Draft Horsham District Local Plan 2019-2036

Chapter 7 Conserving and Enhancing the Natural Environment (Key Questions)

The policies in this document will address the following issues:
  • The high-quality environment makes Horsham District an attractive place to live and work. As well as contributing to the high quality of life, it plays an important role in attracting and retaining businesses. It is therefore important to ensure that it is maintained and enhanced.
  • Increased traffic has led to a reduction in air quality in the district. There are Air Quality Management Areas in Storrington and Cowfold. The impact of increased traffic on air quality in the rest of the District will need to be considered and mechanisms to improve air quality should be put into place.
  • Opportunities to redevelop and clean up any sites which have become contaminated through past uses should be investigated.
  • Water quality in the District is overall, moderate to good. New development will need to ensure that increased levels of wastewater are treated to ensure that there is no deterioration in these levels and that enhancements are made where possible.
  • There is a continued need to protect and enhance nationally and locally designated landscapes, habitats, species and ancient woodland;
  • In addition to protecting designated sites, other habitats and species should be protected and enhanced to maintain a functional ecological network within and beyond the District boundaries.
  • The population should be given the opportunity to access a high-quality natural environment without damaging it.

Environmental Quality

7.1 Overall, the environmental health of the District is good. At the present time, a key area of concern is the recent decline in air quality. Monitoring of air quality in the District has revealed that some areas have high levels of nitrogen dioxide, which can cause health problems. In Storrington and Cowfold the level of this air pollutant has been high enough to require the designation of Air Quality Management Areas (AQMAs). The primary cause of high nitrogen dioxide levels in the District is from vehicle emissions, and the impact of development on transport levels and air quality is therefore a key consideration for this plan.

7.2 Overall, water quality in the District is in general good, although there are some parts of the Adur where water quality needs to be improved. There is a need to accord with the Water Framework Directive and ensure that water quality is maintained or enhanced. There is the potential for water quality to be adversely affected as a result of development, and by climate change, for example from increased demand on waste water treatment works. The land in the District is of high quality overall, but there is potential for a small number of sites to be contaminated as a result of past uses. Development proposals which would be impacted by contamination would need to ensure that remediation of the land takes place.

District Character and the Natural Environment

7.3 Horsham District is predominantly rural in character, and is varied in nature. The Horsham District Landscape Character Assessment 2003 identified 32 separate landscape character areas across the District. This unique character depends on the combination of natural features such as the field size, amount of woodland cover, hills and river valleys; built features, including settlements of different sizes and building style; and historical features. The range of different building materials includes sandstone and flint tile hanging, and the distinctive Horsham stone, which is used as a roofing material in many villages across the District.

7.4 Many of the features that contribute to the overall character of Horsham District have been recognised for their important contribution to the landscape and nature conservation. Around 8% of the land has been designated as of importance for nature conservation. The land in our District supports a number of protected species including bat species, snakes, great crested newts, dormice and badgers. Much of the north eastern part of the District has been designated as a nationally important Area of Outstanding Natural Beauty (AONB), and the southernmost section of the District (including the land not covered by this plan) is within the South Downs National Park.

7.5 Areas that are outside nature conservation designations are still important to the overall character of Horsham District, and this environment is highly valued by those who live and work here. The recently updated Landscape Capacity Assessment (2020) demonstrates that although much of the District is not a designated protected landscape, it has a limited capacity for development due to its rural and relatively unspoilt qualities. The landscape in some areas also acts as an important visual break, separating smaller and larger settlements. The natural environment is also important to the economy, as it provides 'services' such as flood protection, fuel sources, food, and helps reduce the impact of climate change. It is therefore important that the attractive qualities of the District are retained, whilst accommodating change to meet the District's wider social and economic objectives, through landscape led development that truly understands the existing landscape character and uses it as an asset to design and place making.

Policy 25 - Environmental Protection

7.6 In order to maintain, and improve, the quality of the environment in Horsham District, the potential for development to generate pollution will need to be considered and appropriately mitigated where necessary.

7.7 The Council will seek to ensure that surface water flooding is managed to prevent the contamination of water courses. Where necessary, contaminated land should be remediated, and the appropriate types and locations of lighting should be used, so as not to give rise to unnecessary light pollution, particularly in rural areas.

7.8 Noise pollution can have a significant impact on the quality of life and health of individuals and communities. To help avoid adverse noise impacts from development, authorities in East and West Sussex have produced a Planning Guidance Document on this issue. Applicants should therefore address the issues raised in this document prior to making an application.

7.9 The air quality in Horsham District is of particular concern, and can lead to a number of health problems, including cardiovascular and respiratory diseases.  When air quality falls below certain thresholds, councils must declare an Air Quality Management Area (AQMA) and prepare an Air Quality Action Plan to address the air quality issues in this area.  Two AQMAs have been declared in the District, in Storrington and Cowfold, both due to the exceedance of the annual mean objective for nitrogen dioxide. Therefore, development proposals should give particular consideration to their impact on air quality and the detail of this is provided in a revised planning policy. 

Policy 25 - Strategic Policy: Environmental Protection

The high quality of the District's environment will be protected through the planning process and the provision of local guidance documents. Taking into account any relevant Planning Guidance Documents, developments will be expected to minimise exposure to, and the emission of, pollutants including noise, odour, vibration, air and light pollution arising from all stages of development. Development proposals must ensure that they:
  1. Address land contamination by promoting the appropriate re-use of sites and requiring the delivery of appropriate remediation. Proposals where contamination is known or suspected, or the site is within the vicinity of contaminated land, must be accompanied by a Land Contamination Assessment;
  2. Are appropriate to their location, taking account of ground conditions and land instability;
  3. Maintain or improve the environmental quality of any watercourses, groundwater and drinking water supplies, and prevent contaminated run-off to surface water sewers; 
  4. Minimise the impact of lighting on neighbouring uses and the wider landscape, including potential glare and spillage. Proposals where illumination is to be installed must be accompanied by a Lighting Assessment;
  5. Demonstrate that users of residential and other noise sensitive development will not be exposed to unacceptable noise disturbance from existing or future users.  Development proposals which are known or suspected to be noise generators, or to be sensitive to noise from nearby sites, must be accompanied by a Noise Assessment; 
  6. Minimise the air pollution and greenhouse gas emissions in order to protect human health and the environment;
  7. Contribute to the implementation of local Air Quality Action Plans and do not conflict with is objectives;
  8. Maintain or reduce the number of people exposed to poor air quality including odour. Consideration should be given to development that will result in new public exposure, particularly where vulnerable people (e.g. the elderly, care homes or schools) would be exposed to the areas of poor air quality; and
  9. Ensure that the cumulative impact of all relevant committed developments is appropriately assessed.

7.10 Proposals for new development within the vicinity of an existing business or community facility where it is considered that the current use could have a significant adverse environment impact on the new development, will not be supported unless it can be demonstrated that suitable mitigation will be implemented prior to the occupation or use of the new proposal.

Policy 26 - Air Quality

Air Quality

7.11 The main source of air pollution in Horsham District is from vehicle emissions, although emissions from households including open fires also contribute.  The existing areas of poor air quality, together with the potential for traffic increases arising from new development across the District have led the Council taking the decision to declare the whole of the District an 'Emission Reduction Area'.  Therefore all developments in Horsham District must be appropriate to their location, taking account of the likely effects of air pollution on health, living conditions and the natural environment and make reasonable endeavours to minimise emissions, and where necessary, offset the impact of that development on the environment.  

7.12 The Council, along with other local authorities located in West and East Sussex, is a member of the Sussex Air Quality Partnership, which seeks to ensure that a consistent approach is taken towards the management of air pollution.  They have produced guidance 'Air Quality and Emissions Mitigation Guidance for Sussex (2019)' which outlines the steps required to assess and mitigate the impact that new developments may have on local air quality for a number of air pollutants.  

7.13 The mechanisms for calculating the additional transport emissions associated with development and the method for determining the estimated monetary value of damage from proposed development caused by pollutants PM and NOx is set out in The Air Quality and Emissions Mitigation Guidance for Sussex (2019).

7.14 It should be noted that the design and layout of development can help to offset air quality impacts, and this should include the preservation and enhancement of green infrastructure - green spaces and woodland can help to offset the impacts of adverse air quality.

7.15 Applicants will be expected to refer to this guidance, or any future updates, screening checklist and where appropriate, enter into pre-application discussions with the Council's Air Quality Officer, to discuss site-specific considerations. 

Policy 26 - Air Quality

The Council recognises the importance of the management of air quality. Taking into account any relevant Planning Guidance Documents, proposals will be required to:
  1. Take account of The Air Quality and Emissions Mitigation Guidance for Sussex (2019), or any future updates. Major development proposals and proposals within an Air Quality Management Area (AQMA), or in relevant proximity to an AQMA, must be accompanied by an Air Quality Impact Assessment and an Emissions Mitigation Assessment;
  2. Contribute to the implementation of local Air Quality Action Plans, and not conflict with the set objectives;
  3. Minimise traffic generation and congestion through access to sustainable transport modes, maximising the provision for cycling and pedestrian facilities;
  4. Encourage the use of cleaner transport fuels, including through the provision of electric car charging points;
  5. Mitigate the impact on the amenities of users of the site and surrounding land to an appropriate level, where development creates or results in pollution including particulates, dust, smoke, pollutant gases or odour; and
  6. Ensure that the cumulative impact of all relevant committed developments is appropriately assessed.

Strategic Policy 27 - The Natural Environment and Landscape Character

7.16 The Council is seeking to maintain and where appropriate enhance the beauty and amenity of both the natural and built-up areas of the District. The potential for development to result in small changes that cumulatively impact on landscape, settlement character and the natural environment will be a key consideration, particularly in terms of the impact on smaller scale and local features. In addition to the protected landscapes, as shown on the Policies Map, Neighbourhood Plans and other development proposals will need to demonstrate that proposals conserve and enhance the character of the District as identified in documents such as the Horsham District Landscape Character Assessment 2003, Proposals should also demonstrate that development is located in areas with the greatest landscape capacity to accommodate development, as indicated in the Landscape Capacity Assessment 2019, or another subsequent updates to this documentation. Where appropriate, local green space designations may also have a role in conserving and enhancing the District, where it can be demonstrated that they are special to the local community in accordance with national guidance.

7.17 Consideration of the townscape character of settlements will be informed by broad based studies of historic character, Conservation Area Appraisals, Village or Parish Design Statements and any emerging Neighbourhood Plans. Maintenance of the existing settlement pattern is a key objective for the Council, and in particular maintaining the separation between settlements (see Policy 29 Settlement Coalescence).

7.18 Neighbourhood Plans and development proposals will need to demonstrate that proposals contribute to the multi-functional network of green spaces, water and other environmental features in urban and rural areas known as Green Infrastructure. Green Infrastructure includes trees, parks, road verges, allotments, cemeteries, woodlands, rivers and wetlands. The Council's Green Infrastructure Strategy identifies current and potential future provision of Green Infrastructure. This includes the opportunity to enhance existing biodiversity in identified opportunity areas. There is an expectation that there will be net gains to biodiversity, and Neighbourhood Plans and development proposals will also be required to demonstrate that existing biodiversity is protected and enhanced, including the hierarchy of designated sites indicated on the proposals maps and where necessary, demonstrate the requirements of the Habitats Regulations have been met.  In addition to the identified Green Infrastructure, a strategic scale Nature Recovery Network is being developed in partnership with organisations such as the Sussex Wildlife Trust, and towards which future development will be expected to contribute. The provision of Sustainable Urban Drainage Systems (SUDS) is expected to be given early consideration, and incorporated into development proposals at the outset, taking account of issues relating to their management, long term adoption and maintenance, and to enhancing the landscape

7.19 Whilst it is recognised that the undeveloped nature of rural areas must be protected, it is acknowledged that there may be circumstances where development is necessary to ensure the continued sustainable development of rural areas, including where it is necessary to retain farms and facilitate efficient sustainable farming operations. It might also include redevelopment of rural brownfield sites, which is required to sustain social and economic needs of rural communities, such as business uses, community, leisure, cultural and tourism facilities, or necessary upgrades to infrastructure, such as water supplies, or high speed broadband and renewable energy.   

7.20 In addition to this policy, applicants should also take account of Policies 25 Environmental Protection, Policy 30 - Protected Landscapes, and Policy 31 Green Infrastructure and Biodiversity when considering environmental and landscape impacts of their development. 


Strategic Policy 27 - The Natural Environment and Landscape Character

The Natural Environment and landscape character of the District, including the landscape, landform and development pattern, together with protected landscapes and habitats, will be protected against inappropriate development. The Council will expect development proposals to be landscape led from the outset so that they clearly inform the design and layout.  Proposals will also be required to:
  1. Protect, conserve and enhance the landscape and townscape character, taking into account areas identified as being of landscape importance, the individual settlement characteristics, and maintain settlement separation;
  2. Maintain and enhance the Green Infrastructure Network, the Nature Recovery Network and, where practicable, help to address any identified deficiencies in the District;
  3. Maintain and enhance the existing network of geological sites and biodiversity, including safeguarding existing designated sites and species, and  secure net gains in biodiversity;
  4. Incorporate SUDS into a scheme in an optimal location for their purpose whilst also securing landscape enhancements and good quality spaces.  Proposals will be expected to provide details to demonstrate that the whole life management and maintenance of the SUDS are appropriate, deliverable and will not cause harm to the natural environment and/or landscape; and
  5. Where applicable, conserve and, where possible, enhance the setting of the South Downs National Park and the High Weald Area of Outstanding Natural Beauty.

Strategic Policy 28 - Countryside Protection

7.21 Horsham District covers a large area and contains a diverse range of characteristics, from the heavily wooded character in the north, to more open river floodplains in the south. The Council is seeking to identify the most valued parts of the District for protection, and to maintain and enhance this natural beauty and the amenity of the District's countryside. It is considered important that the unique characteristics of the District's landscapes are retained and where practicable, enhanced. It will be necessary to ensure that development proposals take into account the key characteristics of the landscape character areas.

7.22 It is recognised that as part of the requirement to deliver a step change in housing growth, the Council may need to consider the allocation of urban extensions or a new settlement as part of a genuinely plan-led approach. Should such an approach be taken, these areas will have a designated settlement boundary. Areas outside any new allocations or other designated settlement boundaries will be expected to be retain their predominantly rural character. However, it is important not to unduly restrict rural communities and to maintain some flexibility to enable organic growth of existing appropriately located enterprises such as rural businesses, rural housing exception sites and rural workers’ accommodation.  

7.23 For the purposes of this policy, sustainable development of rural areas includes the diversification of activities on existing farm units which facilitate and do not prejudice the agricultural use. It also includes the suitably scaled expansion of existing appropriately located uses (premises and/or site) and the re-use/redevelopment of brownfield sites for equestrian, business or tourism use. The policy enables appropriate regard to be given to new development often located within the countryside such as equestrian facilities / stables; small scale camping facilities especially where linked to existing premises; green energy generating facilities ancillary to an existing premises or demonstrated to be of Regional or wider importance; and petrol filling stations located on an 'A' road. Where appropriate, the Council may seek evidence as to why a proposed use cannot be located within a built-up area boundary. 

Strategic Policy 28: Countryside Protection

  1. Outside built-up area boundaries and unclassified settlements, the rural character and undeveloped nature of the countryside will be protected against inappropriate development. Any proposal must be essential to and justify its countryside location, and must meet one of the following criteria:
    1. Support the needs of agriculture or forestry
    2. Enable the extraction of minerals or the disposal of waste;
    3. Provide for quiet informal recreational use; or
    4. Enable the sustainable development of rural areas.  
  1. In addition, all proposals must be appropriately integrated within the landscape and be of a scale appropriate to its countryside character and location. Development will be considered acceptable where it does not lead, either individually or cumulatively, to a significant increase in the overall level of activity in the countryside, and protects, conserves, and seeks to enhance, the key features and characteristics of the landscape character area in which it is located, including;
    1. The development pattern of the area, its historical and ecological qualities, tranquillity and sensitivity to change;
    2. The pattern of woodlands, fields, hedgerows, trees, waterbodies and other features; and
    3. The landform of the area; and
    4. Where relevant, the designated South Downs National Park 'International Dark Sky Reserve' (IDSR).

Strategic Policy 29 - Settlement Coalescence (Key Questions)

7.24 Horsham District is characterised by rural countryside interspersed with a network of market towns, villages and small hamlets. There is a need to retain the network of rural settlements and their separate identities, and it is important to contain the rural settlements and retain the sense of leaving one place and arriving at another. There are places where further development in the gap between settlements would result in the areas joining and losing their own individual sense of place. Even where there is countryside between settlements, the presence of buildings, signs and other development along roads prevents the sense of leaving a settlement and passing through the countryside. At night, various forms of artificial lighting can also lead to a sense of continuous urbanisation. A particular example is the A264 between north eastern edge of Horsham and Crawley. Other communities in the district have raised concerns about the potential for other settlements to merge, including Southwater and Horsham, and West Chiltington Common with West Chiltington Village.

7.25 Whilst the existing situation cannot be addressed by planning policy, further urbanisation can be resisted. This policy will ensure that settlements retain their unique identity and the undeveloped nature of the landscape between towns and villages will be retained. The Council will consider how proposals fit within the wider topography and whether landscape features such as the network of fields, trees and hedgerows are conserved, and therefore maintain the break between settlements. We will also seek to limit other urbanising impacts including increased lighting, traffic movements and ribbon development along road corridors. It should be noted that this policy applies to all settlements, but particular regard to the policy criteria will be given when considering proposals located between Horsham and Crawley, Southwater and Horsham, or West Chiltington Common and West Chiltington Village.

7.26 It is recognised that a number of proposals have been submitted to the Council for consideration as locations for strategic housing growth. A number of these are in the key locations which have been identified as being most sensitive for their potential for settlement coalescence. Whilst no final decisions have been made as to whether these sites should be allocated, the sites are in locations where there has been sustained pressure for development. Paragraph 72 e of the National Planning Policy Framework states that when identifying suitable and sustainable locations for development they should consider whether it is appropriate to establish Green Belt around or adjoining new developments of a significant size.   Therefore, as part of our consideration of these sites, will look at whether any locations in the District meet the criteria for Green Belt designation, which are set out in paragraph 135 of the NPPF. Any proposals would require the Council to:

  1. demonstrate why normal planning and development management policies would not be adequate;
  2. set out whether any major changes in circumstances have made the adoption of this exceptional measure necessary;
  3. show what the consequences of the proposal would be for sustainable development;
  4. demonstrate the necessity for the Green Belt and its consistency with strategic policies for adjoining areas; and
  5. show how the Green Belt would meet the other objectives of the Framework.

Future Green Belt Designation 

  • Do you agree that we should consider whether the designation of Green Belt may be appropriate in this District?
  • Do you have any suggestions for the sites or locations which may be appropriate for designation?
  • Why do you consider that the land you have suggested meets the NPPF criteria as set out in paragraph 7.26?
Policy 29 - Strategic Policy: Settlement Coalescence
  1. Landscapes will be protected from development which would result in the coalescence of settlements in order to protect local identity and a sense of place.  Development between settlements will be resisted unless it can be demonstrated that: 
    1. There is no significant reduction in the openness and 'break' between settlements;
    2. It does not generate urbanising effects within the retained 'break' between settlements, including artificial lighting, development along and/or the widening of the roads between the settlements; and increased traffic movements.
    3. Proposals respect the landscape and contribute to the enhancement of their countryside setting, including, where appropriate, enhancements to the Green Infrastructure network, the Nature Recovery Network and/or provide opportunities for quiet informal countryside recreation.
  2. Redevelopment of existing sites that seek to reduce the existing urbanised character and appearance of an area between settlements, particularly along road corridors, will be supported.

Strategic Policy 30 - Protected Landscapes

7.27 Designated for their national importance in terms of landscape and scenic quality, sections of both High Weald Area of Outstanding Natural Beauty (AONB) and the South Downs National Park fall within the administrative area of Horsham District. The South Downs National Park Authority is the Planning Authority for the National Park Area, including the area within Horsham District. This policy, in common with all others in this plan does not therefore apply to the land within the National Park Area, however, appropriate regard should be given in respect of land within its setting.

7.28 It is essential that the key qualities of these protected landscapes are conserved and enhanced. In the AONB, this includes the heavily wooded character, gill streams and historic farmsteads and into the locally distinctive hammer ponds whereas a key feature of the South Downs are the steep scarp slopes which form a backdrop to many of the settlements in the south of the district. The conservation and enhancement of protected landscapes will be actively supported, particularly as defined in the High Weald AONB Management Plan and the South Downs Integrated Landscape Character Assessment or any other relevant updates to these documents.

7.29 Development has the potential to harm protected landscapes. Major development within the AONB will not normally be permitted, and will need to demonstrate that the need for development cannot be met elsewhere or in another way, and that the development is in the public interest. It is however acknowledged that protected landscapes need to be able to adapt to cope with new pressures and meet the needs of residents in the area, and there may be cases where small scale development that helps to maintain economic or social well-being in or adjoining these landscapes is necessary.

7.30 Development close to the edge of both the AONB and the South Downs National Park has the potential to have adverse impacts on the qualities of these landscapes, and applicants will need to be mindful of this in relation to any proposals close to the boundary of either of these protected landscapes.

Policy 30 - Strategic Policy: Protected Landscapes
  1. The natural beauty and public enjoyment of the High Weald AONB and the adjoining South Downs National Park will be conserved and enhanced and opportunities for the understanding and enjoyment of their special qualities will be promoted. Development proposals will be supported within the High Weald AONB and in the setting of protected landscapes where it can be demonstrated that there will be no adverse impacts to the natural beauty and public enjoyment of these landscapes as well as any relevant cross boundary linkages. 
  2. Proposals should have regard to any management plans for these areas and must demonstrate:
    1. How the key landscape features or components of natural beauty will be conserved and enhanced. This includes having appropriate regard to 'dark skies', and maintaining local distinctiveness, sense of place and setting of the protected landscapes, and if necessary providing mitigation or compensation measures;
    2. How the public enjoyment of these landscapes will be retained; and
    3. How the proposal supports the economy of the protected landscape and will contribute to the social wellbeing of the population who live and work in these areas.
  3. In the case of major development proposals in or adjoining protected areas, applicants will also be required to demonstrate why the proposal is in the public interest and what alternatives to the scheme have been considered.

Strategic Policy 31 - Green Infrastructure and Biodiversity

Green Infrastructure

7.31 Green Infrastructure is a term used to describe a multi-functional and connected network of green spaces, water and other environmental features in urban and rural areas. It includes trees, parks, road verges, allotments, cemeteries, woodlands, rivers and wetlands. Green Infrastructure can contribute to the provision of 'ecosystem services'. This includes flood protection, water purification, carbon storage, land for food production, places for recreation, landscape and nature conservation. Without these services, life as we know it would not be possible, and increased flooding or drought episodes would have severe economic consequences.

7.32 The Council has identified the key strategic Green Infrastructure Assets and opportunities in the District. In addition to existing features such as woodland and rivers, there are also new opportunity areas where new elements of green infrastructure could be provided in the future. It is important to note that Green Infrastructure extends beyond Council boundaries - the Downs Link for example extends north to Guildford and south to Shoreham-by-Sea. Green Infrastructure also exists at a smaller scale, in towns, villages and neighbourhoods. New development can also provide new green infrastructure, such as sustainable drainage systems that can also be used as green spaces, or by providing new recreation routes that are planted to benefit biodiversity.

7.33 The network of Green Infrastructure within the District must be maintained and enhanced. Further detail on the precise location of the strategic Green Infrastructure assets is available in our Green Infrastructure Strategy documentation. Applicants will also need to be mindful of other policies in this document and any future revisions. 

7.34 In addition to the identified Green Infrastructure, a strategic level Nature Recovery Network is being established to which the Green Infrastructure network will contribute.  The Nature Recovery Network will be informed by the five year ‘Wilder Horsham District’ partnership between the District Council and the Sussex Wildlife Trust approved on the 28 November 2019.  Nationally, 41% of UK species’ populations have reduced since the 1970s, and 15% of wildlife species are estimated to be under threat of extinction.  The partnership aims to reverse the decline in species and habitats and to contribute to tackling and reducing the impacts of climate change.  The partnership seeks to take a landscape approach to overcome fragmentation and build landscape resilience to help ensure wildlife can move around, and to build a legacy so the work to reverse the decline continues beyond the life of the partnership.  It will initially focus on the following landscapes and areas but this focus may change to take into account work by the Sussex Nature Partnership. Development proposals should therefore consider how they can contribute towards to the following:

  1. Hedgerows in the Low Weald (providing important connectivity between fragmented habitats)
  2. Woodland – new planting and allowing natural regeneration, important tools in capturing more carbon and helping wildlife
  3. The Adur catchment; improve freshwater and floodplain habitats, water quality and flood resilience through working with natural processes
  4. Join up key sites, such as the Knepp Estate with the woodland to the north-east of Horsham town and The Mens in the west of the District, creating the core of a District wide ecological network.
  5. Take action to support pollinating insects throughout the district, in both towns and rural areas.


7.35  A key element of Green Infrastructure is retaining a rich biodiversity network.  The nature of the habitats and species found across the District is very varied, but key characteristics include the network of woodland habitats, which is particularly dense in the north of the District. Much of this woodland has been present since at least 1600. Designated as ancient woodland, these areas are of particular importance to wildlife and are irreplaceable. As identified by the Local Economic Partnership, woodland has the potential to play a key economic role in the District in the future, providing a low carbon fuel source and biodiversity benefits. Another key habitat in the District is the dense network of hedgerows, which support a range of wildlife and act as corridors, linking wildlife habitats within the District. The floodplains of the Arun and Adur are also distinctive habitats within the District, and the Arun Valley is of both national and international importance for nature conservation. Farmland is another key habitat across the District, and the south-west of the District provides an important feeding ground for the internationally important Barbastelle bats.

7.36 Development has the potential to harm biodiversity both directly and indirectly. Direct effects include loss of land to new development, whereas indirect effects include increased traffic resulting in a decline in air quality, which can impact habitats and species some distance from a development site. Development does however have potential to create places for biodiversity, for example by maintaining existing and planting native species as part of site landscaping, or incorporating features such as bat and bird boxes, hedgehog accessible ‘boundary gaps’, and green roofs/walls which provide better insulation and help to reduce surface water run-off.

7.37 This policy seeks to secure a 10% net gain in biodiversity, as a minimum.  The Policies Map shows the location of key nature conservation sites and further information regarding the location of areas with potential for enhancing biodiversity (biodiversity opportunity areas) is available in the Council's Green Infrastructure Strategy and the Sussex Biodiversity Action Plan. Further information on habitats and species that have been recorded in the District is available from the Sussex Biodiversity Record Centre.

7.38 Development proposals must provide sufficient information to assess the effects of development on biodiversity, and should provide any necessary ecological / geodiversity surveys and reports. These should include any proposed prevention, mitigation or compensation measures. Reports should include evidence that they have followed the mitigation hierarchy set out in BS42020, which seeks as a preference to avoid impacts, then to mitigate unavoidable impacts, and, as a last resort, to compensate for unavoidable residual impacts that remain after avoidance and mitigation measures.

7.39 Appropriate regard should be given to current and historical data, regeneration / re-population potential, species’ adaptability to climate change, irreplaceability of habitats, the significance of the site for the connectivity of habitats and species, and, where possible an assessment of ‘natural capital’. All development proposals should seek to enhance biodiversity through a range of measures, including enhancements either on or off the site, and provide buffer strips around protected sites, including Ancient Woodland and other vulnerable habitats, and maintain, reinstate and enhance wildlife corridors. Applicants will also need to be mindful of the presence of any invasive species on the site and seek to remove these in accordance with any relevant legislation.

7.40 Although located in the South Downs National Park, applicants will need to be particularly mindful of the impact development within Horsham District could have on Arun Valley Special Protection Area (SPA) and The Mens Special Area for Conservation (SAC). Both these sites are of international importance for nature conservation, and applicants will need to demonstrate that development does not have adverse impacts on either of these sites in accordance with relevant legislation. In the case of Arun Valley, proposals must demonstrate that they will avoid harm to the water quality and water levels on site. In the case of The Mens, development must not impact on bat flight paths in the District. As recommended in the Habitat Regulations Assessment of this plan, a 'bat sustenance zone' has been identified and is shown on the Policies Map. Within this area, it may be necessary for compensatory measures such as hedgerow enhancement to be undertaken prior to any development. This will also contribute to the establishing the Nature Recovery Network. 

7.41 In addition to the wider importance of woodland and Ancient Woodland identified above, individual trees, including 'veteran trees' are also important contributors to the character and biodiversity of the District, and many are protected by Tree Preservation Orders. Traditional orchards are also important for biodiversity. It should be recognised that it may sometimes be necessary to undertake work on or fell protected trees (e.g. due to disease or storm damage). Applicants wishing to undertake work on protected trees are advised to consult the available Government Guidance on this issue. Where replacement planting is required, replanting with native species will be encouraged to ensure that ecological networks remain functional and to prevent the isolation of trees and woodland in the landscape.

7.42 In general, the Council will support new development which retains and /or enhances significant features of nature conservation on development sites, and that brings forward 10% biodiversity net gain.  In addition to supporting development which makes a positive contribution to biodiversity, support will be given for landscape scale enhancements through the Nature Recovery Network, through the creation of green spaces, and linkages between habitats to create local and regional ecological networks. This will not only increase populations of species and the different types of species but also ensure that wildlife is more resilient to change.

Policy 31 - Strategic Policy: Green Infrastructure and Biodiversity
  1. Development will be supported where it can demonstrate that it maintains and enhances the existing network of green infrastructure, the Nature Recovery Network, natural capital and biodiversity. Proposals that would result in the loss of existing green infrastructure or part of the Nature Recovery Network will be resisted unless it can be demonstrated that new opportunities will be provided that mitigates or compensates for this loss, and ensures that the ecosystem services of the area are retained.
  2. Proposals will be expected to retain and enhance existing fresh water features, hedgerows, trees and deciduous woodland and the provision of additional hedgerow and tree planting will be sought subject to appropriate consideration of local and wider context, habitats and species.
  3. Where the felling of a tree is necessary, for example due to disease, replacement planting with a suitable species and location to retain the link with the wider network of habitats and Green Infrastructure, will be required.
  4. Development proposals will be expected to remove invasive species and will be required to contribute to the enhancement of existing biodiversity and deliver, as a minimum, a 10% net gain through the delivery of appropriate on-site biodiversity net gain or, where this is not practicable, to off-set the delivery to the Nature Recovery Network.
  5. Proposals should create and manage appropriate new habitats, taking into account pollination, where practicable. The Council will support new development which retains and /or enhances significant features of nature conservation on development sites. The Council will also support development which makes a positive contribution to biodiversity, and where appropriate the Nature Recovery Network, through the creation of green spaces, and linkages between habitats to create local and regional ecological networks and allow the movement of wildlife through development sites.
  6. Particular consideration will be given to the hierarchy of sites and habitats in the District as follows:
    1. Special Protection Area (SPA) and Special Areas of Conservation (SAC)
    2. Sites of Special Scientific Interest (SSSI) and National Nature Reserves (NNRs)
    3. Local Wildlife Sites (LWS), Local Nature Reserves (LNRs) and any areas of Ancient Woodland, traditional orchards, local geodiversity or other irreplaceable habitats not already identified in a & b above.
  7.   Where development is anticipated to have a direct or indirect adverse impact on  sites or features of importance to nature conservation, development will be refused unless it can be demonstrated that:
    1. The objectives of a site’s designation, where applicable, and integrity of the area will not be undermined;
    2. The reason for the development clearly outweighs the need to protect the value of the site; and,
    3. That appropriate mitigation and compensation measures are provided.
  8. Any development with the potential to impact Arun Valley SPA or the Mens SAC will be subject to a Habitats Regulation Assessment to determine the need for an Appropriate Assessment. In addition, development will be required to be in accordance with the necessary mitigation measures for development set out in the HRA of this plan.

Policy 32 - Local Greenspace

7.43 Local Green Space provides a wide range of social, health and environmental benefits and are a vital component of the District's green infrastructure.  The purpose of local green spaces is to protect green areas of particular importance to local communities and provide special protection.  Although individual spaces may not provide the strategic functions of a designation such as Green Belt, they are nonetheless important at a neighbourhood level and should be protected because of their special value to the local community.

7.44 The NPPF ‘presumption in favour of sustainable development’ does not apply to designated local green spaces.  However, national policy is clear that designation of local green space should be consistent with the wider planning policy for the area.  Proposals affecting the designated Local Green Space should be consistent with national Green Belt Policy.

Policy 32 - Local Green Space
  1. Local green and open space should be protected. Areas designated as local green spaces, as identified on the Policies Map, will be safeguarded from development unless it can be demonstrated that:
    1. Development is proposed to enhance Local Green Space functions, for example, through improvements to access, recreation and wildlife; or
    2. Required for a statutory utility infrastructure purpose, for example, water, gas, electricity or telecommunications provider.
  2. The creation of new areas of publicly-accessible green space should be supported and allocated through Neighbourhood Plans, providing it is within reasonably close proximity to the community it serves, is local in character and is not an extensive track of land.  It must also meet the relevant criteria in relation to scale, beauty, historic significance, recreational value, tranquillity and ecological value and does not conflict with the strategic policies of this Local Plan.


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