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 Planning: letters of representation

March 2011 

16 March 2011


For the attention of Val Cheesman


Head of Development Control

Horsham District Council

Park North

North Street


RH12 1RL



Dear Sir


DC/11/0224  Land South of Athelstan Way, Horsham


I am writing on behalf of The Horsham Society to register our strong objection to this application.


We note that the application on behalf of  WSCC for housing on a greenfield site outside the built-up boundary is for outline consent only, prior to its intended sale. 


It seeks to rely primarily upon the Council’s inability to demonstrate five years supply of deliverable sites and the Facilitating Appropriate Development SPD (FAD).


We contend that the prime requirement contained within FAD to demonstrate that a proposed site is deliverable at the time planning consent is sought cannot be met through an outline application such as this where there is no potential developer or timescale for build-out.  Any assertion that this site is deliverable within the meaning of FAD is unproved and therefore unsound.


Furthermore some of the criteria within FAD, all of which have to be satisfied before planning consent can be given, are incapable of being tested through an outline application which inevitably provides inadequate detail; in others the evidence fails the test.


The applicant refers to the Council’s Strategic Housing Land Availability Study 2009 and incorrectly claims the site (SA06) was identified as “deliverable” whereas in fact it was said to be “developable”.  Nothing has happened in the intervening period to change this position and we therefore contend that its inclusion in the SHLAS does nothing to support the suggestion that the site is deliverable within the period required to satisfy FAD. 


Furthermore, the applicant fails to make reference to the Council’s subsequent consultation document 'Leading Change in Partnership to 2026 and Beyond',  which identified this site within Chesworth Farm Strategic Site Option 5, and the Council’s subsequent decision not to proceed with it in the next stage of the Core Strategy Review.  The presumption is therefore firmly against housing development on this site.


The 1997 Inspector’s report on an earlier proposal to identify this land for residential development is still relevant, and his conclusion that it would have a seriously harmful impact on the character and appearance of the open rural area to the south of the town making the proposal unacceptable is as valid today.


Turning to the criteria within FAD, we would draw attention to the following examples where they have either not been met or are incapable of being adequately tested.


Criterion 6


The assertion that the landscape and townscape character would be preserved and/or enhanced in accordance with the relevant policies is untrue or otherwise unproven. 


Specifically, the requirements in Policy DC2


“development will be permitted where it protects and/or conserves and/or enhances the key characteristics of the landscape character area in which it is located, including; the development pattern of the area, its historical and ecological qualities, tranquility and sensitivity to change”


are not met by this proposal.  The land in question has been used by local people for informal recreation for many years with no attempt by the landowner or his agent HDC to prevent it, other than a single locked access gate from Athelstan Way which could reasonably be interpreted as an intent to prevent inappropriate vehicular access.  Only towards the end of January 2010 did a notice appear on the access gate in Athelstan way to the effect that it was private land and there was no access to public footpaths via the gateway.  However, because the land is accessible from other points on its perimeter the closure of the gate is in any case immaterial. 


Furthermore,  HDC’s Chesworth Farm Management Plan 2007 states


“7.6 Muggeridge Field:


Although this field is owned by West Sussex County Council it forms part of a circular walk used by some visitors and management input is sometimes necessary.  Past management has included stopping motorcyclists and quad-bikers and removal of dangerous barbed wire.  The field receives a Summer hay cut.”


which shows unequivocally that use of the land for informal recreation has been both accepted and facilitated, and that for all intents and purposes the field has been treated as an integral part of the Chesworth Farm country park.


The Inspector’s report in 1997 said


“... this is not a self contained parcel of land where development would sit easily into the landscape without any serious visual impact.  Not only is the site attractive in its own right as open countryside rising gently from the present edge of the town, it is also an integral part of a wider rural area which forms part of the strategic gap and maps a very important contribution to the pleasing setting of the town.”


Similarly, the requirements in Policy DC9 to


“ensure that the scale, massing and appearance of the development is of a high standard of design and layout and where relevant relates sympathetically with the built surroundings, open spaces and routes within and adjoining the site, including any impact on the skyline and important views”


are not met in that the properties would be visible and create an unacceptable intrusion into the countryside to the south.  This would be particularly pronounced in respect of the properties on the south west of the site where the ground rises significantly. 


The Inspector’s report in 1997 said


“ the development would appear as an intrusive and uncontained sprawl into open countryside.”



The suggested design and finish of the buildings is indicated solely by reference to an ad hoc assortment of existing houses in the locality.  The same inability to apply a meaningful test of the criterion applies to the requirement to


“use high standards of building materials, finishes and landscaping; and includes the provision of street furniture…”


which is simply not evidenced in the application.


Criterion 7


The assertion that the proposed development complements the character of the settlement as defined in the relevant Town or Parish Design Statement is not proved. 


The Horsham Town Design Statement SPD states that


“a special feature of the town is its proximity, and easy access to attractive and varied countryside from open fields of Chesworth Farm …..”


“were there to be further outward development it would be very unlikely that Horsham could retain its identity or essential character”


“to the south is the River Arun and the countryside of Chesworth Farm and Denne Hill.  Were these to be developed it would drastically change the character of the town and its close links to the countryside”


“future development should protect …the sensitivity of the boundaries between town and countryside”


The proposed development of this site, which is de facto part of the Chesworth Farm southern boundary of the town,  in the manner proposed would not be compliant with the spirit or intent of the Design Statement.


The quotes from the Inspector’s report of 1997 reproduced under Criterion 6 above are equally relevant in respect to this criterion. 


Criterion 14


The application lacks sufficient detail to provide any assurance as to the quality of design, showing only an ad hoc collection of photographs of existing properties in the neighbourhood,  and cannot therefore be said to demonstrate the high standards required to comply with this criterion.


Criterion 16


The proposal manifestly would result in the loss of existing sport, recreational or amenity space and does not meet the aims of PPG17 which says


            Urban Fringe Areas


The countryside around towns provides a valuable resource for the provision of sport and recreation ……


…….local authorities should encourage the creation of sports and recreational facilities in such areas and the development of areas of managed countryside, such as country parks, community forests, and agricultural showgrounds”


This land is currently used for recreational purposes and is de facto part of Chesworth Farm. The applicant relies upon the statement that this use has not been lawful but as stated earlier there has been no attempt by the owners to prevent such use which has now been formalised through custom and practice, and confirmed in the Chesworth Farm Management Plan.  To permit development would be to fly in the face of PPG17.


Criterion 18


As stated above, the fact that this is only an application for outline consent without an identified developer or build-out plan makes it impossible for the Council to be satisfied that the site is deliverable as required by FAD.  It therefore fails the most fundamental test on which the rationale for the SPD is based.



Turning to traffic and access issues, the Transport Planning Statement appears to provide for fewer traffic movements than commonsense would suggest is likely which may be a product of the particular model they used.  It is unclear, for example, whether the atypical traffic movements associated with the presence of a care home off Athelstan Way have been appropriately taken into account.  We contend that traffic movements in and out of Athelstan Way will be greater than suggested and add to the already busy A281.  The suggestion that the A281 is cycle friendly because of its relatively low traffic speeds does not take account of the volume of traffic, including large vehicles, and the parking on both sides of the road on the  approach to the town centre, with consequent narrowing of the effective width and danger to cyclists. 



Having regard to all these factors,  The Horsham Society considers that this speculative application manifestly fails to satisfy the criteria set out in FAD.  Any suggestion that the faults and omissions could be remedied through conditions or reserved matters (as suggested in part by the applicant) would comprehensively undermine the intention of the SPD that only fully formed proposals with a proven ability to deliver within a short timescale should be approved through this route.  Furthermore nothing material has changed to undermine the Inspector’s conclusions in 1997 in regard to the unsuitability of this site for residential development.  The application should therefore be refused.



Yours faithfully


John Steele

Secretary, Planning Sub Committee