Horsham District Council is reviewing their Local Plan. The Horsham Local Plan consultation runs until 5pm on 30 March 2020.
Read the Sussex Wildlife Trust's official response to the consultation here: SWT response to Horsham Local Plan 2020 FINAL
We encourage anybody impacted by the Horsham Local Plan review to get involved and submit your own comments via the Horsham District Council website
Frequently Asked Questions about the Horsham Local Plan consultation
What is a Regulation 18 consultation?
When a Local Planning Authority (LPA), in this case Horsham District Council (HDC), is writing a new local plan, they have a legal requirement to consult with the public. The first round of official consultation is called Regulation 18 after the regulation of the Town and Country Planning (Local Planning) (England) Regulations 2012 which say this has to happen. At Regulation 18, LPAs must allow people to make comments on what a plan should contain.
Once the consultation period is over, HDC will look at all the comments submitted and any additional evidence, and decide what policies and site allocations should be in the Local Plan. Sometimes additional consultations happen, but legally after this point HDC can go straight onto the Regulation 19 consultation. This is when the LPA has written a plan that it thinks is complete and wants to submit it for consideration by a Planning Inspector. The plan goes out to public consultation again, but you are much more restricted on the types of changes you can suggest.
The point is that the Regulation 18 consultation is the time to submit anything you want to say about the plan. For example, problems, changes, improvements and missing evidence, because things are much more restrictive later on.
Do I have to respond online?
Horsham District Council would like you to respond via their online planning portal, as this makes it much easier for their planning team to go through all the thousands of comments that are probably going to receive. It also makes it very clear which section or element of the plan the comment is about. However, if you do not want to sign into their portal or use an online system, you don’t have to. HDC will accept responses by paper or email. However, you must make sure you make it very clear which parts of the plan you're talking about, otherwise your comments might be misinterpreted. HDC have more advice on their website – make sure you scroll down to the bottom.
What can I say in my response?
You can say whatever you want in relation to the plan. However, the comments that are going to have the most influence on what HDC decide to take forward will be the ones that relate to planning issues and the ones that are supported by evidence or some kind of justification.
‘Planning issues’ cover a lot of things, but a straightforward indication are the topics covered in the National Planning Policy Framework (NPPF). This is the national policy that LPAs have to comply with. This is one of the main things any plan will be judged against by a Planning Inspector. So linking your comments to paragraphs within the NPPF is always helpful.
What will Sussex Wildlife Trust be looking at in their response?
Sussex Wildlife Trust is a nature conservation charity, so we our respond will be focused on biodiversity issues. We will read the plan in its entirety and see how the council have embedded biodiversity throughout the plan. We want to assess and comment on their approach the plan from the aims and objectives to the allocations and policies.
We will use clear policy and legislation to back up our comments by referencing paragraphs from Chapter 15 of the NPPF on ‘conserving and enhancing the natural environment’. Other chapters may be useful to you including Chapter 3 on ‘plan-making’.
What environmental information is provided?
We haven't been through the plan in detail yet, because we have been commenting on other Local Plans for other LPAs in Sussex. However, we have already noticed that there doesn’t seem to be very much evidence presented on existing biodiversity within Horsham District.
Paragraph 31 of the NPPF says: ‘The preparation and review of all policies should be underpinned by relevant and up-to-date evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.’
Further to this, Paragraph 174 of the NPPF says: ‘To protect and enhance biodiversity and geodiversity, plans should: Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation’
For us this evidence base is really vital as it helps us to assess likely impacts of policies and site allocations. Without up to date baseline information it is very difficult to make detailed comments on proposals.
What about the Habitats Regulations Assessment Screening Report?
The Habitats Regulations Assessment Screening Report (HRA) is a document that HDC must legally produce which assesses any risks to internationally designated sites only i.e. Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Ramsar sites. Whilst it is really, really important that the LPA considers impacts on these extremely valuable sites, this is just one element of the evidence base and does not look at general wildlife or locally or nationally designated sites.
What about the Sustainability Appraisal?
Again the Sustainability Appraisal (SA) is a legal requirement and a document that will be repeatedly amended as the LPA work through the process of making a Local Plan. The main purpose of a SA is to appraise the social, environmental and economic effects of a plan from the outset. In order to help ensure that decisions are made that contribute to achieving sustainable development. The SA looks at all elements of sustainability, not specifically biodiversity. So again, whilst we will comment on the SA it is not a complete evidence base when it comes to nature.
What is missing?
We haven’t looked at all the documents in the Local Plan review evidence base yet, but we are concerned that there does not appear to be any information on the mapping of ecological networks as mentioned in paragraph 175 of the NPPF. We also have not seen anything that relates to Green Infrastructure. This is of concern, but we cannot make any detailed comments on this quite yet.
When will Sussex Wildlife Trust have a position?
We will publish more detailed thoughts as soon as we can. However we do not want to be premature and need to make sure we consider all of the available evidence.
We understand that people are very concerned about the amount of housing proposed in Horsham District and that they want to understand how they can influence this. If you have specific questions about wildlife and biodiversity then please use the comment box below and we will try our best to respond. However, please note we are not in a position to answer questions about none-biodiversity related issues.