Back in September I wrote to you explaining that Horsham District Council had agreed to the continued designation of Horsham Blueprint as a Business Neighbourhood Forum and that the next stage was Regulation 16 Consultation conducted by Horsham District Council (HDC).This took place during September and October 2020 prior to the required Independent Examination.
The role of the Independent Examiner is to consider the draft plan, together with the Regulation 16 representations, to determine if the plan meets the basic conditions requirements. This is to ensure that the plan is consistent with existing national and local planning policies, environmental requirements and human rights legislation.
The Independent Examiner has now started his review of the plan and we expect to receive the draft report by the end of January / early February 2020. The Examiner can either recommend:
The decision to proceed to referendum and timing is then a matter for Horsham District Council.
I know that many are disappointed that Blueprint did not include a number of well-known open spaces as “green spaces” within the Neighbourhood Plan. This is reflected in a number of the comments submitted to Horsham District Council in response to the Regulation 16 Consultation.
We share that disappointment; but irrespective of our personal views, we had to base our decision on the criteria for “green spaces” given in the National Planning Framework. Our decisions were not taken lightly and were based on professional advice.
We concluded that the identification of these sites as “local green spaces” would have compromised the plan’s compliance with the “basic conditions”. This would result in the Examiner recommending that they be removed from the plan; or provide HDC with a reason not to take the plan forward to referendum – thereby losing the protection granted by “local green spaces” designation to the twenty four other locations spread across Horsham.
Despite not being able to designate Rookwood and Muggeridge Field as “local green spaces” they have been identified as part of the “green Infrastructure network”. Policies on green infrastructure have been considerably strengthened following comments on the Draft Plan.
Policy HB10: Green and Blue Infrastructure and Delivering Biodiversity Net Gain includes:
“Proposals for development must be supported by a biodiversity appraisal, which must demonstrate how negative impacts would be minimised and biodiversity net gain achieved….. Where this is not demonstrated, permission for planning or for change should be refused.”
Whilst this won’t necessarily stop development – it does set a very high bar that must be satisfied before planning permission can be granted.
Thank you for your ongoing support of Horsham Blueprint and best wishes for 2021.
on behalf of the the Horsham Blueprint Steering Committee
INDEPENDENT EXAMINATION OF HORSHAM BLUEPRINT BUSINESS NEIGHBOURHOOD PLAN 2019-2036
EXAMINER: DEREK STEBBING B.A. (Hons), Dip. E.P., MRTPI
Horsham Blueprint Business Neighbourhood Forum
Horsham District Council
Examination Ref: 01/DAS/HBBNP
9 December 2020
Dear Mr Cooke and Mr Kwan
HORSHAM BLUEPRINT BUSINESS NEIGHBOURHOOD PLAN EXAMINATION
Following the submission of the Horsham Blueprint Business Neighbourhood Plan for examination, I would like to clarify several initial procedural matters.
I can confirm that I am satisfied that I have received a complete submission of the draft Plan and accompanying documentation, including the Basic Conditions Statement, the Consultation Statement, the Pre-Submission Sustainability Statement and the Regulation 16 representations, to enable me to undertake the examination.
Subject to my detailed assessment of the draft plan, I have not at this initial stage identified any very significant and obvious flaws in the Plan that might lead me to advise that the examination should not proceed.
I will aim to carry out a site visit to the neighbourhood plan area in the week beginning 28 December 2020, subject to the prevailing government COVID-19 advice at that time. The site visit will assist in my assessment of the draft Plan, including the issues identified in the representations.
The visit will be undertaken unaccompanied. It is very important that I am not approached to discuss any aspects of the Plan or the neighbourhood area, as this may be perceived to prejudice my independence and risk compromising the fairness of the examination process (and further respecting the current COVID-19 distancing arrangements).
I may have some additional questions, following my site visit, which I will set out in writing should I require any further clarification.
3. Written Representations
At this stage, I consider the examination can be conducted solely by the written representations procedure, without the need for a hearing. However, I will reserve the option to convene a hearing should a matter(s) come to light where I consider that a hearing is necessary to ensure the adequate examination of an issue, or to ensure that a person has a fair chance to put a case.
4. Further Clarification
From my initial assessment of the Plan and supporting documents, I have identified a number of matters where I require some additional information from the District Council and the Qualifying Body.
I have three questions seeking further clarification, which I have set out in the Annex to this letter. I would be grateful if you can seek to provide a written response by Thursday, 31 December 2020.
5. Examination Timetable
As you will be aware, the intention is to examine the Plan (including conduct of the site visit) with a view to providing a draft report (for ‘fact checking’) within 4-6 weeks of submission of the draft Plan. However, as I have raised a number of questions, I must provide you with sufficient opportunity to reply. Consequentially, the examination timetable will be extended. Please be assured that I will seek to mitigate any delay as far as is practicable. The IPe office team will seek to keep you updated on the anticipated delivery date of the draft report.
If the Business Neighbourhood Forum or Local Planning Authority have any process questions related to the conduct of the examination, which you would like me to address, please do not hesitate to contact the office team in the first instance.
In the interests of transparency, may I prevail upon you to ensure that a copy of this letter is placed on the Business Neighbourhood Forum and Local Authority’s websites.
Thank you in advance for your assistance.
From my initial reading of the Horsham Blueprint Business Neighbourhood Plan and the supporting evidence, I have the following questions for the Business Neighbourhood Forum and the District Council. I have requested the submission of responses by 31 December 2020 though an earlier response would be much appreciated.
Question 1: Re. AIM 3 – Aspirational Development Sites (Pages 39/40)
I note that the first sentence of paragraph 7.30 states that “If the sites, described briefly below [in AIM 3], were to become available, development will be resisted unless it accords with the policies of this Neighbourhood Plan and aspirations for the sites, as set out below”.
Please can the Business Neighbourhood Forum explain why this text purports to be framed as a policy?
I note that AIM 3 (along the with other AIMs) is an aspiration and has no policy status.
Question 2: Re. Chapter 9 and Policy HB12 (Encouraging Sustainable Movement) (Pages 53-58)
I note that Section 9 of the Plan, including Policy HB12, does not identify any specific infrastructure proposals to encourage sustainable movement by walking, cycling and public transport in the Plan area up to 2036.
I further note that Figures 9.1 and 9.2 refer to draft Local Cycling and Walking Infrastructure Plan (LCWIP) cycling networks and key walking routes.
I invite the District Council to confirm the current position and status of the LCWIP being prepared by West Sussex County Council, and to confirm whether or not there are any committed infrastructure proposals within the Plan area designed to encourage sustainable movement that ought properly to be identified within Section 9 of the Plan.
Question 3: Re. Paragraphs 10.4-10.7 – Rookwood (Page 62)
I note the content of these paragraphs regarding the 68 hectares of land at Rookwood. In view of the statement at paragraph 10.5 that “The site is, however, being considered as a potential strategic allocation for major housing development by Horsham District Council as part of its Local Plan Review …..”, I invite the District Council to provide me with a Note indicating the latest position regarding this possible allocation. This should include its implications for the leisure facilities provided at the site and the also for the green infrastructure network in that part of the designated neighbourhood area, noting that it adjoins a Local Nature Reserve.
I further note that this may have implications for the content of Policy HB10, particularly clauses G and H of that policy.
I am pleased to report that earlier this summer Horsham District Council (HDC) re-designated Horsham Blueprint as a Business Neighbourhood Forum. This has enabled the draft Neighbourhood Plan submitted to HDC in June to move on to the next stage known as the Regulation 16 Consultation. Some of you may have seen the HDC consultation notice in the local press.
This is an important next step for the draft plan; as this consultation and the subsequent review of the plan and consultation responses by an Independent Examiner will enable the plan to progress on to the final stage of the Neighbourhood Plan adoption process – the public referendum.
A question some of you may well be asking – hasn’t the draft plan already been consulted on?
Regulation 16 consultation should not be confused with the pre-submission (to HDC) consultation conducted by Horsham Blueprint earlier in the year. The two are different; the earlier consultation provided anyone with an opportunity to comment on any aspect of the plan and for modifications to be made if necessary to reflect those comments (which they were – for example in relation to Rookwood).
With the Regulation 16 consultation any representations made will be passed to an Independent Examiner. This means that they will only be considered within the remit of The Independent examination – that is, whether neighbourhood plan meets the basic conditions.
The purpose of the basic conditions requirement is to ensure that the plan is consistent with existing national and local planning policies; environmental requirements and human rights legislation.
Should the Independent Examiner conclude that the plan fails to meet the basic conditions HDC in discussion with Horsham Blueprint can modify the plan prior to the public referendum. HDC must publish decision statement within five weeks (of receiving the Independent Examiners report) setting out whether they intend to send the Plan to referendum (and if not – why not).
Because Horsham Blueprint is a Business Neighbourhood Forum there has to be two referendums, one for those who pay residential council tax and one for those who pay business council tax; however due to the current Covid-19 restrictions, these referendums are unlikely to take place before May 2021.
Whilst it is not until the plan has been agreed by the electorate at a referendum does it become part of the official planning policies governing development; nevertheless where the local planning authority (HDC) has issued a decision statement detailing its intention to send a neighbourhood plan to referendum, the plan can be given significant weight in decision-making, in so far as it is material to the application being considered
We have worked hard to ensure that the plan meets the basic condition requirements, but if you have any comments regarding that, then please do respond to the HDC consultation on the Horsham District Council website at:
Thank you for your ongoing support of Horsham Blueprint.
on behalf of the Horsham Blueprint Neighbourhood Forum Steering Committee
Thank you to everyone who responded to the consultation exercise by down loading the draft plan and completing the online questionnaire, by submitting an email response, or simply by visiting our exhibition in Swan Walk over the two weekends in early March.
It was great meeting so many people over the course of those weekends. We had many good conversations; some that were challenging; many that were supportive and lots that were both!
The tenor of these conversations has been confirmed by the findings of the consultation exercise questionnaires. All together 147 questionnaires were completed together with 23 written responses.
The detailed analysis of the responses and revision of the draft plan is ongoing; however all 15 draft policies were overwhelmingly endorsed by respondents as can be seen by the graph below.
So what are the next steps?
Once the analysis of the consultation responses is completed the plan will be revised and submitted to Horsham District Council; at which point the plan will be reviewed by an Independent Examiner. Providing the Examiner is satisfied (and subject to any revision that Examiner may require) the plan will then be submitted to a public referendum, and if approved will be adopted by Horsham District Council as one of their planning documents.
Doesn’t a neighbourhood forum have a finite life?
Yes, Neighbourhood Forums such as Horsham Blueprint have a “statutory designation” of 5 years. Blueprint’s current designation expires on the 5th of June. Therefore to complete the above steps Blueprint needs to be re-designated as a Neighbourhood Forum by Horsham District Council. To do this we need demonstrate that:
a) we have a minimum of 21 members supporting the re-designation; and have
b) an Annual General Meeting (AGM) resolution to continue.
Our provisional AGM date is 7:30pm on 19th May 2020 (it might be by ZOOM or Skype if the lockdown continues); but in the meantime please demonstrate your support for the re- designation of Horsham Blueprint by completing the membership form that can down loaded here
on behalf of Horsham Blueprint
It is important that as many residents and businesses in the unparished part of Horsham let Blueprint know what you think about the draft Neighbourhood Plan and whether you support the visions. The document can be found at here or hard copies of the document can be found will be in The Library or Horsham District Council’s Offices.
Supported by the 3 Neighbourhood Councils, Blueprint sought community and business views to understand how the unparished area of Horsham might develop over the next 10-15 years in a sustainable way. The draft plan preserves the Town’s character and identity, sets out the types of homes we need, protects green spaces and continues to support local business and the Town Centre.
There are 15 planning policies and associated actions in the Plan. Briefly;
New homes: The plan does not allocate development sites; rather the focus is to ensure that any development coming forward is directed to the places that have the lowest impact on our landscape, environment and infrastructure. Development should provide the types of houses people need.
Horsham Town Centre and the wider economy: We aim to ensure that Horsham Town Centre remains an attractive and prosperous market town, where people want to spend time shopping and socialising. We encourage a mix of activities to take place within a safe and welcoming public realm. We seek to provide the infrastructure required to retain existing businesses while also attracting new ones.
Environment and green space: Horsham is fortunate to have many green spaces within our urban area including Horsham Park, Warnham Nature Reserve and Chesworth Farm to name a few. We plan to safeguard smaller pockets of green space that are particularly valued, and green corridors for future generations. We also want to mitigate our impact on climate change and include a range of policies to help achieve this, such as promoting sustainable design, encouraging allotments and self-sufficiency.
Transport and movement: Whilst we are supporting additional public car parking, we want to make it easier for residents and visitors to walk and cycle to and within the town and wider area. Our policies will ensure that our rights of way are well-maintained and accessible to all. This includes our ancient network of twittens.
Community assets and infrastructure: The community facilities we have provide an important lifeline not only for our community but for those in neighbouring villages and it is vital that they are safeguarded, improved and, where necessary, expanded to meet the changing needs of our residents. We support additional facilities for children and teenagers and the provision of community halls and cultural venues.
Character, heritage and design: We want to make sure that new development is in-keeping with the local character and is designed to the highest standards – including ensuring it is environmentally friendly and reduces energy-consumption. We also want to celebrate our heritage.
Age Friendly: Horsham has both an expanding younger and older population. We want to support initiatives and steps for Horsham to be designated an Age-Friendly Neighbourhood.
|YOUR VIEW ARE IMPORTANT. Please complete the on line survey. Alternatively the survey can be sent to you by post, if you phone or text 07561395448 and leave your name and address.|