Statutory examination has started ! Letter from Examiner

Pdf of letter can be found here


Andrew Cooke
Horsham Blueprint Business Neighbourhood Forum

Norman Kwan
Horsham District Council

Examination Ref: 01/DAS/HBBNP

9 December 2020

Dear Mr Cooke and Mr Kwan


Following the submission of the Horsham Blueprint Business Neighbourhood Plan for examination, I would like to clarify several initial procedural matters.

1.Examination Documentation

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.

2.Site Visit

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.

Your sincerely

Derek Stebbing






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.