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Thakeham Parish Council
Clerk to the Council: Mr John Denman
The Parish Office, Thakeham Parish Council
Storrington Road, Thakeham, Pulborough
West Sussex RH20 3EJ
Phone: 01798 815305
10 September 2014
Thakeham Neighbourhood Plan: Sustainability Appraisal/Strategic Environmental Assessment Scoping Letter
I set out below for your attention the proposed scope of the Sustainability Appraisal/Strategic Environmental Assessment (SA/SEA) to accompany the forthcoming Thakeham Neighbourhood Plan (TNP).
This letter and its appendices should be regarded as the Scoping Report of the TNP in accordance with Stage A of the provisions of the Environmental Assessment of Plans & Programmes Regulations 2004 (which implement EU Directive 2001/42).
As a statutory consultee in the Regulations you are invited to comment on this report and I would be grateful for your comment by 15 October 2014.
The TNP is being prepared by Thakeham Parish Council as a qualifying body under the 2012 Neighbourhood Planning (General) Regulations. In accordance with the 2004 Regulations , the local planning authority, Horsham District Council, issued its formal screening opinion on 19 May 2014, concluding that an SEA is required and that it would prefer this is undertaken as part of a wider Sustainability Appraisal (SA/SEA).
The District Council has determined that the likely intention of the TNP to contain policies allocating land for development is the primary reason for requiring an SEA. Regarding the environmental sensitivity of the area, the South Downs National Park is located outside the designated Neighbourhood Area. However, the TNP area lies within the 15 kilometre protection zone of the Arun Valley SAC/SPA/Ramsar site of European importance and this may require a separate Habitats Regulations Assessment in due course.
The guidance for undertaking SA/SEA is contained in the National Planning Practice Guidance (ID 11-030), which emphasises that it must “only focus on what is needed to assess the likely significant effects of the neighbourhood plan” and on the “environmental impacts that are likely to be significant”. It states that this “does not need to be done in any more detail, or using more resources, than is considered to be appropriate for the content and level of detail in the neighbourhood plan”.
It is therefore important to establish that the TNP is likely to contain only a small number of policies that may seek to identify sites for housing development, primarily within the settlement boundary and policies that will shape the design of development proposals. It will therefore work alongside other, higher-order, development plan policies for the district to guide the consideration of planning applications.
The SA/SEA framework will be used to assess two or three spatial options for distributing this development in the parish, rather than to assess individual sites in isolation of each other. Its conclusions will direct the selection of sites to those locations assessed as the most suitable by taking account of the SA/SEA and the Parish Council’s view on the relative acceptability to the local community of the spatial options, bearing in mind the need for the TNP to win a majority vote at a referendum.
The TNP may also contain policies relating to its local shops, employment sites, community facilities and sustainable infrastructure, all of which will be in general conformity with the relevant saved development plan policies, and will accord with the provisions of the National Planning Policy Framework. The consideration of these potential policies has begun but will await the conclusions of the consultation on this scoping exercise before progressing any further.
The TNP ‘State of the Parish’ report was published by the Parish Council in August 2014 to summarise the relevant evidence base for preparing the plan. This is attached as Appendix A to this letter. The report contains a summary analysis of the relevant plans and programmes of others that may inform the TNP and provides an overview of its evidence base. In doing so, it provides the information required for Stages A1 and A2 of the SA/SEA process.
Outlined briefly below is additional information required of Stages A3 and A4, together with some additional baseline data for Stage A2 attached as Appendix B.
Other Plans & Programmes (Stage A1)
The TNP State of the Parish report identifies the policies of the documents that make up the adopted 2007 Horsham Local Development Framework as having the most likely relevance in shaping the TNP. Indeed, the TNP must be able to show that its policies are in general conformity with the strategic policies of the development plan (essentially the Core Strategy and General Development Control policies DPD, 2007).
However, the report notes too that the replacement of the 2007 policies is well underway and the Proposed Submission version of the Horsham District Planning Framework (HDPF) was submitted to the Secretary of State on the 8th August 2014. It is anticipated that the examination of this document will take place before the end of the year (2014). Given this, it is likely the TNP will be not be examined before the adoption of the HDPF. The TNP should therefore be in general conformity with the adopted development plan, and also give due consideration to the policies contained in and the evidence supporting the HDPF (including its SA/SEA and Habitats Regulations Assessment).
Baseline Information (A2)
The State of the Parish report contains a wide range of social, economic and environmental data. However, for the purpose of the SA/SEA, some more detailed data has been identified (see Appendix B) in relation to the proposed assessment framework (set out in A4 below). The Parish Council is mindful that it is very difficult in most cases to measure impacts at this local scale as either the data is not reported at this scale and/or the impact is so relatively negligible that it cannot be measured. In which case, the SA/SEA framework will be used to inform judgements on the impact of the proposed policies in relation to any reasonable alternatives there may be.
Sustainability Issues (A3)
The State of the Parish report highlighted no significant sustainability issues that are not also common to rural England. The local community appears to accept that new development may be required provided it is small in scale, well located and is of a high quality design. As a result of the community engagement work completed thus far, a summary of which is also contained in the State of the Parish report, the TNP will plan for new homes over the plan period 2015 – 2031. At this stage, from the evidence work already undertaken, the Parish Council is confident the TNP will be able to do so within the environmental constraints.
Given the modest scale of growth likely to be planned for in the TNP, and its likely focus on the established settlement of Thakeham, there will be no likely measureable impacts on any designated nature sites or heritage assets outside the parish boundary.
Appraisal Framework (A4)
In the light of the context and available data, the Parish Council proposes to establish the following framework of environmental, social and economic objectives and measures in order to identify any likely significant environmental, social and economic effects.
The proposed framework reflects the general sustainability issues of the parish and the likely scope of policies in the TNP. It has selected those objectives of the SA/SEA accompanying the HDPF that are considered the most relevant and informative for this purpose. The decision not to choose an HDPF SA/SEA does not necessarily mean that objective has no relevance to the TNP but that it is unlikely to enable the merits of policy options to be distinguished and is therefore unhelpful for this purpose. For example, no part of the village or its adjoining land falls within Flood Zone 2 or 3 so this data will not help distinguish between policy attributes.
The process of housing site selection will be informed by an analysis of their achievability, availability and acceptability and by an analysis of their suitability when assessed against the spatial policy of the TNP. That spatial policy, and any reasonable alternative spatial options, will be informed by the proposed SA/SEA framework.
The list of objectives and measures below indicates which of the HDPF SA/SEA objectives have been used to inform them.
Objective 1: Housing (HDPF SA/SEA ‘Housing’)
To provide high quality, affordable housing with a range of size, types and tenures appropriate to local needs:
1A - will the TNP improve the availability of decent, affordable housing?
1B – will the TNP provide a range of housing types of various sizes and tenures?
1C – will the TNP make better use of brownfield land for housing?
Objective 2: Community Facilities (‘Leisure & Recreation’ & ‘Equalities & Social Inclusion’)
To ensure everyone has access to appropriate, affordable community facilities:
2A - Will the TNP sustain or increase the provision of community facilities?
Objective 3: Biodiversity (‘Biodiversity’)
To protect and enhance the quality and level of biodiversity and natural habitats within the parish and provide new green infrastructure.
3A - Will the TNP lead to the loss to biodiversity, flora or fauna as a result of development, either directly or through habitat fragmentation?
Objective 4: Landscape (‘Landscape’)
To conserve and enhance the quality of landscape and townscape character in the District:
4A - Will the TNP result in a deterioration of the quality of the landscape or village-scape?
Objective 5: Heritage (‘Archaeology & Cultural Heritage’)
To conserve and enhance the quality and distinctiveness of the historical environment of the parish:
5A - Will the TNP protect and enhance designated features of historical or cultural interest (e.g. Listed buildings, archaeological sites, ancient monuments, Conservation Areas?)
5B – Will the TNP sustain and enhance the settings and views of heritage assets?
Statutory Consultation (A5)
The conclusions of this consultation will be considered by the Parish Council in finalising the SA/SEA assessment framework. That framework will then inform the formulation of the Pre Submission TNP and will be set out and employed in the accompanying Draft SA/SEA report. It is expected that draft TNP policies will be formulated and assessed against one or more reasonable alternatives to ensure any significant environmental effects have been identified and any necessary mitigation measures are included in the policies.
If you have any queries then please contact our planning consultant, Neil Homer, of RCOH Ltd at
mailto:firstname.lastname@example.org@rcoh.co.uk or call him on 07833 462991.
We look forward to hearing from you.
John Denman, Clerk to the Council
Thakeham Neighbourhood Plan: State of the Parish Report
(To be read in conjunction with the Additional Baseline Data in Appendix B)
SEE SEPARATE DOCUMENT (SOPR) SENT WITH THIS LETTER
Thakeham Neighbourhood Plan: Additional Baseline Data
(To be read in conjunction with the State of the Parish Report in Appendix A)
Trends and consequences
The settlement of Thakeham has been identifies as a Category 2 Settlement in the Core Strategy 2007 policy CP5 and as such has been identified as a village with limited services to accommodate small-scale development and defined by a built-up area boundary.
Storrington which is partly within the TNP area has been identified as a Category 1 Settlement in the same Core Strategy policy. It has been described as a town/village with built-up area boundary.
Due to the rural character of the parish, it is important to keep the settlement’s character. The TNP may allocate sites for development within or adjoining the village of Thakeham but only of a smaller scale to maintain the position of the village ij the hierarchy.
Listed Buildings & Conservation Areas
www.heritagegateway.org.uk & http://www.horsham.gov.uk/environment/11000.aspx
There are 39 number of listed buildings in Thakeham (3 are Grade I, 1 is Grade II* and the remainder are Grade II)
There are no scheduled monuments in Thakeham however the main part of the village is within a designated Conservation Area.
There is a Site of Archaeological Importance located to the west of Duke’s Hill B2139 and Storrington Road B2139, just west of the Conservation Area.
Thakeham has a large number of listed buildings, a Conservation Area and a Site of Archaeological Importance and therefore needs to ensure that any new development is sensitive to the character of the areas in which they are located.
Biodiversity & Environmental Conservation
Sites of biological interest
Sussex Biodiversity Centre and Horsham District Planning Framework Sustainability Appraisal
Large areas of the Parish are in the Entry Level Stewardship Scheme. This includes concentrations north of Hungerhill Farm, around Apsley Farm, west of Picketty Cottages, a whole zone along the eastern boundary of the Parish from Cray’s Farm to Orchardway Farm.
Two small pockets of land are in Woodland Grant Scheme 1 located south of Hungerhill Farm and Hungerhill Plantation, a zone in Woodland Grant Scheme 2 is located at Hungerhill Plantation and Apsley Farm, and multiple small areas in Woodland Grant Scheme 3 are located north and south of Abingworth and west of Thakeham.
The TNP area is within the protection zone of the Arun Valley SPA/Ramsar site of European importance and there are many Habitat Areas and areas under the Entry Level Stewardship Scheme and Woodland Grant Scheme.
Habitats identified around Henfield
Thakeham Neighbourhood Plan - State of the Parish Report
There are no Sites of Special Scientific Interest, AONB nor Local Nature Reserves within the TNP area.
The Parish does contain areas identified by Natural England as Priority Habitats and are subject to Habitat Action Plans:
Traditional Orchard Priority Habitat – 8 areas, one near Snowhill Farm, one near Voakes Farm, one adjacent to Hunger Hill in the north of the Parish, one at Warminghurst Farm on the eastern boundary of the Parish, one at Little Thakeham, one at Meadow Farmhouse, one on Greenhurst Lane and one adjacent to Spring Cottage.
There are Eleven areas of Ancient and Semi-Natural Woodland have been identified, including those at Dan Farm, Summer Place, between Acorns Cattery and Town House Farm, Guyhurst Copse and west of Manor House Buildings.
Deciduous Woodland Priority Habitat –forty areas (some very small) dotted across the entire Parish area, but with concentrations north of Cheviots Farm, Hungerhill Plantation, east of Red Cottage, west of Binfield Farm, north of Danfield, west of Danhill Farm, north of Dan Farm, numerous areas around Goose Green, around Warminghurst, around Abingworth, west of Little Thakeham, north and south of Greenhurst Lane.
Details of Nature Conservation Sites
There are no Sites of Special Scientific Interest within the Parish and no Local Nature Reserves. toric Landscape