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Horsham District Council Draft Greenspace Strategy

HDC Draft Strategy

Horsham Society's response



The Local Plan


Consultation has now closed on the long awaited Horsham District Local Plan 2023-2040 and it, and the comments received, will be passed to a Government appointed Inspector for assessment. Public hearings are expected in October and the final Local Plan is due to be adopted by the Council in May 2025.

The new plan will replace the Horsham District Planning Framework 2015. This was the one that promised 16,000 new homes between 2011 and 2031 (averaging 800 a year). Controversially, “at least” 2,500 homes were allocated on a huge greenfield site north of the A264 - since christened Mowbray – and 2,750 homes have since been approved here.

The new Local Plan is 220 pages long and is supported by dozens of reports and appendices which comprise the ‘evidence base’. It covers every aspect of planning including important strategic policies on climate change, the natural environment, countryside issues and economic development. Of more immediate interest it contains policies for what it prosaically calls ‘growth’ which is principally new homes, and the employment and infrastructure to support them. There are separate policies on development quality, design and heritage.


The importance of Horsham town to the District as a whole is recognised, and there is a specific strategic policy which sets out to maintain and strengthen its role as the primary economic and cultural centre in the District.


So far as housing is concerned, the Council has identified a need for 13,212 new homes over the period of the Plan, of which 6,717 already have planning permission or have been allocated in a neighbourhood plan; many of these are on the existing developments such as Kilnwood Vale and Mowbray. Following a re-assessment of the plans for Mowbray the Council has decided the area can take an additional 500 homes, and a further 300 have been allocated on land between the current western boundary and Warnham station. There are new strategic sites at Land West of Ifield (3,000 homes), Land North West of Southwater (1,000) and Land East of Billingshurst (650). The rest of the target will be met through smaller developments in the towns and villages, mostly identified through neighbourhood plans.

Because of the reliance on huge strategic sites which take a long time to develop, the plan provides for delivery of an average of 480 homes per year in 2023/24 to 2027/28, rising to 901 in each of the following twelve years. It also includes ambitious targets for the delivery of affordable homes.


Apart from the north of Horsham allocations, the only new site in the town is land at Hornbrook Farm, opposite Hilliers, where 100 new homes are planned. This is a site which has been vulnerable for many years and the housing density is relatively low because of the form of the land.


So, what are the Society’s views on the Plan? Overall, it is a very thorough document which reflects current concerns over care for our environment and the quality, and design, of developments. Inevitably, perhaps, much of the narrative is ‘motherhood and apple pie’ but in the main the policies (particularly as they affect Horsham town) are excellent and have our support.


There is one significant area where we have taken issue with the Plan, and we have suggested a number of smaller changes.


The greatest obstacle to development at present is the requirement for water neutrality, imposed by Natural England in October 2021 in order to protect the Sussex North Water Supply Zone (which includes Horsham District) from further depletion. No development is permitted which would result in a net increase in water consumption so, as you might imagine, ingenious minds are exploring ways to get around this. These include straightforward innovations such as rainwater harvesting, and others which seem fraught with complexity such as retro-fitting water saving devices to existing buildings. Local authorities in the south have got together with Southern Water to prepare a Sussex North Offsetting Water Scheme (SNOWS) which developers will be able to buy into. In our view there is insufficient evidence that such a scheme will be effective and auditable at scale. Furthermore, the Local Plan requires new developments to be designed to utilise no more than 85 litres of mains water per person per day. We are not convinced that this is achievable, particularly in households with young children or older people in care. We therefore consider the Plan needs to be reworked using more realistic assumptions about household water use.

We have suggested changes to strengthen the Plan’s policies on development of the Broadbridge Heath Quadrant, maintenance plans for environmental innovations such as green walls, sustainable design standards, the need to create new areas of public open space, the encouragement of good quality modern architecture, and maintaining good quality office space in central Horsham. We have also sought improvements to policies on community health and wellbeing, infrastructure, transport, and the rate of build out of affordable homes.


We haven’t commented on the overall target for new homes as it is complicated; more a form of art than science some might think, and the Inspector will pronounce on it in due course. As for the location of the new homes, the proposals for Horsham town are probably the least worst we could have expected; those for Southwater are more serious. Overall, though, we are disappointed that yet again the Council has fallen back on a few huge strategic sites bolted on to existing communities. These are popular with planners but threaten community cohesion and never seem to fully deliver the necessary infrastructure and affordable homes.


The Society has for many years advocated the development of a new town which could be designed from the bottom up, with all the necessary facilities to create a sustainable modern town with its own identity and community cohesion. It would be nice if we good draw any comfort from the statement “any subsequent review of this plan will need to consider whether it remains appropriate for continued strategic scale settlement expansion, or whether the development of a new settlement would be sustainable approach”, however similar statements in previous plans have come to nothing. Given that such an approach would take many years to consider and plan, we do not think it can be accommodated within the usual five-year review process, so we have asked the Inspector to require the Council to start this work within two years.






The former Novartis site, Parsonage Road:

Last year the Society had a helpful meeting with representatives of the developers, but remained disappointed with the proposals for the residential components of this key site. The overall design appears to have been over-constrained by a desire to maximise return on investment. Consequently the Society has objected to the associated planning applications covering appearance, landscaping, layout and style.

The Society highlighted the insufficient provision for parking, also raising concerns about the highway consequences generated by the additional traffic and the proposed traffic circulation.

Sussex House and loss of privacy:

Sussex House is a former commercial building located next to The Capitol in North Street and now being converted to living accommodation. Plans  began to emerge some three years ago and a string of planning applications has followed with a trend towards adding more units and putting pressure on parking. The impact of the developing plans and the reality of the build has caused major concern for nearby residents, especially in terms of loss of privacy through overlooking. The situation appears to have been made even worse by alleged unauthorised deviations from approved plans, in particular, the building of balconies overlooking Norfolk Road. These alleged deviations are currently the subject of a formal objection by local residents.

The Horsham Society has been critical of plans throughout and raised a number of objections concerning the size of the units, inadequate parking and loss of privacy.

Morrisons In Mowbray:

The Horsham Society has been pressing for an improved design of the proposed store. The existing proposal is basically a "shed" and doesn't do justice to what is supposed to be an exemplar development. Morrisons has come back with some options for different brickwork but with nothing on the "shed" design, nothing on the elevations and nothing on the rooflines.

The Society continues to press for improvement.

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