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What The Experts Say…

A crucial stage in the local planning consultation process is the scrutiny of the application by subject matter experts.  Their assessments will help to inform the recommendation made by the Local Planners to the Council.  

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Read on for a summary of the concerns, objections and gaps in information that they raise about strain on services, the impact on wildlife and the landscape, and travel safety. 

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All the consultation responses are available for the public to see on the planning website (enter Consultation into the Search box on the right).  

education

Education

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Horsham District Council’s Strategic Sites Assessments

 

(horsham.gov.uk)

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Insufficient secondary education capacity exists currently to meet the needs of the development. 

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There would be limited ability for new school-age occupants to access existing schools by means other than private car, given their relatively large distance from the site. 

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WSCC Local Education Authority

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Secondary provision in Horsham District is unable to expand... there is not any capacity.

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Objection on the grounds of insufficient education infrastructure provision.  

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It is questionable if there are suitably safe walking and cycling routes to schools in the South of Horsham or in Southwater

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Health services

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NHS Sussex

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Infrastructure levels are below recommendations and there are pressures on all services. 

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The planning permission should not be granted without an appropriate (financial) contribution to local health infrastructure. Without associated infrastructure, NHS Sussex would be unable to sustain sufficient and safe services provided in the area and would therefore have to OBJECT to the development proposal.
 

health

Travel safety

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Horsham District Council’s Strategic Sites Assessments

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(horsham.gov.uk)

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It is considered very challenging to achieve direct, convenient, and attractive active travel routes to Horsham Town as the most direct route, the B2237 Worthing Road, is a constrained and heavily trafficked corridor with a single narrow footway (which alternates sides) for most of its length outside the built-up boundary, with limited scope to improve.    

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There are no significant proposals or opportunities to improve walking, wheeling and cycling to Horsham, given the constraints.  Therefore, a favourable active travel mode share is unlikely. 


WSCC Highways

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The most direct route (towards Horsham) is along the B2237 corridor. This constrained in width, limiting the ability of the applicant to implement any substantial improvements to the existing footway width or provision.  For cyclists, there are very limited improvement options available along the B2237.  This route is far from suitable to accommodate all users.

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Active Travel England

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Active Travel England’s formal recommendation: Refusal.

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The proposed routes for active travel to a range of key amenities are not suitable or attractive for general everyday use in terms of safety and personal security.

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The development will have a high reliance on motorised vehicles, even for short journeys.


Worthing Road is a single carriageway road with a 40mph speed limit and for the most part is tree-lined and lacks any active frontage. There are no crossing facilities where the footways change from the west side to the east side of the carriageway and collisions involving cyclists have been recorded along its length, notably at its junction with Tower Hill.  

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Eastern route the via Lovers’ Lane and Pedlar’s Way:  It is noted that this route is unsurfaced, unlit, has little natural surveillance … ATE does not consider this to be a feasible alternative to enable walking, wheeling and cycling journeys to and from the development.

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Access points for people walking, wheeling and cycling:  ATE does not consider any of these four access points to be suitable to serve the development.

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WSCC Local Education Authority

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It is questionable if there are suitably safe walking and cycling routes to schools in the south of Horsham or in Southwater.

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These schools are not nearby or conveniently located, being towards the maximum walking distance for the children and their parents to travel. For young families walking to school … in parts the pavements are quite narrow for pushchairs and adults and children walking two abreast.  

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Horsham Blueprint

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This route already suffers from congestion and is considered by many to be the most dangerous route into (Horsham) town for pedestrians and cyclists.

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From Forest Neighbourhood Council objection letter

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The narrow pavement along Worthing Road is only suitable for pedestrians walking in single file and is not suitable for prams or buggies.

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The developer’s aspiration to “promote active travel” and “discourage the use of private cars” is not feasible for families with pre-school and school-aged children.
 

travel

Water neutrality and flood risk

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Horsham District Council’s Strategic Sites Assessments

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(horsham.gov.uk)

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At this stage it cannot be concluded there will be no adverse impact on the Arun Valley.

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From HYDROGEOLOGICAL REVIEW OF WATER NEUTRALITY STATEMENT by H20GEO

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In summary, there is insufficient evidence to demonstrate that the scheme will be Water Neutral until investigation works have been completed and it’s demonstrated that the Upper Tunbridge Wells Sands aquifer can provide the yield required, sustainably and in perpetuity.

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WSCC Local Flood Authority

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The LLFA maintain our objection to this planning application in the absence of a satisfactory Flood Risk Assessment and Drainage Strategy. 

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Insufficient information for this Outline Application infers that flood risk may increase elsewhere, upstream, or downstream from the site.
 

water

Landscape

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Horsham District Council’s Strategic Sites Assessments

 

(horsham.gov.uk)

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The landscape in this area is predominantly rural in character and development of the site would cause landscape harm by reducing the separation and distinction between Horsham and Southwater and negatively impact upon the character of each settlement.  

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The development of this site could set precedent for further development in the future and further contribute to coalescence.

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The site is overall very rural in character and forms an important part of the visual separation between Horsham and Southwater. 

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The Landscape Capacity Study 2021 assesses the capacity of the landscape for both medium and large-scale housing as “no to low”.

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Horsham District Council’s Landscape Architect

 

(horsham.gov.uk)

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The proposals are considered to result in adverse impacts on the landscape character and visual amenity of the area.  For these reasons the proposal cannot be supported on landscape grounds.


The proposals are not deemed to be the right location for a large development such as this from a landscape perspective.

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A small section, in the northeast of the site closest to Denne House, falls within the Landscape Character Area 22, Denne Park. This area recognises that the key landscape features and qualities are highly sensitive to large scale development and that the historic importance of the landscape and its attractive parkland qualities mean that there is no capacity for large scale housing or employment development.

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The site fails the tests of the first part of Policy 26, lead to a significant increase in the overall level of activity in the countryside location and is of a scale which is not appropriate to its countryside character and location, also in conflict with part 2 of the policy.

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The introduction of residential development and other sport uses within the landscape will no doubt increase the overall levels of activity in the countryside location and overall tranquillity of the area, also amplified by the night time lighting glow inevitable as part of the introduction of the 800 new homes and sports activities.

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The character of the area would change from well wooded, contained, semi-rural and predominantly tranquil landscape, to a new urban setting.

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Southwater Parish Council

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The development area has not been allocated for housing development within the Southwater Neighbourhood Plan (SNP) being beyond the Built-Up Area Boundaries as defined by the SNP.


The proposed development also greatly exceeds the quantum of development the Southwater community accepted through the SNP, which allocated land for 422 - 450 new residential units at land west of Southwater.

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Council for the Protection of Rural England

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The application is also contrary to HDPF Policy 27 Strategic Policy: Settlement Coalescence because it would significantly reduce the openness and ‘break’ between Horsham and Southwater’s respective built-up area boundaries and generate urbanising effects within the gap including artificial lighting, development along a key road corridor, and resultant increase in traffic movements.

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The site is outside of Southwater’s built-up boundaries and is neither allocated in the HDPF, nor in Southwater’s Neighbourhood Plan.  The application, if permitted, would therefore undermine the spatial strategy for the district, which is predicated on planned expansion of existing settlements through the Local Plan or neighbourhood planning.

Horsham Blueprint

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Forest Neighbourhood Council

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The site is outside the built-up boundaries of both Horsham town and Southwater Parish, and lies within the green rural gap which is currently an area of ‘quiet recreational use’. It should be protected from inappropriate development.

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Biodiversity and wildlife

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Horsham District Council’s Strategic Sites Assessments

 

(horsham.gov.uk)

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Ancient woodland is located just beyond the north west boundary of the site and also close to the south east boundary.  There are a number of woodland corridors which are linked to these.  

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Impacts on this are possible which could potentially lead to a loss of important wildlife habitat.  

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The level of biodiversity net gain which could be delivered is unclear.  

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Place Services

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Great Crested Newts were recorded within six ponds in and around the site.  During construction there is the potential for impacts to GCNs as a result of reduction of total habitat … or indirect impacts such as pollution and contamination of water sources. 

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The major impact on the GCNs population as a result of the decrease in suitable habitat across the site and as a result of disturbance during construction would be direct and long term, resulting in a Major Adverse effect at the County level. This would be considered significant, and licence would be required to proceed.

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Council for the Protection of Rural England 

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Whether the proposed site supports wild birds listed as rare and most threatened species has not been determined because the application has been submitted without an onsite bird survey.

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Southwater Parish Council

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The proposal makes no consideration for tree planting in line with Southwater Neighbourhood Plan. These policies form part of the development plan and must not be ignored.

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Denne Neighbourhood Council

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The impact on the wildlife and environment by building 800 houses and concreting over acres of land, will be immeasurable. Protected and rare fauna and flora will be adversely affected, not only by the loss of their natural habitat but in the case of nocturnal wildlife by the effects of streetlights and floodlights.

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Horsham Blueprint

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The Environmental Survey undertaken as part of the planning process confirms four Red Listed Bat species and thriving colonies of Great Crested Newts in the network of ponds and culverts built across the old Denne estate. The applicant has dismissed these rare bats as merely “commuting into the site”. However, Denne Park’s Lime Avenue, planted in 1760, provide invaluable roost sites for the bats. The configuration of the two-storey driving range and hockey pitches would mean flood lights would be shining directly on to the bat roosts.

biodiversity

Loss of golf, amenities and green space

Southwater Parish Council

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The proposed development, by reason of the size and scale would have an urbanising influence in the countryside beyond Southwater resulting in harm to the countryside character of the area.  It is contrary to Policy 26 of the Horsham District Planning Framework (HDPF) which states that ‘proposals must be of a scale appropriate to its countryside character and location’.

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Horsham District Council’s Strategic Sites Assessments

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(horsham.gov.uk)

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The current evidence fails to clearly demonstrate that the existing golf course is surplus to requirements or that the “replacement” offer appropriately compensates for the significant loss of open space.

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There is a lack of evidence to demonstrate that the proposal can appropriately address the open space needs of the proposed housing or provide the number of new trees to accord with the Southwater Neighbourhood Plan.

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Homes England

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The Golf Needs Assessment is not sufficiently robust to assess the impact of the proposals on golf provision, to adequately consider the effect of the closure and subsequent reconfiguration, or that it adequately considers the combined effects in combination with the closure of Ifield Golf Club.

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Horsham Blueprint

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The replacement of the course by one of only 9 holes would be a very retrograde step, leading to displacement to other courses and, for example, unsustainable demand for tee times on the Rookwood course. 
 

golf
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