Storrington, Sullington and Washington Neighbourhood Plan

Storrington, Sullington and Washington Neighbourhood Plan

Health Check

June 2015

Andrew Ashcroft

Assistant Director – Economy, Environment and Culture

Herefordshire Council

Neighbourhood Plans Independent Examiner

Introduction

I was commissioned in June 2015 to carry out a health check of the evolving Storrington, Sullington and Washington Neighbourhood Plan (SSWNP). A revised pre-submission plan was published in April 2015.

This report sets out a series of findings and recommendations.

As part of the health check I have:

• Read the documents as provided to me by Horsham District Council
• Read the SSWNP
• Read its associated Sustainability Assessment/SEA
• Read key elements of the emerging Horsham Local Plan (HLP) and the interim findings of the Inspector (December 2014)
• Looked at certain sites on Google Maps to assist my understanding.

Structure of the Health check

This health check provides an overview of the emerging SSWNP and an assessment of its relationship to the basic conditions against which it will eventually be examined.

I have also looked at the wider package of documents and which include:

• The SEA/Sustainability Assessment
• The Site Assessment Report
• The Policies Maps

Overall Findings

The Plan is well-presented and constructive. It sets out a positive and in general terms a realistic basis for the future planning of the SSWNP area.It has been very positive in identifying opportunities for sustainable growth and is very clear about where this growth should take place. It is distinctive to the Plan area both generally, and in terms of how it promotes growth in particular.

The associated Strategic Environmental Assessment (SEA) has recently been expanded and has been linked with the preparation of the SSWNP itself. Following the commissioning of specialist advice by the South Downs National Park Authority there is an on-going debate on the extent to which the document has been prepared. I have made some observations on this matter in this health check.

The combined effect of these two related documents will givesignificant confidence in general terms to the appointed independent examiner that the submitted SSWNP meets the basic conditions for neighbourhood plan preparation. The remainder of this note sets out areas where the Plan could be improved. In particular it identifies areas where the plan could be made stronger and its linkages with the emerging SEA could be consolidated. It also identifies certain policies where the current drafting is unclear. The health check sets out to identify potential revisions to the Plan that would reduce the number of modifications that the independent examiner may be minded to make in order to ensure full conformity with the basic conditions. These revisions will provide an even stronger context for the future delivery of the Plan through its statutory processes

The Plan

In general the Plan reads well. It sets out a package of visions and objectives and is underpinned by a robust yet proportionate evidence base. To the non-local reader it succinctly sets out the parish profile and the strategic planning context. The remainder of this section highlights areas for refinement. In the majority of cases my comments raise issues around the clarity of the policies rather than the direction or purpose of the Plan itself. The underpinning philosophy of the plan is clear. In some cases that philosophy does not precisely translate into the relevant policies. In other cases it does so in a very prescriptive fashion and which may reduce the longer term flexibility that the Plan will need.

Policy 1 – A Spatial Plan

This policy sets an appropriate plan context. It properly sets out to concentrate development within and adjacent to the principal settlements covered by the Plan. The policy makes a distinction between the type and scale of development that would be granted planning permission in the three principal settlements and in the settlement boundary as defined at Old London Road. Paragraphs 4.16 and 4.17 provide a useful explanation of the different approach adopted. However the policy requires a reasonably detailed explanation of very small scale infill development. Otherwise an examiner may want to delete this element due to uncertainty (and therefore conflict with the NPPF). Given the clarity and appropriateness of the thought process in paragraph 4.16 it would be best to amend this section of the policy to replace very small with infill development of up to 5 dwellings. There is a possibility that an independent examiner may also consider that a maximum of five dwellings is too prescriptive. However given the nature of the settlement pattern within this boundary the identification of a maximum figure of five appears generous rather than prescriptive.

The final paragraph of the policy identifies the concept of ‘green gaps’. These gaps are not immediately obvious on the policies maps and I cannot find any reference to green gaps in the keys on these maps. The supporting text does not address the matter directly. This clarity will be required by land owners and the local planning authority in particular, and other interested parties in general.

In a broader sense the following issues also need to be clarified on green gaps:

• Why their identification/designation is necessary beyond national and local policies.
• The extent to which they overlap with identified Local Green Spaces (Policy 13).
• The extent to which Policy 13 would be insufficient to satisfy the spatial objective otherwise promoted through green gaps.

Policy 2 – Site Allocations

In principle this is a robust and appropriate policy. It underpins the scale and direction of growth in the Plan. It is a key success area of the Plan – nine housing/mixed use sites are identified and which are anticipated to yield approximately 300 dwellings. This is entirely the positive approach the government had in mind in promoting the introduction of neighbourhood planning.

I make a few general comments as follows:

• The letters (key to sites) are not easy to read on Inset maps 1-3. Sites B, E and F are particularly difficult to identify as a non-local person.
• It would help if there was a link made between the sites as listed in the policy and their reference keys on the policies maps.
• The scale of the maps does not readily identify the sites themselves. In some cases the sites are obvious (C/DG/). In others it is less obvious (see above). This is important given the significance of the SSWNP within the development plan framework and the engagement of developers and landowners. Ideally each site should have its own smaller scale plan clearly identifying its boundary.
• There may be merit in combining the allocation of each site directly with its supporting text. By way of example the Robell Way site would be immediately followed by paragraphs 4.22 to 4.24. To maintain your policy structure you could then have policy 2/A, policy 2/B etc. That said the existing arrangements are perfectly satisfactory if either time or your own preference does not support this proposed approach. In this plan context however the nine sites result in a position where each element of supporting text is some distance away in the document from the policy itself. This makes navigation and understanding lessthan clear for the reader.

I set out below some detailed comments on each of the nine sites.

Robell Way

This appears to be a good housing allocation. The potential conflict with Policy CP11 of the Horsham Core Strategy is addressed in paragraph 4.23. The policy would read better if the description included details of its size/yield as currently set out in criterion b of the policy

The first criterion is too restrictive in practical terms. In particular it is not clear about the scale and nature of the employment development required. Its link to Policy 4 is also loose given that the basis of that policy is a general supporting policy for employment development. Whilst other employment policies in the SSWNP are site-specific there is no reference to them in the policy. In any event the current wording of the policy simply requires the granting of planning permission for alternative employment development rather than its implementation.

In all the circumstances I would recommend the deletion of this criterion and for two principal reasons. The first is that paragraph 4.22 has already come to a judgement about its lack of long term effective use as an employment site. The second is that there are sufficient new employment opportunities identified in the Plan to mitigate against the harm that would be caused to Policy CP11 of the Core Strategy. These two factors are linked together by the practical inability to link the development of this site (one of the largest of the proposed housing sites) to the development of any specific employment site. In any event the text in paragraph 4.23 demonstrates the thinking of the plan makers and provides indicative guidance to those preparing employment proposals in the plan area.

In criterion b (or its associated paragraph 4.23) it would be helpful to clarify the reasoning behind the view that the site is suited to smaller homes (and then what constitutes a smaller home). By definition the planning system cannot specify that new homes should be exclusively or mainly available for first time buyers. This may well prove to be the case as sales of houses take place. However the houses on this or other sites may be purchased by a whole range of persons including older persons downsizing from larger houses. This aspect should be removed from the Plan.

I can understand the ambition set out in criterion d. However national policy is clear that new development should only be required to provide infrastructure based on the scale and nature of the scheme proposed. The criterion would read better as:

‘The scheme makes provision for an appropriately-sized area of public space and to include a multi-use games area.’

Paragraph 4.24 could then be amended to make reference to Horsham Council standards for open space and justify the local need for a multi-use games area

In criterion f there is little or no clarity on the long term ambitions for the amenity buffer. The first part of the criterion is appropriate (protection). The second part fail to provide clarity on the works that the developer would be required to undertake to ensure that it provides the effective amenity buffer sought.

I can again understand the ambition set out in criterion e. However there is no programme established for the development of the skate board park and I am uncertain on what basis planning permission would be refused for the development of this site if a contribution to a skate board park off site could not be achieved. I recommend that criterion e is deleted. In any event it is probable that a wider or more local application of CIL funding would underpin the implementation of the skate board park.

The Vineyard

This appears to be a positive housing allocation.

The description is specific about the development of primarily one/two bed starter houses. As with the Robell Way site a more detailed justification is required to give clarity to the Plan’s wider audience. Paragraph 4.25 almost certainly provides the answer/solution to this matter by making reference to the existing pattern of (residential) development. On this basis the detailed references to size of houses in the policy initial text could be removed and replaced with a third criterion to read

‘the scheme provides a proposal that complements the existing pattern of residential development off Old London Road and at a similar density’.

Old Ryecroft Allotments

Again this appears to be a good housing site

The same comments as the previous sites apply to this site on the size and scale of houses.

In criterion a the reference to Ryecroft Lane could be removed. It inappropriateness for access is adequately addressed in paragraph 4.26

Criterion c is entirely appropriate. However it would read better if its language overlapped with the Planning (Listed Buildings and Conservation Areas) Act 1990 as follows:

‘The scheme design will preserve or enhance the Storrington Conservation Area’

Amberley Rd

The same comments apply to house sizes. In this case further clarity would be helpful on the breakdown between 3 and 4 bedroom houses and the proportion of other dwellings. On the latter point it would be best to refer to the other houses as smaller houses 9that is less than 3 or 4 bedroom) rather than starter/low costs for reasons set out in the Robell Way section above

In criterion a the reference to Bax Close should be removed. It inappropriateness for access should then be addressed in paragraph 4.27

In criterion b the reference to the designation of the proposed open spaces as Local Green Space is best set out in supporting text rather than in the policy itself.

As currently drafted paragraph 4.27 reads somewhat negatively. Rather than set out the evolution of the site’s development since the recent refusal of planning permission it should set out the basis on which future proposals would achieve planning permission. By definition this is simply a change of emphasis in wording.

Criterion c needs to be stronger than merely requiring the scheme to ‘have regard’ to the national park designation. I recommend that the Plan is more prescriptive and that this criterion is redrafted to read:

‘The scheme design will sustain or enhance….’

Chantry Lane

Again this appears to be a sound allocation (in this case a combined residential/employment scheme).

Criteria a to d set out the proposed delivery/design of the scheme. Its logic is reasonable and by definition would generate sustainable development. However it is likely that its details will be scrutinised by an independent examiner for the following reasons:

• If the existing site is poorly located and poorly accessed for employment uses why is the site being promoted for an element of employment uses in the plan period?
• This is emphasised by the site not been identified as a key employment site in the development plan
• The justification underpinning the housing element being restricted to 50% of the site.
• The restrictions proposed on the occupation of the housing part of the site and its implications on viability and delivery (criterion d)
• The specific reference to start up business uses in criterion c

Paragraphs 4.29/4.30 do not directly address these points. In particular they do not address the general mix of uses on the wider site and the justification for preventing the full implementation/occupation of the housing part of the site before the completion of the adjoining employment scheme. Paragraph 4.30 recognises that the residential element of the proposal is likely to be a key element of enabling development. However as drafted the policy may undermine the effectiveness of an emerging or future package

On this basis I recommend that the policy is amended as follows:

• Remove criterion b. Address the ambitions for the scale of housing development and the size of houses in the supporting text
• Remove the final part of criterion c and replace with ‘….and will comprise a mix of unit sizes in business (B1) use’. This will not prevent start up uses being proposed.
• Remove criterion d. Address the ambitions for the relationship between housing and employment development in the supporting text. The supporting text could make specific reference to the need for a detailed section 106 agreement to be negotiated to address this issue at the time of the determination of the initial comprehensive planning application (and as supported by an overarching master plan).

As drafted the final criterion is probably too specific. It could be explained better in the supporting text. On this basis it could then be replaced with a new and shorter criterion as follows:

‘The scheme makes appropriate provision to mitigate its own off site traffic movements and those traffic movements in combination with those generated by the development of Chantry Mill Quarry’

Old Mill Drive

The earlier comments on house sizes on other sites apply equally to this policy.

The supporting text in paragraph 4.32 is very clear about the intention for retaining and safeguarding commercial uses in the vicinity. The policy is far less clear. This could be addressed by including a criterion to this effect.

Old Post Office

This policy reads well. I recommend that criterion b is amended along the lines I have suggested for the Old Ryecroft allotments site to use the terminology in the legislation.

Ravenscroft

Again this housing allocation appears to be sound. Its implementation is assisted as it is linked to the proposed development of allotments on the adjoining site (and as set out in Policy 11).It is on this basis that the restrictive nature of criterion a is acceptable in this case.

The comments on house sizes made elsewhere apply to criterion b in this policy. I assume that the intention is that this site yields similar affordable houses to those recently developed off Ravenscroft (4.34). If this is the case the policy should say so and the text set out the reasoning behind that policy approach.