Draft Horsham District Local Plan 2019-2036

Comment ID /5478
Document Section Draft Horsham District Local Plan 2019-2036 Economic Development (Key Questions) Strategic Policy 6 - Economic Growth Strategic Policy 6 - Economic Growth View all on this section
Respondent Keep Southwater Green (Mr Pete… View all by this respondent
Response Date 30 Mar 2020
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  • Object
Comment on SP6

Please see below as text box won't let me 'cut and paste'

Proposed Change Paragraph 5.6 claims that Strategic Policy 6 seeks to achieve ‘sustainable economic growth’ over the Plan period, but there nowhere appears stated any definition of what this should mean in practise: whether economic growth that is environmentally sustainable (in accordance with the UN definition) or – as might be inferred from paragraph 5.8 – economic growth that is sustained. In support of the latter interpretation it is disappointing to note that there appears no explicit SP6 commitment to prioritising the re-use of brownfield land for new business premises, nor even to ensuring that all major new business sites are sustainably located with respect to the availability of sustainable transport options, for both employees and freight (eg. through proximity to rail-freight transfer facilities) - as might have been expected in order to implement the Plan’s ‘vision’ for Transport (# 3.15). Instead, there appears to be an assumption (# 5.3) that ensuring ‘sufficient additional employment land can be provided alongside new housing growth’ so as to ‘ensure that new residents have opportunities to live and work locally’ will mean that they actually do so in numbers that justify the allocation of such ‘employment land’, whereas this will in practise depend upon such factors as whether the types of new homes built are appropriate for those doing the types of jobs that might be on offer. In reality most new residents will commute to their existing jobs elsewhere, which lends a certain unreality to the SP6 requirement that all strategic site allocations of 800 or more homes must provide one job for each new dwelling within the site, which can only mean that even more greenfield land must be ‘released’ to satisfy this requirement. (The planning assumptions upon which this is predicated may be challenged on the grounds that employment needs in a particular location surely determine the housing requirement at that place - rather than vice versa as seems to be assumed by para. 5.8). It is therefore disappointing that, ‘to ensure that sufficient additional employment land can be provided alongside new housing growth’, the Council has already approved several greenfield sites as new ‘employment land’ (# 5.3), which could be seen as having the potential to influence the selection of options for ‘strategic’ housing development in locations close to some of them (notably at Adversane and Billingshurst). The same might be thought of some of the ‘Employment Site Allocations’ listed by SP6 (Rosier Commercial Centre and land north/south of Bucks Barn being explicitly linked to possible ‘strategic’ housing sites nearby), though others do have environmental sustainability potential through the redevelopment or intensification of an existing or adjacent site or as a result of their proximity to a railway line and therefore a possible rail-freight transfer facility (as at Warnham Station and the Langhurstwood Road Sites – though the latter require a bus service for access by workers without cars). It is moreover claimed (# 5.9) that ‘This policy seeks to address the office floorspace requirement by providing additional, high-quality employment floorspace within the District’, but it might also be asked how far SP6 takes into account the likelihood that the growth of Internet-based remote-working will appreciably reduce the demand for office floorspace before the end of the Plan period.