Publication

As a result of the above it is not considered that this part of the plan is sound. The plan does not appear to have properly considered reasonable alternatives and there are inconsistences in the evidence as with regards to the scale of development actually being considered and the failure to reconsider the access requirements based on a reduced scale of development.
The proposal has failed to assess the impact of the development on the landscape setting of Horsham St Faith and has failed to consider the significant amenity issues associated with locating a site immediately opposite an existing B1 and B2 Industrial Estate which is proposed for significant expansion. The proposal is also clearly no consistent with the advice contained at Paragraph 182 of the National Planning Policy Framework.
If the plan is to be made sound the proposed site allocation should be properly assessed having full regard to the issues raised in Section 5.

In relation to the allocation Policy GNLP0125R Land to the west of West Lane, Horsham St Faith there are clear inconsistencies between the comments made in the supporting text to Policy GNLP0125R that “More homes may be accommodated, subject to an acceptable design and
layout, as well as infrastructure constraints” and Paragraph 6.70 of the plan which states that “It is considered that aswell as existing allocations andwindfall development, approximately 20-50 new homes are appropriate for the Horsham St Faith cluster. Horsham St Faith and Newton St Faith contains a range of services including a primary school, village hall, food shop and public transport". No justification has beenmade as to how and why this allocation has been increased from20-30 dwellings in theRegulation 18 plan to 50+ in the current consultation, especially in view of the comments made at paragraph 6.70.
The proposed allocation represents part of an existing agricultural field and has no defensible boundaries and will represent an uncontrolled expansion into the open countryside. The accompanying text to Policy GNLP0125R surprisingly includes no commentary regarding the need to provide landscaping to soften the impact of the proposal and prevent unrestricted encroachment into the open countryside. This is of particular importance as the site has been promoted on the basis of circa 400 dwellings. The approach being taken by the Council will open this site up to future expansion. As a consequence of the landscape impacts this should score amber in the Stage 2 HELAA comparison table.

There are also other sites submitted via the Regulation 18 call for sites that could provide circa 30 dwellings which would have less impact on both the townscape and landscape, for example GNLP1054 which represents infill development, within an otherwise built-up frontage and defensible boundaries.
The GNLP0125R site is also immediately adjacent to an industrial estate and no issues have been raised with regards to noise and nuisance and the impact that new housing could potentially have on the operation of the existing and extended industrial estate. The potential adverse impacts on amenity are confirmed by Policy SL2007/GNLP406/HNF3 which is proposing a 4.39ha allocation for B2 and B8 uses. There is scant evidence that the impact of this B2/B8 allocation has been considered in the allocation of GNLP0125R. It is apparent that this allocation is also contrary to the advice contained at paragraph 182 of the National Planning Policy Framework. Whilst this aspect of the allocation scores amber on the HELAA table it is contended that this should score red.
The potential impacts on a Grade 1 Listed Church, the scheduled monument St Faith Priory and the Conservation Area are noted. However, these are not considered by the Council to be an impediment to development. This is rather a perverse view when sites with a less harmful relationship have been rejected, for example GNLP1054. Due to the concerns raised it is questioned as to whether this aspect should have scored red in the Stage 2 – HELAA Comparison Table.
The assessment regarding Transport & Roads is also perverse with this being assessed as green. The accompanying text to Policy GNLP0125R states that “the scheme will need to provide frontage footways, carriageway widening, implementation of improvements required to the walking to school route including junctions on route and the provision of two vehicular accesses” The HELAA Conclusion also states that “subject to suitable footpath provision, any potential impact on the functioning of local roads could be reasonably mitigated”. The level of works required is considerable and the Transport and Road impacts should be amber.
The requirement for two accesses also raises queries as to the actual scale of development which will eventually be provided with circa 125 dwellings being able to be provided from a single access point and no justification or evidence has been provided as to why two points of vehicular access are required. The two access points appears to have stemmed from the initial proposal for 400 dwellings and shows that the policy has not been reviewed to reflect the reduced scale of development.
In view of the above there are questions as to whether the plan has been positively prepared. There are also questions as to the robustness of the assessment given to this site.

The rejection of the site GNLP1054 has not been justified and the basis of rejecting the site is based on out-of-date information and incorrect assumptions. This site needs to be properly assessed and the scorings revised before a proper and impartial assessment is made with regards to Policy GNLP0125R and GNLP1054. Following this assessment detailed justification should be made as to why GNLP125R is considered the optimum site despite the constraints associated with the site.

These representations have been prepared in relation to the Council’s assessment of the site GNLP1054 and will also include a comparison of this site with the site proposed for allocation GNLP0125R. These representations are also seeking to correct the inaccuracies in the assessment made by the Council, which despite being challenged in the Regulation 18 consultation and assessment have been repeated.
In the case of GNLP1054 as detailed on the plan accompanying these representations it comprises infill development on an otherwise built-up frontage. This is assisted by allocation Policy HNF1: Land east of Manor Road having been subject to an approval of planning permission for 69 dwellings. Construction of this development has recently commenced. This site (HNF1) is also committed to providing significant improvements to the footpath network from this site southwards to the Primary School. It is apparent that the Council saw HNF1 as a sustainable site when allocating it and subsequently granting planning permission.
Unlike GNLP0125R the majority of the works for a safe walking route to school are already approved. This site is 1.4km from the school which is within walking distance and unlike the site GNLP0125R, whilst only being circa 900m from the school requires numerous junction/road crossings to access the school. Therefore, there are questions as whether a safe route to school can be created and the impact the provision of this route will have on the viability of a development of 50 houses.
The Council are incorrect in the comments that they have made regarding the appeal against non-determination (APP/K2610/W/19/3226697). This appeal was dismissed on the basis that the site would have an adverse impact on heritage assets rather than on landscape or access issues. In relation to access the Inspector at paragraph 13 of his decision letter stated that “Whilst there seems no doubt that occupiers of these dwellings would be subject to some additional activity from the use of the road, I do not feel that it would be significantly different to that which they already experience from their dwelling fronting a main road and being set not overly far back from a busy arterial A road”. This is reinforced by paragraph 14 where it is stated that “With these factors in mind, I do not consider that the additional activity associated with the proposed development would, in context, give rise to an unacceptable impact on the living conditions of existing occupiers through noise disturbance”. Paragraph 26 advises that “From the evidence provided by the Council, the appellant and consultees it seems that the appeal scheme would be acceptable in terms of highway safety and the living conditions of future occupiers as well as considering matters of ecology, biodiversity, trees and drainage acceptability.

Continued on attachment.