RESPONSE STATEMENT BY HORSHAM
HORSHAM DISTRICT LOCAL DEVELOPMENT FRAMEWORK
SITE SPECIFIC ALLOCATIONS OF LAND DEVELOPMENT PLAN
ALTERNATIVE DEVELOPMENT SITE -
Land West of New Town Road, Storrington (ADS92)
LAND WEST OF NEW TOWN ROAD, STORRINGTON (ADS92)
1.1 Following the submission by the Council in November 2005 of the Site
Specific Allocations of Land document (SSAL) (CDHor11) a number of
alternative development sites were put forward by respondents for
consideration as allocations. These sites were included within the Alternative
Development Sites and Boundary Changes document (CDHor15), published
for consultation in January 2006.
1.2 The Council does not support these suggested sites and maintains that
they are neither necessary nor appropriate in the context of both the
provisions of The Core Strategy 2007 (CDHor2) and the site specific
considerations. The purpose of this Response Statement is to explain the
Council’s position on this Alternative Development Site and to address the
issues raised in the submitted representations in support of, or against, the
suggested allocation. The Statement sets out the Council’s view on the likely
key issue and question for Examination identified by the Inspectors, which are
Effect on the landscape setting of Storrington.
Flood risk, drainage and water supply.
Suitability of access.
The nature of the proposed scheme.
2. Site Description
2.1 The site is located at the western edge of Storrington abutting but outside the
existing built-up area boundary. It has an area of 0.71ha. The site comprises
the northern part of a field which is bounded by residential development to the
north and east and Amberley Road to the south-east.
2.2 To the north is recent residential development pursuant to allocation SR3 in
the Local Plan 1997. Along this boundary are three oak trees protected by a
Tree Preservation Order (TPO 1140). To the east are the gardens of
properties in New Town Road and Downlands. To the west is a watercourse
and a line of trees, beyond which is open countryside. To the south, there is
no defined boundary and little vegetation with the alternative development site
extending into the remainder of the field towards Amberley Road.
3. Existing Policy Designation
3.1 The site is located outside of the built-up area as defined in the adopted
Horsham Core Strategy 2007, the Proposals Map 2006 and the Local Plan
1997. It therefore lies within an area designated as countryside.
3.2 The Council’s approach to the development of such sites is set out in Policy
CP8 of the Core Strategy and the provisions of Policy CP5 which are also
4. Relevant Planning History
4.1 There is no planning history for this land.
5. Principal Issues
5.1 The principal issue in relation to this site is whether this land is required for
housing to fulfil the requirements of Policy CP4 of the adopted Core Strategy
and if so, whether this site should be allocated at this stage, given the
particular characteristics of the site, without a proper assessment of other
possibly more appropriate sites.
5.2 The Council submits that any form of residential development on this site
would be unnecessary at this stage. The position on housing land supply is
set out in the Council’s Overall Position Statement and the Response
Statement on Matter 1. This demonstrates that the Council has allocated
sufficient previously developed land sites and smaller scale greenfield sites to
meet the requirement of Policy CP4 of the adopted Core Strategy over the
period to 2018. It is further considered that the Council does not need
additional greenfield site allocations at this stage but, if there is a need to
address the small unidentified site allowance, or any other deficiency that
might be identified, through new allocations, this should be undertaken
through the programmed Reserve Housing Sites DPD and review of the Core
5.3 In the light of the above context, it is submitted that there is no need for
additional greenfield sites to be included within the built-up area boundary.
An assessment of the Inspectors identified key issues and questions is set out
Effect on landscape setting of Storrington
5.4 This alternative development site is on the northern side of one of the
‘gateway’ approaches to the village of Storrington. Whereas residential
development on the Policy SR3 allocation site has limited impact on the wider
surroundings and from Amberley Road, the current site which is part of a
larger area of attractive, open countryside is considered to be important to the
rural setting of the village.
5.5 The lack of existing vegetation or other landscape features on the southern
boundary together with the elevated nature of Amberley Road relative to this
land would result in a development that would be highly visible and visually
intrusive in the area. Development of this site would therefore be an
unacceptable incursion into a sensitive area of countryside, given also the
AONB immediately to the south of Amberley Road. In contrast, the
development at Downlands immediately to the east, which comprises 4
dwellings, benefits from screening to its southern boundary. These dwellings
also sit relatively comfortably on the site and relate well to the built-up area.
5.6 Furthermore, development of this alternative development site with no defined
or natural southern boundary would be likely to result in future pressure for
additional development on the remaining area of the field to the south,
towards Amberley Road which would cause serious harm to the appearance
and setting of the village.
Flood risk, drainage and water supply
5.7 The Environment Agency’s indicative flood plain map shows the site not to be
at risk from flooding. However, the Environment Agency advised in relation to
the planning application for the development on the allocated site (SR3) to the
north that at that time they were aware of previous flooding downstream and
considered it necessary for there to be controls over the rate of surface water
runoff from that site into the adjacent watercourse. It is likely that a flood risk
assessment would be required in relation to any development of this site.
5.8 Storrington has historically experienced problems with sewer capacity and
localised flooding due to surface water entering the foul sewer. However, as
with the site to the north, this is likely to be a matter for detailed drainage
design and there is no indication from Southern Water that appropriate
drainage or a water supply could not be provided to any development on the
site. A public foul water sewer crosses the site to the north and Southern
Water also advised that a water supply could be provided to that site.
Suitability of Access
5.9 Access to the site would need to be provided in a way that would be
acceptable in environmental as well as highway safety and capacity terms.
Consequently, access via the site to the north is considered to be the only
acceptable option subject to the three protected oak trees along the mutual
boundary being unaffected by further development. An arboricultural
assessment would be required to demonstrate that this alternative
development site could be accessed without harm to these trees.
5.10 The County Council advised in relation to the previously allocated site (SR3)
that provided the new road into that site from New Town Road was built to
adoptable standards, it would be capable of serving some further
development. However, visibility at the junction of New Town Road and
Amberley Road was below the required standard and a lowering of the speed
limit together with gateway surfacing and signage works were proposed to
reduce traffic speeds.
The nature of the proposed scheme
5.11 Notwithstanding the Council’s overall concerns about development of this site,
given its edge of settlement location and subject to issues of design, scale
and layout, it is considered that a density close to the national indicative
minimum as set out in PPS3 would be more appropriate than a higher density
scheme. Under Policy CP12 of the Core Strategy, a development of 21 units
(at 30 dwellings per ha) would be expected to provide a substantial proportion
of smaller homes and 8 affordable units of a size and tenure to be agreed in
the light of the Council’s identified housing needs for the area.
5.12 In relation to other sites within Storrington, the two greenfield sites at St
Josephs Abbey (AL12) and the RAFA site (AL12) would assist in meeting
specific identified local needs for retirement housing. In addition, two sites in
Storrington allocated under Policy AL1 would provide affordable housing,
firstly at Foxmead, Meadowside, in accordance with Policy CP12 and
secondly at Abbey House, Ravenscoft, a site where permission has recently
been granted for a wholly affordable housing scheme of 24 units.
6. Response to Representations
6.1 The Rothschild Trust Nominees (2090) refer to the LDF Sustainability
Appraisal and Strategic Environmental Assessment (page 242 CDHor03)
which states that : ‘Development could affect entrance to the village. May be
suitable for development if it meets identified need’.
6.2 As indicated in paragraph 5.2 above, the Council’s is satisfied that it does not
need to allocate this site at this time in order to meet the identified housing
requirements to 2018. Furthermore, whereas the other greenfield allocations
in Storrington, at St Josephs Abbey and the RAFA site are aimed at meeting
specific local housing needs in accordance with Policy CP8 of the Core
Strategy, the scheme being promoted for this alternative development site
comprises a largely open market development with an element of affordable
housing. It would not therefore meet any specific local need. In terms of
balancing the benefit of securing a limited proportion of affordable housing
against its environmental impact, it is considered that the harm that would be
caused by the adverse effect of development on this site on the setting of the
village outweighs other considerations.
6.3 Other issues raised by The Rothschild Trust Nominees (2090) are considered
elsewhere in this statement; in the Council’s overall Position Statement and in
the Response Statement on Matter 1.
6.4 Storrington & Sullington Parish Council (2230) and Crest Nicholson (South
East ) Ltd (2575) object to the allocation of this site on the basis that is outside
the built up area and is an incursion into open countryside which would be
damaging to the setting of the village. These issues are also addressed
7.1 The Council opposes the inclusion of this site within the built-up area
boundary and a specific allocation of the site for residential development. It
has been demonstrated that there is no need to allocate smaller greenfield
sites at this stage to meet the housing need indicated in Policy CP4 and no
local need has been identified in accordance with Policy CP8. Furthermore,
the development of this site would have implications for the landscape
character and setting of Storrington and the wider countryside having regard
to the existing policy context.
7.2 The allocation of this site would not comply with the relevant Tests of
Soundness and would make the Site Specific Allocations of Land Document
less sound because:
it would not be consistent with national planning policy, particularly PPS1,
PPS3 and PPS7, by virtue of its location and impacts (Test 4);
it would not be coherent and consistent with the Core Strategy, particularly
Policies CP1 and CP8 (Test 6);
it does not represent the most appropriate allocation in all the
circumstances (Test 7).