Draft Horsham District Local Plan 2019-2036

Comment ID /4802
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 Ms Anna Prior View all by this respondent
Agent Lichfields (Miss Maddie Lane)
Response Date 30 Mar 2020
What is the nature of this comment?
  • Object
Summary
This draft policy does not fully address situations for development proposals on brownfield land outside and/or adjacent to Built Up Area Boundaries where there is capacity for a greater extent of development of non-residential uses or more than five residential units (whether via conversion or redevelopment).
Comment

Sites adjacent to a Built Up Area Boundary

Draft Policy 9 ‘Conversion of Agricultural and Rural Buildings to Commercial, Community or Residential Uses’ outlines the criteria for when residential development of “up to five residential units” outside defined Built Up Area Boundaries (BUABs) will be supported. The policy does not include criteria for proposals for more than five residential units and it is unclear how the 5 dwelling limit has been derived. This does not fully address the policy vacuum for development proposals on brownfield land outside and/or adjacent to BUABs where there is capacity for a greater extent of development of non-residential uses or more than five residential units (whether via conversion or redevelopment). This clarity is required to bring the policy in line with NPPF.

The NPPF strongly supports the effective use of land in meeting the need for homes and other uses. It states that “strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land” (Para.117). The Draft Plan fails to seize this requirement. Nor would it ensure that the Local Plan is optimising the use of land as required at paragraph 123a of the NPPF.

 

Agricultural and Rural Buildings
The Draft Local Plan recognises that Horsham includes a stock of buildings which are suitable for conversion to other uses and that proposals for the conversion of rural buildings to other uses will come forward over the plan period (Para. 5.20).

This is supported in the context of the above comments on the suitability of brownfield/PDL sites adjacent to BUABs. However, whilst “equestrian businesses” are noted to make up part of the rural character of Horsham District within the supporting text to Policy 9 (Para. 5.20), equine use is not specifically covered in any policy wording for potential residential conversion. This should be acknowledged in Policy 9 in order to establish a clear policy approach to alternative uses.



Proposed Change Development in suitable brownfield locations (in line with the NPPF) needs to be specifically addressed for brownfield sites adjacent to BUABs. Such location are significantly more sustainable than development in the open countryside and should be the preference for any development outside of BUABs.

(Please read alongside accompanying letter and submitted plan)
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