Draft Horsham District Local Plan 2019-2036

Comment ID /4589
Document Section Draft Horsham District Local Plan 2019-2036 Economic Development (Key Questions) Policy 9 - Conversion of Agricultural and Rural Buildings to Commercial, Community and Residential Uses Policy 9- Conversion of Agricultural and Rural Buildings to Commercial, Community and Residential Uses View all on this section
Respondent Thakeham Parish Council (Mr Ow… View all by this respondent
Response Date 30 Mar 2020
What is the nature of this comment?
  • Object
Summary
Strong Objection: as it stands, this policy will directly and seriously undermine Policy 28 Countryside Protection.
Comment

Strong Objection: without proposed amendments, and as it stands, this policy will directly and seriously undermine Policy 28 Countryside Protection.

Council is very concerned about both the general aims and specific phrasing of this new policy.  To the extent that it will facilitate the conversion of agricultural buildings in isolated countryside settings to general open-market housing and commercial uses inappropriate to locations, we consider the policy to be fundamentally misguided.  It runs directly counter to existing Thakeham Neighbourhood Plan Policy 9 (Development in the Countryside), which aims to resist ‘sporadic development by preventing conversion of isolated buildings or farm buildings of no merit’ and to ‘ensure that houses suitable for agricultural or forestry workers will not continue to be lost from the local housing stock by their extension into general open market dwellings.’

Council fundamentally disagrees with facilitating the presence of more open market housing and businesses at isolated locations in the countryside.  This policy’s aim (which is evidently to facilitate this, subject to some moderation of visual change and ensuring access) misses the fundamental point that adding more people, activity and vehicles in isolated rural locations has negative environmental impacts that simply cannot be adequately mitigated or balanced by other benefits.

To the extent that it relates to residential development this policy is also unnecessary and has considerable potential to cause confusion.  There is an existing regular stream of agricultural conversion applications under class Q prior approval regulations.  The adoption of this new policy will leave applicants, statutory consultees and the local planning process unclear which application route to follow, and which criteria apply.

Therefore Council seeks the removal of all reference to residential units from this policy.  In addition, we believe that the new policy text needs a number of improvements, i.e. conversions of buildings outside BUABs should:

  • Be for the purpose of commercial or community developments of a type that is appropriate to a countryside location;
  • Clause 2 needs the addition of a reference to avoid substantial demolition as well as ‘reconstruction’;
  • Clause 5 relies on a series of aesthetic judgements relating to design quality and ‘enhancement’ that are likely to be vulnerable to appeals vs refusal. It needs greater specificity, including provision that proposals should not result in a significant increase in the existing building footprint or height;
  • Clause 6 suffers from exactly the same weaknesses that affect Policy 8, and should be tightened thus:

“Any proposal must demonstrate that it will not adversely affect the character, appearance or visual amenities and the intrinsic character and beauty of the countryside and the location in question, and must seek to enhance biodiversity in and around the site.”

Proposed Change Council seeks the removal of all reference to residential units from this policy. In addition, we believe that the new policy text needs a number of improvements, i.e. conversions of buildings outside BUABs should:

Be for the purpose of commercial or community developments of a type that is appropriate to a countryside location;
Clause 2 needs the addition of a reference to avoid substantial demolition as well as ‘reconstruction’;
Clause 5 relies on a series of aesthetic judgements relating to design quality and ‘enhancement’ that are likely to be vulnerable to appeals vs refusal. It needs greater specificity, including provision that proposals should not result in a significant increase in the existing building footprint or height;
Clause 6 suffers should be tightened thus:
“Any proposal must demonstrate that it will not adversely affect the character, appearance or visual amenities and the intrinsic character and beauty of the countryside and the location in question, and must seek to enhance biodiversity in and around the site.”
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