By Laura Brook
The Sussex Wildlife Trust Conservation Policy Team hit the ground running in 2020. We knew the first three months of the year would be packed with deadlines for Local Plans and strategies across Sussex, and that these key documents would shape the future of our county. We keep a visual record of our deadlines in the office, and the timeline for March was so heavily peppered with deadlines we almost ran out of whiteboard.
The most important item on our March to-do list was always going to be the review of the Horsham Local Plan. This Plan will decide the location of development across the District for years to come and is a big opportunity to help the District’s wildlife.
We’ve had numerous enquiries from local residents concerned about the sites that are being proposed for development, and have been fortunate to talk with some very dedicated groups from across the District who feel passionately about protecting the natural environment across Horsham.
But despite all our forward planning, none of us were prepared for what March would bring to the world and the massive challenges that we’re now facing. Despite the global situation, the deadline for responses to the Horsham Local Plan review remains unchanged and is still looming large on Monday 30 March – and despite the global situation, the Local Plan is still vitally important to the future of our natural environment.
Since staying in is the best thing we can all be doing right now, this unexpected extra time might have come just when it’s needed the most. The Local Plan consultation is open for all to comment on, and this is a vitally important opportunity to help the natural environment from the comfort of your living room – especially if you live in Horsham District.
We know that Horsham District Council is trying to be ambitious in its wider plans to tackle the climate and ecological emergency. It is a District Council that values its natural environment, and this needs to be reflected consistently through all its policies. Local Plans, which decide the location of development in a District for many years to come, are where critical principles are put in place and decisions made. Ill-conceived policies and development have demonstrated many times that wildlife and the natural environment can be very low down the decision-making pecking order. That is why your feedback is important.
We are concerned that the draft Local Plan in its current form has the potential to significantly damage local wildlife.
Horsham District Council acknowledges that ‘the projected household growth numbers are set out at a national level by the Office for National Statistics, [so] local planning authorities do not have discretion to change this calculation, or in any way influence its outcome.’ We understand that the Council can’t refuse to plan for houses, but they can (and must) do it in the most sustainable way possible by having a strong evidence base. At the moment, we feel this is lacking.
National planning policy requires that local plans should ‘take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure.’ We are concerned that Horsham District Council's green infrastructure evidence is out of date – from 2014 – and that it hasn’t informed their decisions on the spatial distribution of development. It appears that Horsham District Council have accepted large sites put forward by developers rather than looking at the District strategically and trying to work out where the most sustainable locations for development would be. We completely understand that lots of factors affect where development can go, not least land ownership, but we’re concerned that without a good environmental evidence base to inform the location of development, the Local Plan in its current form will not be effective in protecting the natural environment or planning for the climate resilient landscape that will be needed to secure the District’s future. This evidence is available but critically has not been used to inform the Local Plan.
We are concerned that nine large strategic sites are being considered for major development but none of them appear to have been fully assessed in terms of ecological impacts – and some of them are right next to important designated wildlife areas, or even have a Local Wildlife Site within them. Other proposed allocations concern irreplaceable habitats or vase swathes of our Sussex Countryside – yet the only information available is presented by the development proposer. This information is poor quality, inconsistent and in some case simply wrong.
Since there is not enough evidence presented in the consultation to be able to assess their impacts on the natural world, Sussex Wildlife Trust objects to all nine of the strategic sites at this time. We have grave concerns about their impact on designated wildlife sites, the severance of local ecological networks, unsustainable locations and contributions to climate change.
We are working hard to finalise our response and would strongly encourage you to take a look at the Horsham Draft Local Plan Review and submit your own thoughts and comments via the website (horsham.gov.uk/planning/local-plan). The deadline is 5pm Monday 30 March, so time is short - but your wildlife needs you now more than ever.