is some small-scale potential for some additional employment near the existing Rosier business park. Access to the site would be obtained from the A272 and the promoters have indicated that they would enhance pedestrian and cycle connectivity with the existing village centre.
Site Suitability	Red /Amber /Green Rating
Landscape
Biodiversity
Archaeology / Cultural Heritage
Environmental Quality
Flooding / Drainage
Climate / renewables / energy efficiency
Housing
Education
Health
Leisure / recreation and community facilities
Transport
Other Infrastructure
Economic impact
Retail
Site Suitability Summary	Overall, much of the site is free from key environmental constraints. The land is not identified as being at specific risk from flooding, although any development that comes forward will need to ensure that no further risks are generated as a result of the development either on or offsite. Although attractive, the landscape in the area has not been designated as being of landscape importance. Nevertheless, it is recognised that a development of this scale would have significant changes on the settlement pattern and the wider rural character in this area. The character of the area is, however, changing because of the ongoing housing development to the north. The site is close to some listed buildings and the design of any development would need to take account of the setting of these buildings to minimise any potential harm to their setting. The site promoter has not committed to providing biodiversity net gain, although they have indicated that existing key habitats and ancient woodland, including the Local Wildlife Site at Wilden’s Meadow would continue to be protected. Further work to understand the impact of this site on the Barbastelle bat will be required. This is a protected species and roosts in the nearby Mens Woodland, which is designated as a Special Area of Conservation and is of international importance. The site promoter has not specifically focused on measures to minimise impact on climate heating beyond existing technologies and keeping pace with changes to building control. From an economic perspective, the promoters have identified some limited potential to provide additional commercial land. The site is close to existing employment sites in and around Billingshurst, which would provide opportunities to live and work locally. It is clear that a strategic scale development has the potential to deliver a large proportion of the Council’s housing requirements and at this stage, it has been indicated that the level of affordable housing which can be provided would be around 35%. No provision to meet Gypsy and Traveller requirements have been identified. The ability to provide further contributions towards a new primary school has been identified, but this school has not yet commenced and there is no on-site SEND provision. It is known that the Weald Secondary school is reaching capacity and there is therefore a need to understand in more detail how the needs arising from this new development could be met, although it is recognised that this will to some extent depend on feedback from WSSC. The proposals are not sufficient in scale to contribute towards an additional GP surgery. The promoters indicate the existing health facilities but further understanding of the capacity of existing facilities and if any contribution is necessary will need to be obtained before securing any housing development on the site. The development of this location could potentially lead to the loss of informal recreation land, although it is recognised open space provision would be incorporated into the proposals. The potential of this location to deliver District-wide leisure requirements is not yet known and further work to understand this wider offer would be required. The site is close to the existing services and facilities in Billingshurst, including the railway station. The site promoters have identified that pedestrian and cycle access will be provided. However, the site would still generate traffic impacts, particularly on the A272 and the proximity to the railway bridge and issues of road safety have been identified as concerns. The portion of the site south of the railway line is somewhat isolated from the land to the north and from the existing settlement: this may limit community cohesion in this section of the development. Development in this location has the potential to increase demand for retail in Billingshurst but this is balanced against the lack of any proposals by the site promoter to bring forward any benefits or upgrades that would also benefit the existing community.
Deliverability	The site has the necessary legal agreements in place to deliver this scheme during the plan period and complete 1,200 homes by 2036. As this site is in close proximity to Billingshurst, which is currently experiencing expansion and is another location proposed for further development, there is a need to understand in more detail how this development could affect market absorption and delivery of housing in this area.
Viability	At this stage, it is considered that there is potential for the development on this site to be viable. The site promoters are established developers with an extensive track record of delivery. However, the proposals are focused on the delivery of new housing with limited provision of community facilities.
Development Quality	The promoters have a vision for the proposed housing development, which includes good walkable links to the village centre, and rail station. However, the proposals are focused heavily on the delivery of housing rather than a wider consideration of how they contribute to wider place making and the benefit for the existing community as well as any new residents. As an extension of Amblehurst Green to the north, there is a risk this proposal could result in limited diversity in design.

Land West of Billingshurst (Newbridge Park)

SA744_A4_portrait_2

Site Name: Land West of Billingshurst (Newbridge Park)		SHELAA Reference: SA744, SA642 (includes SA225), SA668
Site Area	75 -100 hectares
Site Description	The site primarily comprises arable and pasture fields bounded by hedgerows and mature trees. Some isolated mature trees are present within some of the fields. The north eastern parcel is relatively flat. The land north of the A29 undulates with a tree-lined valley running east to west through the middle. The land slopes down from the north east to the south and west with a medium slope. The site is separated from the rest of Billingshurst to the east by the A29, which adjoins the site. To the south, west and the north the site is countryside and is very rural in character.
Summary of Proposal	A number of parcels of land have been promoted for development to the west of Billingshurst. To the north, land is promoted for around 850 to 1000 dwellings. Land to the south has been identified for around 500 -750 homes. The site promoter to the north has indicated that the development could provide 35% affordable housing and specific elderly care provision. Potential to deliver accommodation for Gypsies and Travellers has also been identified by this promoter. Promoters of this site have all indicated that land would be provided for a new primary school and other forms of community provision, including health care. Both site promoters indicate that open space and a country park would be provided. Landscape-led design and garden suburb principles would be incorporated into the development. The promoters of the northern segment also indicate that they could achieve biodiversity net gain and outline measures such as hedgerow planting and woodland and wetland provision. Access to the site would be obtained from the A272 and the promoters have indicated that they would enhance pedestrian and cycle connectivity with the existing village centre. Land at Platts Roundabout has recently gained development consent (subject to legal agreements) for a petrol filling station and some additional commercial units – these would provide employment opportunities and retail provision for new residents. The northern site promoter has stated a small amount of retail that would not conflict with the existing provision in Billingshurst could be provided. The promoter of the northern site has indicated that electric vehicle charging points would be provided and building regulations and design would contribute to reduced carbon emissions.
Site Suitability	Red /Amber /Green Rating
Landscape
Biodiversity
Archaeology / Cultural Heritage
Environmental Quality
Flooding / Drainage
Climate / renewables / energy efficiency
Housing
Education
Health
Leisure / recreation and community facilities
Transport
Other Infrastructure
Economic impact
Retail
Site Suitability Summary	Overall, much of the site is free from specific environmental constraints. Although the site adjoins the river Arun, this area is not identified for development. Further work is however necessary to ensure no further risks are generated as a result of any development either on or offsite. Although not designated as being of landscape importance, the landscape in this area is attractive and undulating. Although geographically close to Billingshurst, its separation from the village by the A272 limits its relationship with the existing built form, and this relative isolation contributes to the very strong rural character in this area. As with any development at this scale, there would be significant changes on the settlement pattern and the wider rural character in this area but it is considered that the impact would be particularly high given the existing character and quality of the landscape. Were the northern section of this land to be allocated, the scheme - which is being promoted as separate land parcels - would lead to a disjointed settlement pattern. The site is close to some listed buildings and the design of any development would need to consider this to minimise any potential harm to their setting. The site promoter of the northern half of the land west of Billingshurst has committed to providing biodiversity net gain, but this is not the case for all promoters of land in this area. It is noted that the river Arun is a Site of Special Scientific Interest (SSSI), and further information is required to understand how damage to the quality of this habitat would be prevented because of the increased level and proximity of any development. The proposed site is also located in known flight paths of the Barbastelle bat, a protected species that roosts at the nearby Mens Woodland. This is designated as a Special Area of Conservation and is of international importance. Further work to understand the impact of this site on this protected species is required. Whilst the site promoter of the northern half of land west of Billingshurst has recognised that there is a need to minimise climate impacts, it does not focus on measures to do this and there is no commitment to new energy generation technologies, other than the provision of opportunities for electric vehicle charging. From an economic perspective, there is already development consent for the provision of additional commercial land, and the site is close to existing employment sites in and around Billingshurst, which would provide opportunities to live and work locally. It is clear that a strategic scale development has the potential to deliver a large proportion of the Council’s housing requirements. At this stage, it has been indicated that the level of affordable housing, which can be provided, would be around 35%, together with some specific elderly accommodation. The potential to meet Gypsy and Traveller requirements has also been identified. The ability to provide land for a new primary school has been identified – but additional land may be required for SEND provision. It is known that the Weald Secondary school is reaching capacity and there is therefore a need to understand in more detail how the needs arising from this new development could be met, although it is recognised that this will to some extent depend on feedback from WSCC. The site promoter of the northern half of land west of Billingshurst indicates that some land could be provided for additional health care if required. Further understanding of the capacity of existing facilities and if any contribution is necessary will therefore need to be obtained before securing any housing development on the site. It is noted that all site promoters state that a country park would be provided. However, as the sites are being promoted separately there are no links between the two, and the total size and need for such a space is not understood and appears very disjointed, rather than any form of comprehensive provision. In geographic terms, the land is relatively close to the existing services and facilities in Billingshurst, including the railway station. The site promoters have identified that pedestrian and cycle access will be provided. However, the land is separated from the existing built form of Billingshurst by the A29, and this does present a significant physical barrier in terms of accessing wider community facilities and the formation of a single larger community. Whilst it is recognised that new linkages can be provided, these will add infrastructure costs and will need very careful design to ensure that the necessary community cohesion can be provided. The site will still generate traffic impacts on the wider road network, particularly when combined with other nearby development. Further work to understand the impacts of this and what upgrades may be necessary is required. Development in this location has the potential to increase demand for retail in Billingshurst and the potential to provide more retail on some of the site is identified. However, there is no consideration as to whether there are any opportunities to bring forward any benefits or upgrades in the existing village centre, which would also benefit the existing community.
Deliverability	At the current time three separate land parcels are being promoted in this area – the site is not being proposed as a unified scheme. Due to the lack of a unified scheme, the allocation of the site in its entirety could lead to delayed or slow delivery if disputes arise between the site promoters: for example, in terms of identifying where and how infrastructure is provided. If a smaller land parcel were allocated, whilst this would be easier to deliver, the level of community facilities that would be delivered would be less comprehensive. As this site is in close proximity to Billingshurst, which is currently experiencing expansion and subject to other separate proposals for large scale strategic development, there is a need to understand in more detail any potential for this to affect market absorption and delivery of housing in this area.
Viability	At this stage, it is considered that there is potential for the development on this site to be viable. However, further work is needed to understand the precise level of housing that could support the level of affordable housing and the extent of community facilities that can be provided.
Development Quality	The promoters have a vision for the proposed housing development, which is, on the northern parcel, landscape-led and seeks to provide links to the existing settlement of Billingshurst. However the proposals are not well related to the existing settlement and will affect existing rural quality. Limited information is available as to the vision for any design principles or materials. Furthermore, the promotion of three separate schemes in this area has the potential to bring forward a disjointed scheme, which does not provide a successful new extension to Billingshurst with a clear sense of place.

Land at Buck Barn, West Grinstead (Weald Cross)

SA716_A4_portrait

Site Name: Land at Buck Barn, West Grinstead (Weald Cross)		SHELAA Reference: SA716
Site Area	180 hectares
Site Description	The site primarily comprises arable and pasture fields bounded by hedgerows and mature trees. Some isolated mature trees are present within some of the fields. The northern section of the site slopes down towards a mature belt of trees, which bisects the site. The southern boundary of the site adjoins the A272 east of the Buck Barn crossroads junction with the A24. The western edge of the site adjoins the A24 at the southernmost extent of the site. The remainder of the western boundary of the site is formed by roads that are more rural. The Downs Link (a strategic recreation route between Guildford and Shoreham-by-Sea) adjoins the site to the east. Although adjacent to the busy road network, the area is predominantly rural in character although there are some urban influences including power lines that run east to west through the site.
Summary of Proposal	The site is proposed for a development of around 3,500 homes. The site promoter has indicated that the development could provide 35% affordable housing and specific elderly care provision. Potential to deliver accommodation for 15 Gypsies and Traveller pitches has also been identified by this promoter. Promoters of this site have all indicated that land could be provided for a new primary and secondary school and the developers could build out the education facilities if required. The site promoters would provide healthcare facilities and are a member of “Healthy New Towns Network,” an organisation committed to prioritising health and wellbeing. The site would also provide new community facilities, a retail centre and a family pub-restaurant. Both site promoters indicate that open space and sports pitches, including a cricket oval, would be provided, as well as enhancements to the Downs Link. The site contains a Local Wildlife Site and ancient woodland. The site promoters have stated that they could provide biodiversity net gains, and that woodland and hedgerows would be retained wherever possible. Further enhancements would be provided with upgrades to the watercourse to provide water meadows. Access to the site would be obtained from the A272 and the promoters have indicated that they would provide enhancements to the A24; including a potential flyover at the Buck Barn crossroads and a Park and Ride scheme with bus connections to Southwater, Christ’s Hospital railway station and Horsham. The promoter has indicated that Employment floorspace (B1, B2, B8 use class) could be provided but details in relation to this aspect of the scheme are limited. The promoter of the site has indicated that Electric Vehicle charging points would be provided and that all buildings would be built to a high standard following fabric-first approach, battery storage system / energy centre, and will aspire to zero-carbon and energy positive technology. No details are provided on renewable forms of energy on site.
Site Suitability	Red /Amber /Green Rating
Landscape
Biodiversity
Archaeology / Cultural Heritage
Environmental Quality
Flooding / Drainage
Climate / renewables / energy efficiency
Housing
Education
Health
Leisure / recreation and community facilities
Transport
Other Infrastructure
Economic impact
Retail
Site Suitability Summary	Overall, much of the site is free from key environmental constraints, although it is noted that some of the land is designated as ancient woodland. The land contains some watercourses, although no land at risk from flooding is proposed for development. Should development take place in this location, it will be necessary to ensure that no further risks are generated because of the development either on or offsite. Although attractive, the landscape in the area has not been designated as being of landscape importance. Nevertheless, it is recognised that a development of this scale will have significant changes on the settlement pattern and the wider rural character in this area. The landscape contains some sensitive areas, particularly to the north. The site is close to some listed buildings and the design of any development would need to take account of the setting of these buildings to minimise any potential harm to their setting. The proposals do not intend to remove the power lines across the site that would have a landscape impact, and if the site were allocated, would lead to implications for the layout of any scheme. The site promoter has committed to providing biodiversity net gain, but further information is required to understand how this will be achieved. The site is relatively close to Cowfold, with direct road access to this settlement from the proposed site via the A272. The centre of Cowfold has been designated as an Air Quality Management Area due to poor air quality that has predominantly arisen because of high traffic volumes in this area. There is potential for additional traffic generated by this proposal to have an adverse impact on the air quality of this area, which will need to be understood and mitigated. Measures such as electric vehicle charging have been proposed as potential mitigation in this respect. The site promoter has recognised the need to minimise climate impacts but although they are proposing to minimise energy use of the buildings and the provision of electric car charging points and provision for new vehicles provision of renewable energy technologies on site is not proposed. Although the site will provide additional retail and economic development, the details on how this would be provided are still emerging and at this stage, it is not clear whether one job per new home would be provided. It is clear that a strategic scale development has the potential to deliver a large proportion of the Council’s housing requirements and at this stage, it has been indicated that the level of affordable housing which can be provided would be around 35%, together with some specific elderly accommodation. The potential to meet Gypsy and Traveller requirements has also been identified. The ability to provide land for a new primary and secondary schools has been identified and at this stage, there appears to be potential for the developer to build them if required. Further detail on the provision of new schools will be needed but to some extent, this will depend on feedback from WSCC. The site promoter has indicated that some land could be provided for additional health care if required, together with community facilities and open space. Further understanding of the capacity of existing facilities and if any contribution is necessary will therefore need to be obtained before securing any housing development on the site. An additional health benefit on this site is the proposal to ensure that healthy lifestyles are incorporated into development from the outset. The site is relatively remote from existing settlements (8km from Horsham), and there is no railway station nearby. It is however recognised that upgrades to the existing road network would be required and that there may be potential to provide cycling opportunities due to the proximity of the Downs Link, together with upgrades to bus services and a Park and Ride. The precise nature of their delivery and the details as to how a Park and Ride would work and be effective in reducing car use has not been fully demonstrated. The site will still generate traffic impacts on the wider road network, particularly in combination with other development and this will require further study in terms of the level of mitigation that may be required particularly along the A24 and A272 corridors. Development in this location will generate additional retail demands – it is noted that some of this will be met on site but further understanding of the impact that this may have on other settlements in the surrounding area will be necessary.
Deliverability	The site is being promoted by a single developer and there are two current landowners with the land under option. This is considered to minimise the risk of delivery in this location. It is not considered that the 3,500 homes proposed could be delivered in the Plan period - at the current time it is considered that a more realistic level of delivery is around 2,000 to 2,500 homes. At this stage, the promoter has stated that essential infrastructure would be delivered early. The site is however in relatively close proximity to Southwater which is subject to existing and ‘promoted’ expansion – thus cumulative impact may affect market absorption and delivery of housing in this area
Viability	At this stage, it is considered that there is potential for the development on this site to be viable. However, further work is needed to understand the precise level of housing that could support the level of affordable housing and community facilities that are provided.
Development Quality	A clear vision for the site has been identified, based on Garden Community Design Principles and in accordance with the Healthy New Towns Network principles. Having a single developer could limit the diversity in design resulting in a less ‘organically’ evolved settlement

Land West of Crawley, Rusper

SA101_A4_portrait

Site Name: Land West of Crawley, Rusper		SHELAA Reference: SA101 – Land West of Ifield & SA291 – Land West of Kilnwood Vale
Site Area	Land West of Ifield – 170ha Land West of Kilnwood Vale - 20ha
Site Description	The site primarily comprises arable and pasture fields bounded by hedgerows and mature trees together with a golf course. Some isolated mature trees are present within some of the fields. The wider area of study is located north of the A264 from Faygate in the west and extends in an arc north west towards Crawley, Gatwick Airport and the A23. To the east, the site adjoins the neighbourhood of Ifield, in Crawley and Gatwick Airport is to the north, both of which are key urban influences in this area. Although adjacent to the busy road network, and close to the urban influences, the area is predominantly rural in character including areas of Ancient Woodland.
Summary of Proposal	An area of search has been identified which sweeps in a broad arc around the western edge of Crawley from Faygate in the south west around to Crawley and Gatwick in the north east. Homes England, who are promoting much of this land, consider that there is potential for up to 10,000 homes which could be delivered as three new neighbourhoods of Crawley. The first of these is being promoted on the Land to the West of Ifield. All the land being proposed for development is located within Horsham District, but a small portion of the wider site lies within Crawley Borough (Ifield Brook Meadows Local Wildlife Site and Local Green Space). Further land within the area of study is being promoted for housing development to the west of Kilnwood Vale, where the development of a new neighbourhood is currently ongoing. In isolation, this parcel of land is being promoted for around 800 homes. (This would form part of any wider proposal for 10,000 homes were the site to be allocated for this scale of development). It has been indicated by the promoters of the wider site that the 10,000 homes would provide a minimum of 35% affordable housing. Potential to deliver accommodation for 15 Gypsies and Traveller pitches has also been identified by this promoter with a specific land area identified to the Council through a recent call for Gypsy and Traveller sites. All promoters of the land have indicated that land would be provided for education, including early years, new primary and secondary schools together with SEND provision. The site promoters would provide healthcare facilities which, if a scheme of 10,000 homes were to come forward, could be delivered comprehensively. The site would also provide new community facilities and a retail centre for each new neighbourhood together with a family pub / restaurant. Both site promoters indicate that open space and sports pitches would be provided –a target of 50% of the land being open space has been identified. The site contains a number of Local Wildlife Sites, a Site of Special Scientific Interest (SSSI) and ancient woodland that would require continued protection. The site promoters have committed to 10% biodiversity net gains and have indicated that they will protect Ifield Brook Meadows and provide a wider flood alleviation scheme. Homes England have indicated that the delivery of 10,000 homes to the West of Crawley would attract government backing to deliver a link road around the western edge of Crawley from the A264 to the A23 south of Gatwick airport. Other proposals in this area also include extensions of the Crawley Fastway bus service. The promoter has indicated that new employment floorspace (B1, B2, B8 use class) could be provided and Homes England have indicated that 10,000 new jobs would be created – one job per new home. The promoter of the northern site has indicated that electric vehicle charging points would be provided and have made a commitment to energy efficiency and sourcing energy from non-renewable sources including schemes such as district heating, solar power and ground source heat pumps.
Site Suitability	Red /Amber /Green Rating
Landscape
Biodiversity
Archaeology / Cultural Heritage
Environmental Quality
Flooding / Drainage
Climate / renewables / energy efficiency
Housing
Education
Health
Leisure / recreation and community facilities
Transport
Other Infrastructure
Economic impact
Retail
Site Suitability Summary	Development of the land to the west of Crawley presents a number of environmental challenges. The land contains some watercourses, and although no land at risk from flooding is proposed for development, some wider flood alleviation measures are required in this area. Should development take place in this location, it will be necessary to ensure that no further flood risks are generated because of the development on or offsite. An additional challenge will be the need to ensure that wastewater treatment capacity is available to prevent impacts on water quality. A new wastewater treatment works may therefore be required, particularly if a development of 10,000 comes forward. The landscape west of Crawley, whilst visually attractive, has not been designated as being of national landscape importance, although the Land West of Kilnwood Vale and the southern edge of the area of study adjoins the High Weald Area of Outstanding Natural Beauty. The potential impact on this landscape area will need to be considered taking account of the local value of the area for local residents. In addition, there are a number of areas of historical importance on the western edge of Crawley – including Ifield Village Conservation Area and a number of listed buildings including a Grade I Listed church. It is recognised 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. Any development would need to be informed by a detailed understanding of the landscape character, setting and heritage appraisal. The setting of Ifield Village Conservation Area would need to be respected. Should land be allocated in this location, there will need to be serious consideration to the potential for a Greenbelt designation in this area to minimise the risk of further coalescence between Horsham and Crawley and maintain both Horsham and Crawley’s character both of which have a countryside setting. Links from the western side of Crawley into the open countryside would need to be maintained. The site promoter has committed to providing biodiversity net gain but further information is required to understand how this will be achieved, particularly as there are a number of parcels of land in this area that are already designated for their wildlife importance. The proximity of some of the land to Gatwick Airport may also limit the type of enhancements that can be achieved to avoid any increased risk from bird strike at the airport. The location of the site so close to Gatwick Airport also presents challenges in terms of ensuring that any future residents are not adversely impacted by noise or poor air quality – further work to understand the impact this may have is still required. The site promoters have recognised the need to minimise climate impacts, and has identified ways to reduce reliance on carbon as an energy source and ensure energy efficiency. In common with other site promoters, further understanding of how this would be delivered is still required. Development of the wider 10,000 home scheme would in particular need to be designed to exemplar sustainability standards. There are opportunities to take advantage of a masterplanned approach and economies of scale, designing in tight energy and water efficiency targets from the outset in order to futureproof for a zero carbon future and changing climate. The need to ensure continued economic growth has been identified by the site promoters and a positive element of these proposals is a commitment to providing one new job per home. The level, type and location of employment land to be provided within a development in this area will need to be informed by the outcomes of the Northern West Sussex joint evidence and ongoing work with Gatwick Airport. It is clear that a strategic scale development, particularly for 10,000 homes, has the potential to deliver a very significant proportion of the Council’s housing requirements. There is also potential to deliver a portion of those that have been identified as part of Duty to Co-operate discussions, particularly in the North West Sussex housing market area, and those that may also be derived because of any forthcoming expansion at Gatwick Airport. At this stage, it has been indicated that the level of affordable housing, which can be provided, would be around 35% together with some specific elderly accommodation. The potential to meet Gypsy and Traveller requirements has been identified. The opportunity to provide land for new primary and secondary schools and SEND provision has been identified. The promotion of this scheme by Homes England is likely to assist in terms of being able to attract Government backing to ensure such provision can be made when they are needed. Further detail to confirm this will be required but the provision of new schools will to some extent depend on feedback from WSCC. It should be noted Crawley has an existing known need for additional secondary school provision, in addition to any requirements arising from the development itself. The site promoter has indicated that some land could be provided for additional health care if required, together with community facilities and open space. Again, the promotion of this scheme by Homes England is likely to assist in terms of being able to attract Government backing to ensure they can be provided in a timely manner, although more certainty from the NHS is also required. Further work to understand how the design and layout of any proposals can contribute to healthy lifestyles is required to ensure that these are incorporated into new development from the outset. The site is located at the heart of the Gatwick Diamond, close to both Crawley and Horsham. Rail access in these areas is generally good as is the high quality bus network in Crawley. There is potential for the Fastway bus service to be extended. However, it is recognised that congestion on the roads in and around Crawley is a particular issue. A key benefit of this scheme is the potential to attract Government backing to bring forward a link road from the A264 to the A23 north of County Oak within Crawley and for this to be delivered in its entirety before the completion of any properties. It is however noted that the route and design of any such road will be critical to take account of the nature conservation sites and volume of traffic passing through the new communities, including bus priority measures, and should be designed to enable the prioritisation of cycling and walking and connectivity by public transport. Development in this location will generate additional retail demands – it is noted that some of this will be met on site, but the impact that this may have on Crawley town centre and Horsham will also be an important consideration.
Deliverability	The land for 10,000 homes is being promoted by Homes England, but at this stage it is not possible to demonstrate at the level required at a Local Plan Examination that the land has been assembled and that the site could therefore be delivered. However, both the land west of Ifield and the Land West of Kilnwood Vale are subject to options which could ensure that these parcels of land could be delivered during the plan period. There is significant potential for this scheme to deliver much-needed infrastructure. This would need to be delivered as part of an agreed masterplanned framework that could deliver up to 10,000 homes. The nature of the proposal which is being promoted by Homes England could help to secure Government funds to bring this forward. Without such government support, the delivery of such a site together with the necessary infrastructure could be very challenging. 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 proposal 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. The delivery of 10,000 homes would extend beyond the plan period, although the extension to Kilnwood Vale and the proposals west of Ifield have the potential to be built out over the plan period. The land west of Crawley is close to existing areas of new housing development, both at Kilnwood Vale and Land North of Horsham. Such a significant scale of growth in this location has the potential to affect market absorption and delivery of housing in this area. The site adjoins the administrative boundary of Crawley and any development in this area would have a significant impact on this settlement. Horsham District Council has a record of joint working with Crawley, for example the Joint Area Action Plan, to bring forward Kilnwood Vale. It would be expected that joint working to bring forward an expansion of Crawley would also take place should this site come forward. From previous experience, it is known that to be effective joint working does take time, and again this could have an impact on the commencement of development in this location.
Viability	At this stage, it is considered that there is potential for the development on this site to be viable. However, further work is needed to understand the precise level of housing that could support the level of affordable housing and community facilities that are provided. There is potential for Government backing of infrastructure provision in this area that may assist with the viability and delivery of necessary infrastructure.
Development Quality	A clear vision for the site has been identified, based on Garden Community Design Principles. Homes England have also identified the need to ensure the longer-term stewardship and management of any new community, which may come forward in this location. Further detail is required to understand how new development will be designed to ensure exemplar new neighbourhoods.

Land at Kingsfold, Warnham (North West Horsham)

SA459_A4_portrait_2

Site Name: Land at Kingsfold, Warnham (North West Horsham)		SHELAA Reference: SA459
Site Area	177ha
Site Description	The landscape is predominantly agricultural and rural in character. The site is dominated by the Sutton and Mole Valley railway line, which divides the site into eastern and western parcels. There are tree belts and wooded areas (including designated Areas of Ancient Woodland) that divide the western and eastern parcels of land into smaller fields. Boldings Brook is in the eastern part of the site, surrounded by mature vegetation. The western parcel inclines from the lower land level of the railway line upwards to the A24 Dorking Road in the west. To the east of the railway line, the land is relatively flat until it meets Boldings Brook, where it inclines eastwards to meet Langhurstwood Road and Friday Street. The land in the south eastern part of the site is relatively flat and well screened by existing trees and hedgerows.
Summary of Proposal	The site is proposed for a development of 1,000 dwellings across five new villages, centred on the existing settlement of Kingsfold and along the A24. Development is proposed both east and west of the railway line. It has been indicated that the site could deliver 35% affordable housing together with sheltered accommodation or care home to meet the needs of the elderly population. Land is available for Gypsy and Traveller accommodation. Promoters of this site have all indicated that land could be provided for early years (up to 5 years of age), a new primary school together with early years and SEND. No secondary school has been identified. The precise educational requirements would require further feedback from WSCC. The promoter has stated a contribution could be made towards health care including land for a new facility if required. It is proposed that open space and sports pitches would be provided together with local shops and village facilities. The site contains a number of areas of ancient woodland that would require continued protection. The site promoters have committed to biodiversity net gains. It is noted that the road upgrades to the A24 would lead to the loss of some ancient woodland. It is proposed that the scheme would deliver an A24 relief road around the settlement of Kingsfold together with other traffic calming measures. Potential for a new parkway station (including relocation of Warnham Station) has been identified. The promoter has indicated that a significant new area of business floorspace would be provided with this development providing 75,000m² business community (B1, B2 & B8 uses) and at least one new job per home. The promoter of the northern site has indicated that electric vehicle charging points would be provided and has made a commitment to energy efficiency and sourcing energy from non-renewable sources, including schemes such as district heating, solar power and ground source heat pumps.
Site Suitability	Red /Amber /Green Rating
Landscape
Biodiversity
Archaeology / Cultural Heritage
Environmental Quality
Flooding / Drainage
Climate / renewables / energy efficiency
Housing
Education
Health
Leisure / recreation and community facilities
Transport
Other Infrastructure
Economic impact
Retail
Site Suitability Summary	Overall, much of the site is free from key environmental constraints. The land contains some watercourses, although no land at risk from flooding is proposed for development. Should development take place in this location, it will be necessary to ensure that no further risks are generated as a result of the development either on or offsite. The landscape in the area has not been designated for its importance, but it has a strong rural character, and due to its undulating nature is highly visible from a number of vantage points. A development of this scale would have very significant changes on the settlement pattern creating a linear urban form along the A24, and altering the very rural character of this area. The site is close to some listed buildings and a number of these are highly visible in the landscape and would be adversely impacted by development in this location. The site promoter has committed to providing biodiversity net gain but further information is required to understand how this would be achieved, particularly as the proposals would result in the loss of an area of ancient woodland (an irreplaceable habitat) to bring forward the new road upgrade. The site promoter has recognised there is a need to minimise climate impacts, and has identified the potential for land within the site area to be used for solar panels. It is noted electric vehicle charging points would be provided as part of the development. It is clear that a strategic scale development has the potential to deliver a large proportion of the Council’s housing requirements and at this stage, it has been indicated that the level of affordable housing which can be provided would be around 35% together with some specific elderly accommodation. The potential to meet Gypsy and Traveller requirements has also been identified. The development of this site would not form a single new settlement, but would be a series of interlinked hamlets. None of these individually or cumulatively would be of a sufficient size to be self-contained and offer the full range of services and facilities required to meet the day-to-day needs of its residents. Residents would, therefore, be reliant on the services and facilities in nearby Horsham and North Horsham (and to a lesser extent, Warnham). Furthermore, the positioning of the Sutton and Mole Valley Railway line severs the proposed site into separate eastern and western parcels. Improved pedestrian and cycle connections can be demonstrated to improve connectivity between the two parcels, however, no vehicular access is proposed across the railway line and access to some key facilities such as the local school may be difficult and unlikely to generate community cohesion. The Transport Strategy submitted with the proposals suggests that the site provides a number of sustainable transport options but there is concern that these options are limited. The upgrade to the A24 would provide road enhancements in this area but the development would in itself generate additional vehicle journeys to Horsham or Surrey to the north, as the proposal would not provide a comprehensive range of services and facilities. The site promoters have suggested the provision of a new parkway station would improve connectivity, although there is no evidence that Network Rail or the train operating companies have endorsed this as a feasible option and further certainty would be required in relation this upgrade. Pedestrian and cycle access from the site to the main town of Horsham is considered to be poor, with the main route via the A24 which is inappropriate for pedestrians and cyclists. Other surrounding routes, such as Langhurst Wood Road / Friday Street are also not considered suitable as they are rural roads with no footways. Although the site promoters also suggest that the public right of way (No 1421) provides connectivity to the North Horsham strategic allocation, this is over 2km away and therefore not considered to be within an easy or reasonable walking distance. The proposals would result in a significant amount of employment space, forming an extension to the existing Broadlands Business Campus, brought forward by an experienced commercial developer and, from an economic perspective, it is acknowledged that the site could have potential for additional employment development given its proximity to the existing employment space at Broadlands.
Deliverability	The land is in the ownership of relatively few landowners and is being promoted by a single site promoter. The upgrades to the A24 which would support this scheme would impact the deliverability of this scheme in terms of when development could commence. It is however anticipated that 1,000 homes and the business park have the potential to be delivered in the plan period.
Viability	At this stage, it is considered that there is potential for the development on this site to be viable. However, further work is needed to understand the precise level of housing that could support the level of affordable housing and community facilities which are provided. The funding and delivery of the relief road for a scheme of this size is untested and would require further detailed investigation.
Development Quality	A key concern with these proposals is the provision of homes in a series of separate villages. The linear form of this development with the lack of a road link across the railway line is unlikely to result in a cohesive new community. There will still be reliance on Horsham to the south for services and facilities and this could generate additional infrastructure pressures in the town.

Land North East of Henfield (Mayfield)

SA414_A4_portrait

Site Name: Land North East of Henfield (Mayfield)		SHELAA Reference: SA414
Site Area	310ha
Site Description	The landscape in this area is rural with much of the land in agricultural use, interspersed with hedgerows and tree belts. There are some existing rural businesses within the site, and a formal garden (Sussex Prairie Garden) which is a local tourist attraction from late spring to mid-autumn. There is some localised urban intrusion from pylons which cross the site. The site is relatively flat, with some gentle undulations. The character of the site is relatively enclosed in the north and more open in the south, from where there are clear views to the South Downs National Park. The landscape beyond the site is also countryside, although the village of Henfield is close to the south western boundary of the site.
Summary of Proposal	The site is proposed for around 7,000 dwellings, although this would not be completed within the Plan period. It has been indicated that the site could deliver 35% affordable housing together with sheltered accommodation or care home to meet the needs of the elderly population. Land is available for Gypsy and Traveller accommodation. The promoter of this site has indicated that land would be provided for early years, new primary and secondary schools, early years and SEND provision. The potential to link to Plumpton College has also been highlighted as a possibility. The promoter has stated a new healthcare facility would be provided together with a range of other community facilities including a main town centre and two neighbourhood centres, a hotel, sports hub, open space, leisure and community facilities. The site contains two areas of ancient woodland that would require continued protection. The site promoters have committed to at least 10% biodiversity net gains. The promoters state that the scheme would deliver a link road to the A23 and the site promoter indicates that a public transport corridor, active travel corridors and a transport hub would also be provided as part of the development. The promoter has indicated that around 7,000 new jobs (1 job per new home) would be provided through the provision of new employment spaces (primarily B1 and B8 uses) and through the community and retail uses on the site. It is stated that carbon impact will be minimised through design of the development and through on-site low carbon and sustainable energy generation (including Electric Vehicle charging points, car club, domestic Photo Voltaic cells).
Site Suitability	Red /Amber /Green Rating
Landscape
Biodiversity
Archaeology / Cultural Heritage
Environmental Quality
Flooding / Drainage
Climate / renewables / energy efficiency
Housing
Education
Health
Leisure / recreation and community facilities
Transport
Other Infrastructure
Economic impact
Retail
Site Suitability Summary	Overall, much of the site is free from key environmental constraints. The land contains some watercourses, although no land directly at risk from flooding is proposed for development. Should development take place in this location, it will be necessary to ensure that no further risks are generated as a result of the development, not only onsite but also downstream where winter flood events are already known to arise and are well documented. The landscape in the area has not been designated for its importance, but it has a strong rural character. A development of this scale will have a very significant impact on the settlement pattern and the wider rural character in this area. It is recognised that there are proposals to replace the electricity pylons with underground cables, which would provide some landscape benefit. The southern section of the site is open in nature and has the potential to adversely impact the setting of the South Downs which is clearly visible from this section of the site. The south western edge of the site is also relatively close to Henfield. This village is also facing significant development pressure and there is a risk in the longer term of the potential for the existing and new settlement to coalesce. The site contains some listed buildings, the setting of which may be affected, but these are limited in number particularly when the overall site area is taken into account. The site promoter has committed to providing biodiversity net gain, and to retaining existing features such as hedgerows and ancient woodland. The site is relatively close to Cowfold and Hassocks. The centre of Cowfold and land around Stonepound Crossroads in Hassocks have been designated as an Air Quality Management Area due to poor air quality, which has predominantly arisen as a result of high traffic volumes in these areas. There is potential for additional traffic generated by this proposal to have an adverse impact on the air quality of this area, which would need to be understood and mitigated. The development may also need to provide new sewage treatment facilities to ensure that water quality in the area is not adversely affected. The site promoter has recognised the need to minimise climate impacts, and has identified the potential for land within the site area to be used for solar panels. It is noted electric vehicle charging points would be provided as part of the development. It is clear that a strategic scale development has the potential to deliver a large proportion of the Council’s housing requirements and at this stage it has been indicated that the level of affordable housing which can be provided would be around 35%, together with some specific elderly accommodation. The potential to meet Gypsy and Traveller requirements has also been identified. The proposals would provide for a range of community facilities and services in order to ensure that any new settlement can become a self-sustaining community. Further work is required to understand whether these facilities would be sufficient to offset pressure on existing settlements (e.g healthcare) and the timing of any delivery will be critical in order to minimise pressures on existing services, particularly in the early stages of any development. The potential for adverse impacts on nearby settlements - for instance, retail centres in Henfield or villages and towns in Mid Sussex District - will also need to be explored in more detail. The site is in a very rural location and is not accessed directly by any A roads. The nearest railway stations are in Hassocks and Burgess Hill, followed by Shoreham-by- Sea on the south coast. Although a link road to the A23 has been proposed, it is likely that additional traffic generated by the development will create pressure on the narrow rural roads in this area. However, it is recognised that the scheme will seek to minimise car trips and provide pedestrian, cycling and bus services. The proposals have identified that 7,000 new jobs would be generated as a result of development in this location. It is however noted that the site has been proposed in part to help the unmet housing needs in both the Gatwick Diamond and coastal West Sussex areas. This site is not particularly close to either the key employment areas of Crawley and Gatwick, or those on the south coast. If development in this location is to genuinely meet these unmet housing needs, it is expected to generate out-commuting from this area by some residents to reach employment.
Deliverability	The land is in the ownership of a number of landowners. Options agreements are being sought by the site promoter, but at this stage some areas of the site are still under negotiation. At the current time, the ability of the site to demonstrate delivery at a Local Plan Examination is not yet fully demonstrable. Some of the initial land promoted to the Council is now not thought to be available. The site is a new settlement and would require the delivery of a range of new infrastructure. It is considered that this will also have an impact on when development in this location could commence and on the initial rates of delivery. The site adjoins the administrative boundary of Mid Sussex and any development in this area will have a significant impact on this District, particularly in terms of the provision of a new road to access the A23. Horsham District Council has previous experience of joint working, working with Crawley Borough Council to prepare a Joint Area Action Plan to identify and bring forward development to the west of Crawley at what is now Kilnwood Vale. In order for development proposals to maximise their success, joint working is clearly beneficial. Given the proximity of this site with Mid Sussex District and the proposal for a link road which would be within this authority area, it will be necessary to engage and work with Mid Sussex. Our previous joint working experience has demonstrated that this is a process which takes time, and additional delays may arise due to the fact that Mid Sussex District is not at the same stage of Local Plan preparation as this Council. These factors are likely to impact on any commencement date at this location were the site to be allocated. It is also noted that the site is close to Henfield which is subject to existing and ‘promoted’ expansion – thus cumulative impact may affect market absorption and delivery of housing in this area.
Viability	At this stage it is considered that there is potential for the development on this site to be viable. However further work is needed to understand the precise level of housing that could support the level of affordable housing and community facilities which are provided together with the delivery of the employment offer in this location.
Development Quality	Promoters have a clear vision for the development. The proposed new market town will be based on the best principles of Garden Town development – seeking to design a characterful, permeable and liveable community. The promoter has recognised the need to consider long term stewardship and management of the community. It has been indicated that a design code would be produced to ensure high quality design and product mix.

Land at Rookwood, Horsham

SA394_A4_portrait

Site Name: Land at Rookwood, Horsham		SHELAA Reference: SA394
Site Area	39ha
Site Description	The site currently comprises a golf course with a mix of open fairways, greens and areas of rough grassland and trees. The site is bounded to the west by the A24 and to the north by the A264. The site is divided into a northern and southern section, separated by the B2237, Warnham Road. The northern section of the site adjoins Warnham Nature Reserve to the east, and the southern section of the site adjoins the built form of Horsham, in a predominantly residential part of the town. The eastern boundary of the site in this location is formed by Boldings Brook.
Summary of Proposal	The site could provide around 900 -1000 dwellings and is being promoted as an urban extension of Horsham. It has been indicated that the site could deliver 35% affordable housing. No land has been identified for Gypsy and Traveller accommodation. The promoter of this site has indicated that a primary school could be provided on the site. There may also be potential for SEND provision in this location. The proposal would provide a community hub and together with some small-scale local retail provision. No specific health care centre is identified as it is indicated needs could be met within Horsham town. The scheme would provide biodiversity net gain with significant provision of open space, a woodland park and green links throughout the development, with a strong buffer to protect Warnham Nature Reserve to the east. It is stated that carbon emissions would be minimised through design of the development and would provide Electric Vehicle charging points. The promoter has stated that development which comes forward would be delivered to high quality design principles including enhanced pedestrian and cycle links.
Site Suitability	Red /Amber /Green Rating
Landscape
Biodiversity
Archaeology / Cultural Heritage
Environmental Quality
Flooding / Drainage
Climate / renewables / energy efficiency
Housing
Education
Health
Leisure / recreation and community facilities
Transport
Other Infrastructure
Economic impact
Retail
Site Suitability Summary	The proposed site is currently in use as a golf course, located on the western edge of Horsham. The landscaping of the existing site is therefore man-made rather than natural, and consequently is not subject to any landscape designation. The site is located inside the A24 and there are therefore close links to the existing built form of Horsham town. The proposed scheme seeks to incorporate green spaces and landscaping throughout the development which would mitigate against the loss of the existing landscape. It is also noted that the promoter will ensure that biodiversity net gains are provided and that the adjoining nature conservation site – Warnham Local Nature Reserve - together with the historic mill building will continue to be protected. The western edge of the site to the south of the B2237 is Boldings Brook, a tributary of the River Arun. The river floodplain is not proposed for development and a range of enhancements to this area have been identified. Nevertheless, should development take place in this location, it will be necessary to ensure that no further risks are generated because of the development either on site or downstream. The site promoter has recognised the need to minimise climate impacts, and has stated that the design of the development will be to high energy efficiency standards and will provide electric vehicle charging points as part of the development. However, further work is required to understand the extent to which enhancements above building regulations and the use of low carbon / renewable energy sourced could be achieved. It is clear that a strategic scale development has the potential to deliver a good proportion of the Council’s housing requirements and at this stage it has been indicated that the level of affordable housing which can be provided would be around 35%. The provision of housing in the Horsham area would deliver housing in a key area of demand. No potential to meet Gypsy and Traveller requirements in this location has been identified. The proposals recognise the need to provide additional community facilities and include a primary school, community hub and a small element of retail. Given the proximity of the site to Horsham town centre, which has District level services and facilities (including swimming pools, cinema, theatres and Horsham Park) any new residents would also be able to easily access these facilities. The wide range of retail in Horsham town centre would be close and accessible to new residents living in this location. It is however noted that the northern section of the site is relatively isolated from the rest of Horsham, which has the potential to impact the community cohesion of this element of the site. It is also recognised that the site is currently in use as a golf course, which provides leisure and recreational opportunities and this would be lost were this proposal to come forward. It is understood that demand for golfing is falling, and that pay and play facilities are available elsewhere, but this will need to be clearly demonstrated. It is noted that the open space within and adjoining the built development would help to provide informal leisure and recreation opportunities. The site is directly accessible to the A24 with the A264 to Crawley directly adjoining the northern edge of the site. There are two railway stations within Horsham (Horsham and Littlehaven) which are accessible from this location. It is noted that pedestrian and cycle facilities will be incorporated into the design of the site. Existing bus services link to the site and could be linked in to the site to help reduce reliance on the private vehicle. The site does not promote additional employment land. The site is close to a range of employment opportunities within Horsham town. Opportunities for home working will be supported through the provision of full fibre broadband. It is however considered that further work is required to understand whether some small element of office space or hubs could be provided in the community hub.
Deliverability	The land is currently in use as a golf course and the land will not be available for development until 2022/2023. The site is currently in public ownership and it is expected that the site could be delivered within the Plan period. It is also noted that the site is within Horsham town and although this is an area of high housing demand, there is a high level of development ongoing in this area including Land North of Horsham. There is therefore a risk that there may be cumulative impacts affecting market absorption and delivery of housing in this area
Viability	At this stage it is considered that there is potential for the development on this site to be viable. However, further work is needed to understand the precise level of housing that could support the level of affordable housing and community facilities.
Development Quality	The site promoter has a clear vision for the development based on very high quality design and landscaping with green open spaces and views incorporated throughout the development, seeking to provide a characterful, permeable and liveable community.

Land West of Southwater, Southwater

SA119_A4_portrait

Site Name: Land West of Southwater, Southwater		SHELAA Reference: SA119
Site Area	140 ha
Site Description	The site currently comprises arable and pasture land interspersed by hedgerows and larger areas of woodland. Overall the site is rural in character, particularly to the west. To the east and south there are more urban influences where the site adjoins Worthing Road and the Horsham District Local Plan allocation of 594 homes.
Summary of Proposal	The site is proposed for around 1,200 dwellings and is being promoted as an urban extension of Southwater. It should be noted that Berkeley Strategic Land are currently building 594 dwellings and community facilities on adjoining land to the south of this site. In addition, the draft Southwater Neighbourhood Plan has identified land for 450 homes within this site area, comprising 350 units and a further 100 units for elderly accommodation. No land has been identified for Gypsy and Traveller accommodation but the landowner has indicated that they are willing to explore provision in their wider land ownership. Homes on the site would meet both older people and key worker provision. A commitment to providing affordable housing on the site is identified but the level is not specified. The promoter of this site has indicated that land for an all-through school, including a primary and secondary school and SEND provision, together with sports and leisure facilities for use by the whole community could be provided. The proposal would provide a community hub, together with some small-scale local retail provision to complement Lintot Square. Community use at Great House Farmhouse is proposed. A public square and outdoor event space would be provided. No specific health care centre is identified as it is indicated needs could be met at the existing centre in Southwater. The scheme would provide 8% habitat biodiversity and 38% gain in linear features of biodiversity, together with 50 acres of open space. It is stated that carbon impact would be minimised through design of the development and electric vehicle charging points would be provided, but the potential for alternative energy sources is not indicated. The proposals include employment providing for around 1,200 jobs, and co-working space for home workers and small businesses. Transport upgrades would also be provided, including link roads to Hop Oast and Two Mile Ash Road and full signalisation of the Hop Oast roundabout.
Site Suitability	Red /Amber /Green Rating
Landscape
Biodiversity
Archaeology / Cultural Heritage
Environmental Quality
Flooding / Drainage
Climate / renewables / energy efficiency
Housing
Education
Health
Leisure / recreation and community facilities
Transport
Other Infrastructure
Economic impact
Retail
Site Suitability Summary	Overall, much of the site is free from key environmental constraints. The land is not identified as being at specific risk from flooding, although any development that comes forward will need to ensure that no further risks are generated as a result of the development either on or offsite. Although attractive, the landscape in the area has not been designated as being of importance. Nevertheless, it is recognised that a development of this scale will have significant changes on the settlement pattern and the wider rural character in this area. The character of the area is however changing as a result of the ongoing development to the south and potentially as a result of development which comes forward through the neighbourhood plan. The site contains a Grade II* listed building (Great House Farm) but it is noted that this would be retained as a community building and the setting of this building protected. The site promoter has committed to providing biodiversity net gain, and has indicated that existing areas of ancient woodland and local wildlife within the site area would be protected. The site promoter not specifically focused on measures to minimise impact on climate heating beyond existing technologies and keeping pace with changes to building control. From an economic perspective, the promoters have identified the potential to provide additional commercial land, with 1,200 new jobs. In addition, the site is close to existing employment sites in and around Southwater and Horsham, which would provide opportunities to live and work locally. It is clear that a strategic scale development has the potential to deliver a good proportion of the Council’s housing requirements and meet a range of identified needs. However it is not certain as to the level at which affordable housing would be provided or that land would be made available for Gypsy and Traveller requirements. The ability to provide further contributions towards a new primary and secondary school has been identified, together with SEND provision. There is a need to understand in more detail how the needs arising from this new development could be met, although it is recognised that this will to some extent depend on feedback from WSCC. The promoters indicate the existing healthcare facilities can accommodate additional growth (there is capacity at the heath centre in Southwater). There is also potential for this proposal to deliver a wide range of community benefits. The site is close to the A24 and there is a very frequent bus service to Horsham, which has a railway station. However, the site will still generate traffic impacts, although the promoters have indicated further upgrades to the A24 can be provided. Pedestrian links to Horsham, including access across the A24, will need further exploration if the site is allocated for development. Additional retail development has been identified. There is potential for this to conflict with existing provision in Lintot Square. However, the site promoter has recognised this and it is considered that development could come forward to prevent this issue arising. There is potential to provide further economic development opportunity in this location with a further 1200 jobs. This would provide additional opportunities for residents in Southwater to live and work locally.
Deliverability	The land is in single ownership and it is considered that the site could come forward for 1,200 homes in the Plan period. It is however noted that the developer in this location has relatively slow build-out rates, which may limit the number of homes that can come forward in the plan period. Development levels would have to rise above current rates to 80 homes per year to ensure that the whole site could come forward in the plan period. It is also noted that the site is close to Horsham and development is ongoing west of Southwater. There is therefore a risk that there may be cumulative impacts affecting market absorption and delivery of housing in this area.
Viability	At this stage it is considered that there is potential for the development on this site to be viable. However, further work is needed to understand the precise level of housing that could support the level of affordable housing and community facilities.
Development Quality	Promoters have a clear vision for the development based on very high quality design and landscaping with green open spaces and views incorporated throughout the development, seeking to provide a characterful, permeable and liveable community.

Smaller Scale Development (Key Questions)

6.30 In addition to the new, large scale strategic allocations that will be necessary to help meet the housing requirements placed upon this Council, it is recognised that additional 'smaller' scale growth in and around towns and villages will be required. Smaller sites are often quicker and less complex to bring forward, and will help to maintain housing delivery across the plan period. More importantly, these sites can also help to sustain local communities, including maintaining the vitality of community shops and services.

6.31 The National Planning Policy Framework 2019 has sought to diversify the housing requirement to increase specific provision of small sites as part of the housing supply. Alongside the key strategic and smaller scale site allocations, local planning authorities will also need to identify further land to accommodate at least 10% of their housing requirement on sites no larger than one hectare, unless it can be shown that there are strong reasons why this cannot be achieved. At the current time, the vast majority of our windfall development (around 100 homes each year) has been delivered on these smaller sites and it is therefore envisaged that the need for smaller sites will mainly be met through this mechanism. Other land which has been promoted to the Council and is considered to be available and suitable for development is however usually larger than 1 hectare, although some potential exists to make up the remainder of this requirement through this route, including in Neighbourhood Plans.

6.32 Neighbourhood Planning has been an integral tier of the planning system since it was introduced through the Localism Act 2011. Horsham District Council takes a positive approach to working with, and assisting, those town and parish councils in the plan area that wish to undertake neighbourhood planning. We now have a number of 'Made' Neighbourhood Plans, with a number of other Parishes at Examination or in the later stages of plan preparation. The sites that are identified in these locally prepared plans will continue to contribute towards meeting housing needs in the period up to 2036.

6.33 Since the adoption of the Horsham District Planning Framework, the preparation of Neighbourhood Plans has become increasingly complex, with a greater level of evidence to support the allocation of sites and demonstrate their deliverability being required. This has slowed the delivery of a number of Neighbourhood Plans in this District. To ensure that the Council can demonstrate that it can deliver housing sites in the period up to 2036 and can maintain a five-year housing land supply, it is therefore likely that our strategic housing allocation policies will need to identify land in villages for developments of 50 homes or more in addition to existing Neighbourhood Plan sites. Where allocation of smaller sites is required, this will be undertaken in close consultation with these communities. There will still be opportunities for communities who wish to do so to allocate additional sites (potentially smaller scale of less than 1ha) in their new or revised Neighbourhood Plans.

6.34 In addition to the assessment of large-scale strategic sites, assessment of smaller sites that have been proposed to the Council as part of the call for sites has been undertaken. The detailed summaries are set out in the background report which accompanies this document. However, a number of sites have been identified as having potential for development. It is not expected that it will be necessary or even possible to allocate all of these sites.

6.35 Table 1 (below) identifies the sites which are considered to have some potential for development, together with the expected level of development for parishes across the district in the period to 2036. A number of these sites have either been identified directly by local communities as part of their neighbourhood plan preparation process, but do not as yet have ‘made’ plans. Other sites are identified as a result of the Council’s site assessment process.

6.36 The draft housing requirement for each settlement has been derived after considering the site assessment criteria, together with their position in the settlement hierarchy which takes account of the relative sustainability of settlements, for example existing facilities, services and transport links. In addition, the cumulative impacts of development in the locality have been considered when determining the level of development for each settlement.

Smaller Sites - Options

Do you consider this approach will allow existing neighbourhood plans that are undergoing preparation to be completed and minimise the need for them to undertake a review in the short term, whilst allowing the opportunity for communities to do this if they wish? Do you have any suggestions for a different approach?
Do you agree that smaller scale sites will also be needed to meet the Council’s housing requirements?
Will the approach of allocating land for over 50 homes in the Local Plan help to provide certainty of delivery, particularly in the short to medium term? Should there be a different threshold?
What are your views on the shortlisted sites and the proposed housing number for each settlement?

Table 1: Smaller sites with potential for allocation

Please note that for parishes where there is no ‘Made’ Neighbourhood Plan, the housing figure in the table comprises the number of houses already identified by the Parish in the draft neighbourhood plan together with an additional number that could potentially contribute towards the updated housing need target set by Government.

For example, Ashington Parish have identified 225 homes in their neighbourhood plan. The potential for a further 400 has been identified as part of the site assessment process. This takes the total set out in the table below to an overall total of 600 homes.

Settlement Name and Parish (where different)	Proposed Settlement Hierarchy Position	Smaller Scale Housing Requirement in addition to any Made Neighbourhood Plan	Short list of sites with potential for allocation	Additional Remarks
Ashington	Medium Village	600	Land South of Rectory Lane SA122,SA735,SA131 and SA484 (225 units) Land North of Rectory Lane - SA085, SA539,SA520,SA790 and 524 (400 units)	Land South of Rectory Lane has already been identified by Ashington Parish in their Neighbourhood Plan, which has completed Regulation 14 consultation. In addition it is considered that there may be potential for further growth to help meet wider housing demand in the south of the District. A number of SHLAA sites north of Rectory Lane may have potential to meet these needs, but further assessment is required to understand how community needs arising from this scale of growth could be met.
Barns Green	Medium Village	50	SA613 – Land at Slaughterford Farm (Sumners Pond) SA006 – Land south of Smugglers Lane SA510 – Land south of Muntham Drive SA344 – Land rear of Two Mile Ash Road	SA613 has been identified by Itchingfield Parish Council, which has now completed their Regulation 14 consultation. Additional sites may be required to accommodate the requirement of 50 homes, and views on the additional shortlisted sites are therefore sought.
Billingshurst	Smaller Town / Larger Village	to be determined	At the current time Billingshurst is being considered for larger scale strategic growth. If land is allocated in this location it is not considered that additional smaller scale development would be appropriate in this plan period. If land does not come forward at Billingshurst for large scale strategic growth further work to identify the appropriate level of smaller scale expansion will be required. Consideration of smaller sites with potential for development are set out in the Regulation 18 Local Plan Site Assessment Report.
Broadbridge Heath/ (Slinfold and Itchingfield Parishes)	Smaller Town / Larger Village	100 -150	SA386 – Land at Lower Broadbridge Farm SA622 – Land at Wellcross Farm	It should be noted that whilst both sites would result in an expansion of Broadbridge Heath, both sites are located in Slinfold and Itchingfield Parishes.
Christ's Hospital (Southwater Parish)	Smaller Village	30	SA129 – Land at the Warren, Christ’s Hospital
Cowfold	Medium Village	75	SA610 – Land south of A272 SA609 –Land north of A272 SA076 – Land at Brook Hill SA083 – Land at Cowfold Glebe SA366 – Land east of Cowfold	SA038, SA076 and SA610 have been identified by Cowfold Parish Council, which has completed its Regulation 14 Neighbourhood Plan consultation.
Henfield	Smaller Town / Larger Village	350	SA317 – Land at Sandgate Nurseries SA065 – Land East of Wantley Hill SA005 – Land north of Furners Lane SA011 – Land West of Backsettown Farm SA686 – Land at Parsonage Farm. SA504 – Land south of the Bowls Club	SA686, SA065, SA011 and SA504 have been identified in the Henfield Neighbourhood Plan, which has been submitted to Horsham District Council. The Regulation 16 Consultation has been completed with the Examination of the Plan programmed for early 2020.
Horsham - Forest ward	Main Town	100	SA074 – Land at Hornbrook Farm
Lower Beeding	Smaller Village	35	SA584 – Land south of Church Farm House SA575 – Sandygate Lane SA567 – Land at Glayde Farm	These sites have been identified by Lower Beeding Council, which has completed its Regulation 14 Neighbourhood Plan consultation.
Mannings Heath (Nuthurst Parish)	Smaller Village	0	/	Following the site assessment process, no additional sites have been identified as suitable for allocation in addition to those which have been identified in the Made Neighbourhood Plan.
North Horsham	Main Town	300	SA568 – Land at Mercer Road	There may be potential for a small amount of expansion to the west of the current North Horsham site. Any proposals for the intensification of the current allocation would need to be considered under the North Horsham allocation in the Horsham District Planning Framework. If required this policy will be saved on adoption of the revised Local Plan.
Partridge Green (West Grinstead)	Smaller Town / Larger Village	200	SA433 – Land at Dunstans Farm SA274 – Land north of the Rise SA320 – Land West of Church Road SA634 – Land at Dunstans
Pulborough / Codmore Hill	Smaller Town / Larger Village	275	SA556 – Land at Highfields, Codmore Hill SA445 – Land at New Place Farm SA112 – Land at Greendene Nurseries
Rudgwick/Bucks Green	Medium Village	50	SA442 – Land to the West of Church Street SA574 – Land north of Guildford Road
Rusper	Smaller Village	to be determined	Rusper is close to the area of study proposed by Homes England for large scale strategic growth. If land is allocated in this location it is not considered that additional smaller scale development would be appropriate in this plan period. If land does not come forward West of Crawley for large scale strategic growth further work to identify the appropriate level of smaller scale expansion will be required. Consideration of smaller sites with potential for development are set out in the Regulation 18 Local Plan Site Assessment Report.
Slinfold	Medium Village	0	/	Following the site assessment process, no additional sites have been identified as suitable for allocation in addition to those which have been identified in the Made Neighbourhood Plan.
Small Dole (Henfield Parish)	Smaller Village	20	SA505 – Land at Highdown Nurseries SA538 – Land West of Shoreham Road	Both identified sites are in Henfield Parish. It should be noted that the Parish of Upper Beeding covers the southern part of the village.
Southwater	Smaller Town / Larger Village	to be determined	At the current time Southwater is being considered for larger scale strategic growth and no smaller scale sites have been assessed as suitable for development at this stage. Consideration of smaller sites with potential for development are set out in the Regulation 18 Local Plan Site Assessment Report.
Steyning and Bramber	Smaller Town / Larger Village	50	SA742 – Land at Glebe Farm	Although classified together as a larger village, Steyning and Bramber are heavily constrained by the South Downs National Park. This has limited the number of sites which have been identified as having potential for development.
Storrington and Sullington	Smaller Town / Larger Village	100	SA361 – Land north of Melton Drive SA639 – Land off Fryern Road SA732 – Land south of Northlands Lane
Thakeham	Medium Village	50	SA039 – Land north of High Bar Lane SA513 – Land south of Furze Common Road
Upper Beeding	Smaller Town / Larger Village	90	SA483 – Land East of Pound Lane SA488 – Little Paddocks, Pound Lane SA055 – Land at Smugglers Lane	These sites, (together with SA155 in the South Downs National Park), have been identified in the Upper Beeding Neighbourhood Plan. An Examiner has concluded that the plan can progress to referendum. This will be held in March 2020. No additional sites other than those already identified by the Parish are considered to be suitable for development.
Warnham	Medium Village	50	SA070 – Land north of Bell Road SA071 – Land South of Bell Road
West Chiltington	Medium Village	25	SA429 – Land West of Smock Alley SA066 – Land at Hatches Estate

Policy 15 - Strategic Site Development Principles (Key Questions)

6.37 It is important that any urban extensions or new communities which are allocated in the new Local Plan bring forward vibrant and successful new communities, either as part of the extension of an existing settlement or in their own right. It is therefore expected that new strategic sites which are allocated adhere to the following key principles.

Strategic Policy 15 - Strategic Site Development Principles

Where land is allocated in the Local Plan for strategic scale development, proposals will be supported where it can be demonstrated that they adhere to the following principles:

Be designed to minimise the need to travel in the first instance and prioritise pedestrian and cycling opportunities. Development shall have a legible layout that facilitates other modes of sustainable transport and minimises reliance on the private car. It is expected that extensive provision for electric vehicle charging will be incorporated into the development.
Deliver the necessary new infrastructure to support the new development, including provision of utilities, water supplies, waste water treatment and any necessary transport mitigation. The design of development should consider the future direction of refuse collection and disposal. All developments will be expected to provide full fibre broadband.
Provide sufficient new employment opportunities through new employment land and through other opportunities to meet the principle of one new job per home.
Development will be expected to deliver the necessary services and facilities that contribute to the development of a successful community. This will include, but is not necessarily limited to, education facilities including SEND and alternative provision, healthcare, community buildings, and leisure and recreational facilities and new retail centres. Proposals will be expected to consider how they can accommodate any District-wide leisure facilities that may have been identified.
Deliver high-quality mixed-use communities that provide a range of housing types and tenures, including provision for young families, older people and Gypsies and Travellers. Strategic Site allocations developers will be expected to take into consideration the demand for self-build and custom build housing and provide enough serviced plots of land to meet the identified need.
Development will be expected to contribute to the achievement of zero carbon through a range of measures. Development will be expected to achieve this through direct measures such as the design and construction of development and the provision of alternative sources of energy such as combined heat and power, together with indirect measures such as design of the development to minimise the need to travel by car.
Masterplans will be expected to identify key areas of biodiversity enhancement, demonstrating that a minimum of 10% biodiversity net gain can be achieved. It is expected that the proposed development will respond to and complement existing features, and that any SuDs features will be incorporated into the provision of biodiversity gain and wider green infrastructure provision.
The design and layout of the development is landscape-led, responding to and complementing positive landscape characteristics and qualities of the site and surrounding area. A strong landscape buffer shall be provided to any open countryside beyond the allocation to provide a robust, long-term defensible boundary to the development. Development will be designed to a high quality that is locally distinctive, uses local materials and accords with garden community principles. Proposals should also be designed to bring forward healthy communities and lifestyles.
Identify long-term management structures to ensure the long-term success of communities which are created.

Strategic Site Principles

Please consider the strategic site development principles set out in the draft policy above. We would welcome your views on whether this policy captures all the requirements that new development can provide, or whether there are any omissions. We would also welcome your thoughts as to how the requirements set out in this policy can be practicably achieved and how any obstacles that it may present can be addressed.

Do you think the draft policy captures all the requirements that new development can provide? If not, what would you add?
How do you think the requirements in this policy could be practicably achieved? And how could we address any obstacles?

Policy 16 - Affordable Housing (Key Questions)

6.38 This policy will set the Council’s thresholds and targets for affordable housing. Affordable housing is subsidised to enable the purchase or rental price to be substantially lower than the prevailing market prices, and where mechanisms exist to ensure the housing continues to remain affordable for those who cannot compete in the housing market. All developments falling within Use Class C3 will be subject to this policy, including any retirement or assisted living accommodation within this use class. A Local Plan Viability Assessment is currently being undertaken, and will help to determine appropriate affordable housing targets and thresholds at the next stage of plan making.

6.39 The housing tenure target is to provide 70% of the total as social or affordable rented properties and 30% as Intermediate or shared ownership properties. Given the high cost of rented properties in the District, we will in the first instance seek social rented provision. It is however recognised that evidence of specific local need and viability considerations may on occasion justify a non-standard tenure mix. It is expected that affordable housing will be delivered as units built on development sites and will normally be in conjunction with the Council’s housing company or Registered Providers.

6.40 A significant amount of affordable housing will continue to be delivered through planning obligations. The currently adopted target is to secure a minimum 35% of homes on a development site as affordable homes. Given the high value of new housing in the district, and the significant need for affordable housing, the scope for increasing this target to up to 50% affordable housing is being considered through viability testing. Any new target will be put forward for consultation as part of the final draft Local Plan. In addition to those requirements and in order to further increase the supply, we are actively pursuing alternative and innovative ways to deliver a range of housing tenures in partnership with local registered providers including market, affordable and social rent. The Council is also embarking on direct delivery of affordable housing through a housing company. In exceptional circumstances, such as where there are overriding site constraints which inhibit the provision of affordable housing, or where it is agreed with the Council that provision can be better met on an alternative site in the District, contributions for off-site provision may be accepted as an alternative.

6.41 Community Land Trusts (CLTs) provide an opportunity for local community ownership of land for long-term affordable housing provision. Affordable housing provided by CLTs and most housing associations are exempt from the “Right to Buy”, allowing affordable housing to remain affordable in perpetuity. The involvement of CLTs in the delivery of new affordable homes, whether as part of a mixed tenure housing development or as an appropriately sited rural exception site, will be supported.

Strategic Policy 16 - Affordable Housing

All residential developments of 10 dwellings or more will be supported, provided that they include an appropriate proportion of affordable homes, and that at least 70% of the affordable homes are provided as social /affordable rented homes, with the remaining proportion provided as intermediate /shared ownership homes. Alternative tenure mixes, including substitution of affordable rented homes for social rented homes, will only be considered if evidence is provided to justify an alternative approach on the basis of local need or risk of non-delivery.
The Council will set thresholds at which different proportions of affordable housing could be sought, based on the outcomes of viability work, to ensure that affordable housing delivery is maximised whilst also ensuring that overall housing delivery is not compromised. An increase in the target for on-site provision of affordable housing above 35%, up to a maximum of 50%, will be tested.
Affordable homes must be integrated throughout the development and be of visually indistinguishable design. They should be located throughout the site in a manner that supports integration but can also be managed efficiently by the relevant housing associations.
If a development site is sub-divided so as to create two or more separate development schemes, one or more of which falls below the relevant threshold, the Council will require an appropriate level of affordable housing to reflect the provision that would have been achieved on the site as a whole had it come forward as a single scheme.
The Council will support schemes for suitably located affordable housing being brought forward through Neighbourhood Plans, including those being delivered through community land trusts.
It is expected that affordable housing will be delivered on-site. Where it can be demonstrated that this is not possible the Council will seek off-site provision or financial contributions in lieu.

Implementation

6.42 The mechanisms for calculating financial contributions in lieu of on-site provision will be set out in separate guidance. A Local Plan Viability Assessment is being undertaken which will ultimately confirm that an appropriate level of affordable housing is sought above an appropriate site threshold. It will be up to the applicant to demonstrate whether particular circumstances justify the need for a viability appraisal at the application stage. The Council will only accept a reduced amount of affordable housing, or alternative mix of sizes or tenures, due to lack of viability if exceptional circumstances have been demonstrated through the viability appraisal.

Do you consider that, if supported by viability evidence, the target for providing affordable housing on housing sites should be increased? If so, what % of affordable housing should the Council be seeking?

Should the Council seek to use the threshold for affordable housing of 10 dwellings on all sites? Are there occasions when it may not be appropriate and if so, what should the threshold be?

Policy 17 - Meeting Local Housing Needs

6.43 This policy is seeking to achieve a mix of housing sizes, types and tenures to meet the District's housing needs as identified in the Strategic Housing Market Assessment (SHMA) 2019 or any future updates. This will ensure that we can create sustainable and balanced communities, including a need to meet the housing needs of an increasingly elderly population.

6.44 Table 2 sets out an appropriate strategic mix of home sizes for different tenure housing which should be used when planning new development. If this is updated during the plan period, the most recent evidence base should be used.

Table 2

	Rented affordable housing	Affordable home ownership	Open market housing
1 bedroom home	35%	25%	5%
2 bedroom home	30%	40%	30%
3 bedroom home	25%	25%	40%
4 bedroom home	10%	10%	25%

6.45 ‘Rented affordable housing’ means social rented, affordable rented and affordable private rented homes. ‘Affordable home ownership’ means shared ownership homes, low-cost market homes and starter homes (as defined in Annex 2 of the National Planning Policy Framework). ‘Open market housing’ are homes sold at full market value on the open market.

6.46 The Council also recognises that future development should respond appropriately to local character and local needs. Evidence of local needs will normally be in the form of a local housing needs assessment prepared specifically for that parish or ward, or a Neighbourhood Plan that has successfully passed examination.

6.47 A range of different housing types and tenures will also need to be delivered. This may include build to rent and opportunities for self and custom build. The Self Build and Custom Housebuilding Act 2015 requires the Council to keep a register of people who are interested in self build and custom build projects in the District in order to assess demand for this type of housing. The Self-Build and Custom Housebuilding Regulations 2016, requires Local Authorities to grant suitable development permissions in respect of enough serviced plots of land to meet the demand on the register within a three year period. This does not mean that the Council itself must provide self-build or custom build plots for this purpose. We aim to satisfy the demand by requiring strategic allocations to deliver the required number of serviced plots, but will also consider appropriate proposals on smaller scale sites and in Neighbourhood Plans.

Strategic Policy 17 - Housing Mix

Development will be supported where it provides a mix of housing sizes and types to meet the needs of the District's communities as evidenced in the latest Strategic Housing Market Assessment or any subsequent updates in order to create sustainable and balanced communities. Other factors that may be taken into account include the established character and density of the neighbourhood, the viability of the scheme, and locally and robustly prepared evidence such as a ‘Made’ or referendum-stage Neighbourhood Plan or a local (parish) housing needs assessment.
The Council will support schemes being brought forward through Neighbourhood Plans, provided they are in general conformity with the relevant Local Plan.

Policy 18 - Improving Housing Standards in the District

Internal Space Standards

6.48 There is a mandate from Government to build more homes. However, the Council is clear that this requirement to build more homes should not be at the expense of providing fit for purpose, good quality housing for local residents.

6.49 In a ministerial statement released on the 27 March 2015 the Government gave local planning authorities the option to set additional technical requirements exceeding the minimum standards required by Building Regulations. However, to justify setting appropriate policies in their local plans, planning authorities are required to gather evidence to determine whether there is a need for additional standards in their local area.

6.50 As part of the preparation of the Local Plan, we have analysed a selection of recent developments against the Nationally Described Space Standards. There is strong emerging evidence to suggest that whilst many units being delivered meet or exceed the standards there are also a significant number of properties that do not. This evidence will be set out in a Minimum Space Standards Evidence Paper to be produced by the Council as the Local Plan Review progresses.

6.51 Ensuring there is sufficient internal space within new dwellings will mean that residents will be able to enjoy everyday activities in their homes and have the flexibility and adaptability required for any potential future needs. These minimum space standards will apply to all new dwellings within the District, including new dwellings provided through subdivision and conversion, and across all tenures. Exceptions to this requirement will only be allowed in exceptional circumstances, for example, if accordance with the policy would lead to a non-viable scheme. However, evidence will be required to this effect and in the interests of transparency, applicants should expect any details submitted to support their position to be treated as all other application documents and be made publicly available. In accordance with National Planning Guidance any viability assessment should follow the Government’s recommended approach to assessing viability and be proportionate, simple, transparent and publicly available.

Providing accessible, adaptable and wheelchair user dwellings

6.52 The National Planning Policy Framework requires local planning authorities to plan by size, type and tenure for the housing needs of different groups in the community, including older people and people with disabilities.

6.53 According to the Office for National Statistics (ONS), 18% of the UK population was over the age of 65 in 2017 and by 2066 a quarter of the UK’s population would be aged 65 or over, with a rise from just 2% of the population being aged 85 or over in 2016 to over 7% by 2066. Our own SHMA has found that the proportion of elderly people in Horsham District will rise significantly and a number of these will have disabilities.

6.54 The English Housing Survey found that 93% of UK homes do not meet the basic accessibility features that provide visitability (a housing design approach that means anyone using a wheelchair or mobility device can visit a dwelling) and many developers are not building new homes that are suitable for people as they age. Evidence prepared for the Council suggests that there is a higher proportion of older people in Horsham District when compared with the wider West Sussex region and nationally. The analysis shows the most significant growth in recent years to have been in the 60-74 and 75+ age groups. Given the growing number of older people in the District the Council recognises the need to provide homes that meet the changing needs of its residents, enabling them to remain independent and stay in their homes longer.

6.55 Building Regulations Approved Documents provide guidance on how to meet Building Regulations. Approved Document M relates to the access to and use of buildings and is split into two parts, with Volume 1 relating to dwellings.

6.56 Whilst M4(1) (Visitable Dwellings) is the compulsory standard that new dwellings must meet, M4(2) (Accessible and Adaptable Dwellings) and M4(3) (Wheelchair User Dwellings) are optional standards and can only be enforced where a local planning authority has adopted the standards through the local plan process. Once adopted the standards can be used to ensure that homes that are accessible and adaptable and of homes suitable for wheelchair users are provided. Our proposed approach to the adoption of M4(2) and M4(3) optional standards into local plan policy will be set out in an Accessible Homes Evidence Paper, which we are currently preparing.

6.57 By adopting these standards Horsham District Council can ensure future development within the District provides homes suitable for life and offers greater choice for disabled people and those with mobility difficulties.

6.58 The Council will allow exceptions to these requirements in exceptional circumstances but robust justification of the particular set of circumstances will be expected. Again, viability assessments should follow the Government’s approach to assessing viability and be proportionate, simple, transparent and publicly available.

Policy 18 - Improving Housing Standards in the District

Internal Space Standards

All dwellings will be required to meet the Nationally Described Space Standards (or any subsequent Government update) for internal floor areas and storage space. These standards will apply to all open market dwellings and affordable housing, including those created through subdivision and conversion.
Exceptions to these requirements will only be allowed where robust justification has been provided and the Council is fully satisfied with the particular set of circumstances.

Adaptable and Accessible Homes

The Council will require all new dwellings to meet the Optional Standards for Accessible and Adaptable dwellings as set out in the Building Regulations Approved Document M4(2) (or any subsequent Government update).
On sites providing 20 or more units (gross) and where there is an identified need on the Housing Register, a minimum of 5% of dwellings provided as part of the affordable housing requirement will be required to meet the Optional Standards for Wheelchair User dwellings as set out in the Building Regulations Approved Document M4(3) (or any subsequent Government update).
Exceptions to these requirements will only be allowed under the following circumstances;

Where it can be robustly demonstrated that meeting these requirements will not be practicable or financially viable
Where a new dwelling is being provided through a change of use or conversion. Where it is not practicable to provide suitable accommodation to the Building Regulations M4(3) standards for Wheelchair Users, an equivalent off-site contribution should be provided.

Policy 19 - Exceptions Housing Schemes

6.59 The NPPF enables the provision of affordable housing to be augmented by an 'exceptions policy' in rural areas. This enables the Council to grant planning permission where residential development would not normally be permitted.

6.60 Policy 19 sets out the criteria that must be met for a rural exception site to be approved (note this is distinct from the support in the NPPF for entry level exception sites set out in paragraph 71 of the NPPF and are delivered on sites adjoining existing settlements). A rural exception site proposal is a well-established mechanism to address a specific local housing need. Such schemes are considered exceptional and are considered to be a departure from the development plan: they will only be considered acceptable if there is a proven affordable housing need. The Council considers the appropriate way of demonstrating this need to be through a Parish Need Survey which should have a methodology, agreed upon by all stakeholders.

6.61 The Council expects rural exception sites to be progressed though partnership working with Registered Providers and the relevant parish council. Community- led schemes will primarily be delivered through Community Land Trusts. There will be an expectation for both rural exception and community-led schemes to demonstrate there is local support. Parish Councils, Registered Providers and developers are strongly encouraged to engage in early discussions with the Council if they wish to explore the possibility of progressing a rural exception site or a community-led scheme.

6.62 The occupancy of properties will be restricted to those with a strong local connection and must adhere to Horsham District Council's Housing Strategy. Properties will also be secured as affordable in perpetuity through Section 106 Legal Agreement.

Policy 19 - Exceptions Housing Schemes

In exceptional circumstances, limited amounts of land that would not otherwise be released for general market housing may be released for the development of affordable homes provided that:

There is an identified local need for such homes and no suitable alternatives exist within the locality to meet that need;
The development would solely meet the needs of a particular parish (or that parish plus its immediately adjoining parishes within Horsham District) and that the needs identified comprise housing for:

Existing residents of the parish who are in unsuitable accommodation or need separate accommodation in the area (excluding existing owner-occupiers)
People whose work provides important services and who need to live in the parish.
People who may no longer be resident in the parish but have longstanding links with the local community.
People with the offer of a job in the parish who cannot take up the offer because of a lack of affordable housing.

The development would provide subsidised housing which will be secured as affordable in perpetuity, through a Section 106 Agreement. Occupancy should adhere to Horsham District Council's housing strategy.

The Council is supportive of the delivery of community led developments involving affordable housing, primarily via Community Land Trust (CLTs), to come forward on suitable small sites throughout Horsham subject to meeting the criteria set out above.

Policy 20 - Retirement Housing and Specialist Care

6.63 The need to provide suitable housing for older people in the District is very important, particularly as a notable increase in the older person population is projected, as evidenced by the Council's Strategic Housing Market Assessment (SHMA). The Study also acknowledges that there is a clear link between age and disability with older people more likely to have a long-term health problem or disability. The SHMA sets out that, given the ageing population and higher levels of disability and health problems among older people, there is likely to be an increased requirement for specialist housing options. There is also a need to consider the needs of people with other specialist care requirements who are not necessarily elderly. We therefore wish to ensure that the right type of housing is brought forward to appropriately meet the needs of the District's residents.

6.64 In addition to ensuring that development is designed to be as flexible as possible to accommodate a wide range of needs, we support proposals for a variety of specialist care housing accommodation in and around the District. These will be monitored and safeguarded through the Authority Monitoring Report. This policy does not direct this specialist accommodation to any particular locations, but sets preferred criteria that need to be met to ensure that such developments are not only in the most suitable location, close to shops and amenities, but also accessible for those with impaired mobility. Whilst residents of retirement housing schemes in particular are often still very mobile they may not have access to a car, and proximity to services within walking distance or on bus routes is important.

6.65 The different types of housing this policy is intended to cover includes retirement living (also known as sheltered housing), which incorporates a self-contained home plus limited communal facilities and some support (not care). Extra-care housing (also known as assisted living) offers a higher level of care than retirement living and more extensive communal areas. Unlike sheltered housing, extra-care housing is regulated by the Care Quality Commission (CQC). Residential care incorporates individual rooms within a wider residential setting and a high level of care, including the provision of nursing care.

6.66 Continuing care retirement communities usually include options for independent living, extra-care housing and nursing care. The developments are often more 'self-contained' and therefore typically provide most of the facilities and services required by the residents as well as opening these facilities to residents of the local areas. Housing options for younger people with care needs can include adapted properties, sheltered housing schemes for young people, supported housing in the community and supported living. These housing types are not intended to be definitive, but provide an indication of the different housing options covered by this policy.

6.67 It is acknowledged that there is some ambiguity regarding the use class of extra-care facilities and whether certain facilities can be classified as C2 (residential institutions) or C3 (dwelling houses). Whilst it is generally accepted that a traditional care home with shared facilities and regular meals served to residents would fall within a C2 use class, schemes with self-contained units with shared facilities and differing care packages could be deemed to fall within either use class. This will depend on the merits of each individual application. Development proposals will therefore be assessed on the level of care provided and the scale of communal facilities.

6.68 For proposals that are deemed by the Council to provide C3 accommodation, we will require affordable housing in accordance with the Council's affordable housing requirements as set out in Policy 16. Proposals that create living spaces that retain the essential characteristics of a self-contained dwelling, even if some care is provided, should not automatically be precluded from meeting the Council's affordable housing policy, however, it is acknowledged that the viability of extra-care housing will differ from general mixed tenure development schemes. Developments that include self-contained units as part of a residential care scheme (C2 use class) will be expected to meet our affordable housing requirements, unless it can be robustly demonstrated that meeting this requirement would make the scheme unviable.

Policy 20 - Retirement Housing and Specialist Care

Proposals for development which provides continuing care retirement housing, retirement housing and specialist care housing will be encouraged and supported within or adjoining defined built-up areas, or as part of strategic housing allocations, and where it is accessible by foot or public transport to local shops, services, community facilities and the wider public transport network. The Council will particularly encourage schemes that meet identified local needs for those on lower incomes and provide affordable accommodation for rent or shared ownership/equity.
Continuing care retirement communities will also be required to:
1. Provide accommodation for a full range of needs, including care provision along with the self-contained and supported living accommodation; and
2. Include suitable provision of services and facilities, including transport, to meet the needs of residents/staff and which contribute to the wider economy.

Development that provides C3 accommodation (dwelling houses) will be expected to provide affordable housing in accordance with the Council's affordable housing requirements. Development that includes self-contained units as part of a residential care scheme (C2 use class) will also be expected to provide appropriate on-site affordable housing or a commuted sum in lieu of on-site units, unless it can be demonstrated that meeting this requirement would make the scheme unviable. Where a site is phased or is in separate parts, the site will be considered as a whole when determining the affordable housing requirements.
Where development is proposed in the countryside, clear justification of its location will be required, together with evidence that alternative sites are not available or are unsuitable.

Policy 21 - Rural Workers' Accommodation

6.69 Rural accommodation supports the rural economy and enables people to live close to where they work, which is particularly necessary in the more remote rural areas in the District. In some circumstances it will be appropriate to allow for the development of accommodation to house workers in the rural economy. To prevent sporadic development, the use or redevelopment of existing buildings will be encouraged to bring redundant buildings back into use. Where a building of heritage value would be reused or renovated for rural workers' accommodation this will be viewed positively.

6.70 New isolated houses in the countryside will normally be avoided. There may sometimes however be special circumstances where it is essential for a rural worker to live permanently at or near their place of work, and therefore help to support the rural economy. It is appropriate to allow for the development of accommodation to house rural workers where it can be justified, and in these instances, the occupation of the dwelling will be restricted by condition.

6.71 It is acknowledged that the rural economy is evolving and is not necessarily limited to solely farm-based activities. Applications for rural workers' accommodation can be considered in this context, but the applicant will be expected to set out the special justification that exists to support residential development in the countryside and that criteria (1) to (4) has been met.

Policy 21 - Rural Workers' Accommodation

Outside the defined built-up area new housing for rural workers will be supported provided that:

There is a functional need for the dwelling and the occupation of the dwelling is to support the established business use
Evidence is submitted to demonstrate the viability of the rural business for which the housing is required
A new dwelling cannot be provided by redeveloping an existing building on the site; and
The size of the dwelling is proportionate to the essential need of the business and is well related to existing buildings on site.

6.72 Where applications are received to remove occupancy conditions associated with rural workers' accommodation, evidence will be required to demonstrate why the condition is no longer required. This evidence should include details of a suitable period of marketing the property at a realistic market price, taking into account average incomes and the existence of the occupancy condition.

Policy 22 - Replacement Dwellings and House Extensions in the Countryside

6.73 This policy is seeking to ensure that any replacement dwellings, house extensions and outbuildings are of an appropriate scale, siting and design, and have due regard to the countryside setting and the existing dwelling. Extensions to dwellings need to ensure that they can be "read" as an extension and do not dominate the existing dwelling. This ensures that a mix of rural housing remains in the District as without this policy all rural dwellings may be extended to become large homes that are beyond the reach of rural residents.

Policy 22 - Replacement Dwellings and House Extensions in the Countryside

Outside the defined built-up areas, house extensions, replacement dwellings and outbuildings will be supported if the development can be accommodated appropriately within the curtilage of the existing dwelling. In addition:

Replacement dwellings will only be supported on a one-for-one basis and if it can be demonstrated that the property is not derelict.
Replacement dwellings should not be disproportionate to the size of the existing dwelling. Extensions should be in keeping with the scale and character of the existing dwelling. The cumulative impact of existing extensions will be taken into account.
Garages and any new outbuildings will be required to meet with all other appropriate policies, particularly design principles and should be grouped with the house, having regard to the dwelling they serve.
Subsequent extensions to converted agricultural buildings which detract from the original form and character will be resisted.

Policy 23 - Ancillary Accommodation

6.74 Residential annexes can provide a desirable form of additional accommodation for families alongside an existing residential dwelling. For example, there may be occasions where annexes can provide accommodation for a dependant or elderly family member or for staff supporting a dependant or elderly family member.

6.75 This policy provides guidance on applications for ancillary accommodation where a proposal seeks to provide additional accommodation beyond that which can be provided through the use of permitted development rights. This policy is particularly relevant where planning permission for ancillary accommodation is being sought outside of the defined settlements in countryside locations, where development is more carefully managed, although the principles can also be applied to those instances where annexes are sought within built-up areas.

6.76 To be considered as ancillary the additional accommodation must be supplementary and modest in scale to the main residence. Whilst we recognise that ancillary accommodation can provide additional accommodation in certain circumstances, the use of annexes as a separate dwelling will not be supported. Where permission is granted for ancillary accommodation it will be subject to a condition requiring the additional accommodation to remain ancillary to the main residence and is not used as a separate planning unit.

Policy 23 - Ancillary Accommodation

Proposals for ancillary accommodation will be supported provided that;

The existing dwelling is in lawful residential use and a genuine need for the accommodation can be demonstrated.
There is no boundary demarcation or sub-division of the garden area between the annexe and the host dwelling within the curtilage of the property;
There is a clear functional link between the annexe and the host dwelling, including shared access arrangements;
The scale, massing and appearance of the proposed annexe relates sympathetically to the host dwelling and the surrounding area.
The use of ancillary accommodation as a separate dwelling will not be supported.

Do you agree with the draft policies in this section?
If not, what changes would you suggest?

Policy 24 - Gypsy and Traveller Accommodation

The following issues have been identified that will be addressed through the policies in this document;

The Council is required to identify the accommodation needs of Gypsies and Travellers and plan for these needs in accordance with national planning guidance.
The current lack of authorised sites means that the Council faces difficulty resisting application for windfall sites in less suitable or desirable locations.
If enough sites are provided, the number of illegal encampments and incursions of Gypsy/Traveller pitches which occur across the district will reduce.
There is a desire for the travelling and settled communities to recognise and appreciate each other’s needs and to work together to build cohesive communities.

Definition

6.77 The Housing Act 2004 places a duty on local authorities to produce assessments of accommodation need for Gypsies, Travellers and Travelling Showpeople (GTTS), and outline how their needs will be met. However, there is no requirement for local authorities to provide sites on land which they may own.

6.78 The main planning policy document relating to GTTS is the ‘Planning Policy for Traveller Sites’ document (PPTS) that was first published by the Government in March 2012 and updated in August 2015. This document provides a definition of both ‘Gypsies and Travellers’ and ‘Travelling Showpeople’ for the purposes of planning policy. Horsham District Council has therefore used these definitions for the purposes of this document.

Gypsies and Travellers:

‘Persons of nomadic habit of life whatever their race or origin, including such persons who on grounds only of their own or their family’s or dependents’ educational or health needs or old age have ceased to travel temporarily, but excluding members of an organised group of Travelling Showpeople or circus people travelling together as such’;

Travelling Showpeople:

‘Members of a group organised for the purposes of holding fairs, circuses or shows (whether or not travelling together as such). This includes such persons who on the grounds of their own or their family’s or dependants’ more localised pattern of trading, educational or health needs or old age have ceased to travel temporarily, but excludes Gypsies and Travellers as defined above.’

Gypsy, Traveller & Travelling Showpeople Sites in Horsham District: Existing Provision

6.79 Horsham Council employed specialist Gypsy, Traveller and Travelling Showpeople consultants to carry out an updated needs assessment for Gypsies, Travellers and Travelling Showpeople in Horsham District for the new Horsham Local Plan period (2019-2036). A survey of all existing Gypsy and Traveller pitches and Travelling Showpeople plots in the District was carried out during 2019. Their findings are as follows:

Gypsies & Travellers - Total number of pitches in the district	Authorised pitches in the district	Unauthorised pitches
119	95	24
Travelling Showpeople - Total number of pitches in the district	Authorised pitches in the district	Unauthorised pitches
8	8	0

Gypsy, Traveller & Travelling Showpeople Sites in Horsham District: Estimate of Future Needs

6.80 86 interviews were undertaken as part of the Gypsy and Traveller and Travelling Showpeople study to understand the future housing needs of Gypsies, Travellers and Travelling Showpeople in the District. This interview process sought to understand which families met the planning definitions for Gypsies, Travellers and Travelling showpeople.

6.81 In total, a need for 93 pitches for Gypsy and Traveller households in Horsham District has been identified over the Plan period, and for which it will be necessary to identify land in the Local Plan to meet this need. The breakdown of need by 5 year intervals over the Plan period is as follows:

Years	0-5	6-10	11-15	16-17	Total
	2019-24	2024-29	2029-34	2034-36
	50	15	17	11	93

Other Needs

6.82 Under the Duty to Co-operate, the need for additional pitches in the South Downs National Park (SDNP) area was considered, as there is one site in Horsham District which extends over the South Downs boundary. It was determined that these caravans were not occupied by Gypsies or Travellers and there is no need for additional pitches in the SDNP area of Horsham District. No additional needs for transit or temporary sites have been identified due to the historic low number of unauthorised encampments and the transit site in Chichester which meets needs on a county wide basis.

6.83 There were a few instances where it was not possible to conclude whether families met the Gypsy and Traveller and Travelling Showpeople definition. There may therefore be a need for an additional 6 pitches for these ‘undetermined’ households. It was recommended that the Council set out a criteria based policy to consider these needs, where evidence is provided that they meet the Gypsy or Traveller definition.

6.84 The Gypsy and Traveller and Travelling Showpeople needs assessment identified a need for 19 additional pitches for households that did not meet the revised planning definition for Gypsies and Travellers. While there is not a requirement to include these households within the Gypsy and Traveller Accommodation Assessment, the need for these households will be addressed through the general housing provision policies in the Horsham Local Plan.

Travelling Showpeople

6.85 The Gypsy and Traveller needs assessment has identified that there are no current needs for the existing Travelling Showpeople in the District. The study concluded that should future needs arise, this could be met on existing sites, although it was recommended a criteria-based policy be provided to consider any undetermined households that can provide evidence that they meet the planning definition of a Travelling Showperson.

Meeting Future Gypsy and Traveller Needs

6.86 Horsham Council held a Gypsy, Traveller & Travelling call for sites exercise between 3 June 2019 and 30 August 2019 to identify potential sites for future Gypsy, Traveller and Travelling Showpeople use. Details of 3 potential sites were received. Further work is necessary to understand the potential of these sites, as well as for the potential for sites to come forward as part of large-scale strategic site allocations (i.e. 800 dwellings or more), as has been identified earlier in this chapter. If this need cannot be fully demonstrated through this route it will be necessary to explore other options to meet this need. Further work to understand the potential for intensification on existing sites will therefore be undertaken.

Policy 24 - Gypsy, Traveller and Travelling Showpeople Accommodation

The Council will meet the identified current and future accommodation needs of Gypsies, Travellers and Travelling Showpeople in Horsham District by:
1. safeguarding existing authorised sites for Gypsies, Travellers and Travelling Showpeople in the District, unless the site is no longer required to meet identified needs;
2. Allocating new sites on strategic site allocations
3. If required, reconfiguring existing private and public sites (which will be determined through a site assessment).

Proposals brought forward for permanent Gypsy and Traveller pitches and Travelling Showpeople plots on the sites identified on existing authorised sites will be required to demonstrate all of the following:
1. a suitable layout of the site;
2. that the site has essential services such as water, power, sewerage, drainage and waste disposal; and
3. high quality boundary treatment and landscaping of the site.

Development of any additional permanent or temporary Gypsy and Traveller pitches must meet an up-to-date and evidenced need and will be determined in accordance with the National Planning Policy for Traveller Sites (2015) document and Gypsy and Traveller / Travelling Showpeople definitions. In addition to part 2 above proposals must also satisfy criteria a-f:
1. the site has safe and convenient access to the highway and public transport services;
2. there is provision within the site for parking, turning and servicing;
3. the site has reasonable access to local services and community facilities such as healthcare, schools and shops;
4. the proposal would not result in significant adverse impacts on the amenity of occupiers of neighbouring sites;
5. the proposal would not result in significant adverse impacts on the visual amenity of the local area; and sites at risk of flooding should be subject to the sequential and exception tests.

Do you agree with the draft policy on Gypsy and Traveller sites? If not, please give details as to why not or how the policy could be changed.
In terms of meeting the identified need for Gypsies, Travellers and Travelling Showpeople, do you agree with the approach of intensifying existing authorised sites, if required, in addition to identifying a number of strategic and non-strategic sites?
If possible, do you think that the Council should allocate all identified need on a number of new sites? Should these all be strategic (800 dwellings +), or a range of large and smaller sites?

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