5. Core Policy SD3: Major Development (Part 5 of 16)

5. Core Policy SD3: Major Development (Part 5 of 16)

This is part of the Coldwaltham Meadow Conservation Group’s comments on the pre-submission Local Plan for the South Downs National Park. We have commented on 14 different Policies and on the HRA and the SA. We have therefore made 16 separate representations, all in the context of Allocation Policy SD64. They consist of the following:

1. The SDNPA Habitat Regulations Assessment
2. The SDNPA Sustainability Appraisal
3. Core Policy SD1: Sustainable Development
4. Core Policy SD2: Ecosystem Services
5. Core Policy SD3: Major Development
6. Strategic Policy SD4: Landscape Character
7. Strategic Policy SD6: Safeguarding Views
8. Strategic Policy SD8: Dark Night Skies
9. Strategic Policy SD9: Biodiversity and Geodiversity
10. Strategic Policy SD10: International Sites
11. Strategic Policy SD12: Historic Environment
12. Strategic Policy SD19: Transport and Accessibility
13. Strategic Policy SD22: Parking Provision
14. Strategic Policy SD23: Sustainable Tourism
15. Strategic Policy SD25: Development Strategy
16. Allocation Policy SD64: Land South of London Road

The Coldwaltham Meadow Conservation Group considers the Local Plan to be unsound because:

The justification for Policy SD64 is not coherent with Core Policy SD3: Major Development.

(The core reference document in this respect is the Assessment of Site Allocations against Major Development Considerations - Technical Report (Envision, 2015 and update 2017), referred to in 4.24, p.48 of the Local Plan.)

Allocation Policy SD64 is Major Development

1. According to the Maurici opinions, referred to in the Local Plan, 4.19, Policy SD64 has been identified as a major development because it might potentially have adverse impacts on the National Park, and this is corroborated in the core document referred to above.Policy SD64 is considered in the 2017 update of the report to have the “…potential to have a serious adverse impact on the natural beauty and recreational opportunities of the National Park”. p.16

There are no exceptional circumstances that justify Policy SD64

2. The Local Plan is unsound because policy SD64 is not currently justified in terms of Core Policy SD3 by the above 2015 report or the 2017 update. There is no evidence that Policy SD64 currently confers any benefits in the public interest that demonstrably outweigh the great weight attached to the National Park Purposes. Both reports consider that ‘exceptional circumstances” in the public interest could be proved, providing a further survey of housing need is undertaken and that the various mitigation measures featured in Policy SD64 are effective. There is no evidence that a housing need survey has been undertaken by the National Park and in any event, this is not an adequate basis for destroying the only flower-rich hay meadow in the Arun Valley. It is a scarce cultural heritage asset that is also an integral part of one of the most scenic and biodiverse areas of the National Park. Both reports agree that there may be a public interest justification in the future, and for this reason, suggest that Policy SD64 should not come forward until the second revision of the Local Plan. If this is the case, then the National Park is acting in conflict with its own Policy Assessment. We cannot see why Policy SD64 is in the current version of the Local Plan, for there does not appear to be any current justification for this. Removing Policy SD64 from the Local Plan would at least provide an opportunity for a Regulation 18 Consultation about the site, which has been omitted by the National Park, due to the recent emergence (March 2017) of Policy SD64. As a result of our Groups’ protests about Policy SD64, other sites within the parish have come forward that are more suitable for development. These should be considered by the National Park as viable alternatives to Policy SD64. This is in the best interests of the local community and the environment that the National Park is supposed to conserve and enhance, and would also be in accordance with NPPF 167.

There is no evidence of local housing need for Policy SD64

3. The Assessment of Site Allocations against Major Development Considerations - Technical Report (Envision, 2015 and update 2017), both confirm that there is “no evidence of local housing need” for Coldwaltham and both reports consider that the houses under construction on the Silverdale estate will meet existing local demands for rented accommodation. The 2017 update cites the 2010 Defra Circular “English National Parks and the Broads UK Government Vision”, which recognises that National Parks are not suitable locations for unrestricted housing and that the National Parks “should focus on delivering affordable housing responding to local needs”.

3.2 This conflicts with the assertion in 4.8 of the same 2017 update that: “The SHMA identifies a longer-term demographic need for 13 dwellings per annum in the Horsham District part of the National Park. It may be appropriate to meet a proportion of this need in settlements in the SDNP to support local employment and services, subject to landscape and other constraints; but there are limited opportunities to do so in other villages… Coldwaltham, as one of only three villages in the Horsham part of the SDNP, will be expected to meet some of the local need. Other potential sites identified by the SHLAA for Coldwaltham are not considered suitable”. However, both the other villages in the Horsham part of the National Park, Amberley and Washington, have their own Neighbourhood Development Plans, and appropriate amounts of new housing will thus be built within these villages in accordance with their agreed local need. This removes the local housing need justification quoted in 4.8 of the 2017 update, referred to above, for building houses at Coldwaltham. The lack of a Neighbourhood Development Plan for Coldwaltham is unfortunate, but should not be considered an exceptional circumstances justification for Policy SD64, a housing allocation that is counter to SDNP Local Plan Objectives 1, 2, 3 and 5.

Horsham’s housing need is not considered an exceptional circumstance

3.3 The Local Plan is unsound in terms of Core Policy SD3 because the 2017 update referred to above, p.19, suggests that Policy SD64 is justified because it is providing housing for Horsham District Council and that this is in the Public Interest: This is not coherent with 4.6 of the same report: “…it is not considered that a shortfall in meeting a pro-rata part of the full objectively assessed needs in the HMAs of which the SDNP forms a part is in itself an exceptional circumstance in the public interest.”

Horsham’s housing need is already provided for

3.4 There is no evidence of unmet housing need for all three villages in the Horsham part of the National Park, and there is no evidence of unmet housing need in any other part of Horsham District Council (HDC). According to HDC’s SHELAA 2016: “…all SHELAA sites within the NP boundary were excluded from the Horsham District Council SHLAA” and that “Considering the information given above, the potential supply of identified sites considered ‘deliverable’ (1-5 years) and ‘developable’ (6-10 years), together with a windfall allowance of 50 units per annum is 9,845 units, which is more than sufficient to meet a ten year supply of housing sites as required through the NPPF.” There is no public interest justification for Policy SD64 in terms of Horsham District Council’s local need, because it is already provided for.

The SHLAA does not refer to Policy SD64

4. The Local Plan is unsound because Policy SD64 was not justified as suitable by the SDNP SHLAA 2016, as suggested above in the Assessment 2017 update. The SHLAA originally referred to a different housing allocation, known as Site HO015, Land at Brookland Way, located in a different part of the meadow. Site HO015 was placed in the lowest south eastern portion of the meadow, where potential screening could be provided by a mature hedgerow. HO015 was considered in the SHLAA to be of Medium/High Landscape Sensitivity and in this respect, was no different to the other sites in the village, (referred to in Appendix E to the SHLAA as HO08 and HO010) that were rejected by the National Park. Site HO015 also proved unsuitable; it was withdrawn in response to a variety of sound environmental objections made during the 2015 Preferred Options consultation. Moving Site HO015 to the top northern corner of Coldwaltham Meadow and calling it Policy SD64 does not make it suitable either; the same environmental objections apply, and the SHLAA Landscape Assessment of the northern extent of the site (the location for Policy SD64) is “High Sensitivity due to the elevation and openness”. This means that the impact of the allocation policy on the surrounding landscape will be even greater. It is more unsuitable than the original proposal and should be rejected on landscape sensitivity grounds. There is no evidence of any exceptional circumstances that would justify Policy SD64’s likely adverse impact on an area of such high landscape sensitivity.

Unjustified landscape description of Policy SD64

4.2 The Local Plan is unsound because the Core Policy SD3 assessment of Policy SD64 is not based on robust and credible evidence. Appendix E ofAssessment of Site Allocations against Major Development Considerations - Technical Report (Envision, 2015 and update 2017), describing the location for Policy SD64, states that: “The site constitutes an unexceptional flat field…it is a logical extension of the existing housing to the north and west of the site.” This is misleading, for it implies that the meadow is enclosed by housing development on two sides. There are no houses to the north of Policy SD64 (Lodge Hill Outdoor Centre is set back from the opposite side of the A29, over the top of the hill, and is hidden from view by the woodland below) and there is only one house to the west of Policy SD64. The majority of the housing is clearly the Brookview estate, which is to the east of Policy SD64. In fact, Policy SD64 is considered in the main body of the same technical report, to be “an incursion into the open countryside”.

4.3 Far from being an unexceptional “flat” field, the fact remains that Policy SD64 extends half way up Lodge Hill, which at 40 metres, is the highest point between Pulborough and the South Downs. The OS Explorer Map 121, scale 1:25000, shows 5, 10, 15 and 20 metre contours within the same site for Policy SD64. Similar information is shown on the SDNPA Settlement Baseline Map for SD64: Landscape Context, Topography, Flood Zone and River Corridor. The total difference in height from the top to the bottom of the field is c17 metres, and Policy SD64 is located at the highest point at the top of the meadow. This accords with the description of the site in Appendix D to the SDNPA SHLAA: “the site is High Sensitivity due to the elevation and openness at the northern extent of the site and along the public right of way”. This means that Policy SD64 will be highly visible in the landscape; it is not in the public interest to adversely effect a National Park landscape for the sake of 30 houses, which are in any event not justified in terms of local housing need or economic growth.

4.4 The Local Plan Core Policy SD3 assessment of Policy SD64 is unsound because the landscape mitigation proposals are not effective. The 2017 update report referred to above, considers: “Landscape proposals shown in the concept plan, and to be translated into a planning brief, indicate a means of mitigation.” However, the topography of the site, referred to above, renders the proposed mitigation undeliverable. The land specified for development in Policy SD64 is also 3 metres higher than the land of the adjacent Brookview estate. The Brookview houses are single storey here, and unless a considerable amount of spoil is excavated from the ground surface level of the new houses, they will be 3-4 metres higher than these existing dwellings. The Development Brief for Policy SD64 specifies that the houses should be two-storey, with steep pitched roofs; this will compound the problem and render the new buildings highly visible in the landscape. The native trees specified in the Development Brief to hide the buildings from view will have to grow to 30-45 metres tall to screen them from the valley floor to the south and west. This represents the maximum height for the tallest of our local indigenous tree species (as specified in the Development Brief) and it is highly unlikely that they will grow this tall in the open conditions of a meadow. In any event, it will take many decades, if not centuries, of growth to achieve this. It will also be impossible, due to the topography of the slope, for trees to screen the houses from higher viewpoints across the valley; even if a forest was planted, the houses and roofs would still be visible. They will be a blot on the landscape, visible for miles and the whole character of the open meadow would disappear. None of this is in the public interest.

4.5 The proposed development of public open space, associated with Policy SD64, with an additional car park for users of the open space, will also drastically alter the character of the allocation site, which when in flower, is probably the most colourful meadow in the National Park. The meadow is then even more prominent in the landscape, for it is the only flower-rich hay meadow in the Arun Valley. The meadow also has an important site separation function and the requirement listed in 9.51 of Policy SD64 that: “development must retain and improve that sense of separation between the two settlements” is not effective because it is not deliverable. Policy SD64, with its shop, car park, large area of landscaping and public open space, will significantly alter the open, rural, agricultural character of our surroundings. Only one 150 metre field will separate us from Watersfield; this will pave the way for the two villages to merge at a later stage. The two small villages will become a small town.

Poor transport links are not a public interest justification

5. The Local Plan is unsound because the following Core Policy SD3 Major Development justification, given in the Assessment update 2017 referred to above, for Policy SD64, is not coherent with the principles of sustainable development: “While it may be possible to find sites outside the designated area in Pulborough, these would not be true substitutes for sites in the village because of poor transport links…” The existence of poor transport links is actually a justification for allocating sites in Pulborough, precisely because they would be more sustainable in terms of minimising the need for transport links to the greater services and facilities that Pulborough offers. It is not a Public Interest argument for Policy SD64, which will result in the destruction of the scarce flower-rich hay meadow in Coldwaltham, and an increase of 12% in the housing stock of a village that has a very limited public transport option and a SDNPA Site Facilities Assessment score of just 2.5. (The score of 3.0 in the Site Facilities Appraisal is incorrect because we only have a part-time Post Office.)

Policy SD64 will only have a “marginal" effect on the local economy

6. The Local Plan is unsound in terms of Core Policy SD3 because Policy SD64 is considered in both the 2015 Assessment report and the 2017 update to “…have only a marginal effect in helping the retention of existing facilities and businesses” (2017 update, Appendix E). This is because Coldwaltham has so few services and facilities; new residents will have to drive elsewhere to gain employment, or access services such as health care, a dentist, a library or a bank. It is worth noting that this assessment of Policy SD64 is maintained in the 2017 update despite the inclusion of a shop and a 50% increase in housing allocation for Policy SD64. (The original 2015 assessment was of a 20-house development on a 1 ha plot.) A new shop could generate a few local jobs but there is no evidence that it will be commercially viable and we doubt that it will ever be built. 82 people attended a meeting organised on 19 October 2017 by the Parish Council to determine views about Policy SD64, and the offers of other alternative housing sites within the village, and, to quote the Parish Council report about the meeting: “Interestingly, the prospect of a “shop” facility was considered irrelevant by most speakers.” (source: Parish Council Notes, The Link, November 2017). This “marginal effect” cannot be considered a justification in public interest terms for destroying the only flower-rich hay meadow in the Arun Valley and the considerable negative impact on the landscape that would result.

A prior public interest justification

7. The landowner of the site for Policy SD64 has received a total in excess of £10,000 of public funding for enhancing the site’s biodiversity. (source: response from Natural England to a Freedom of Information request via Steve Dale, BBC Radio South, 24.7.17). It is not therefore in the public interest to ignore this. The site for Policy SD64 has been a flower-rich hay meadow for decades and the landowner had been in receipt of grant aid to maintain appropriate management of the meadow under the HLS Agri-environment Scheme for the last ten years, ending in November 2017. By accepting the landowner’s offer of the flower-rich hay meadow for housing allocation, the National Park has acted in conflict with Farming Policy 11 in the SDNPA’s Partnership Management Plan. In this context, Policy SD64 also lacks coherence with the National Park’s First Purpose, which is “To conserve and enhance the natural beauty, wildlife and cultural heritage of the area.” Policy SD64 also lacks coherence with Local Plan Objective 2 and development of the meadow is also counter to Local Plan objectives 1, 3, 4, 5 and 9.