Mr. James Appleton (Case Officer)
Adur and Worthing Councils
Planning Services
Portland House
44 Richmond Road
Worthing, West Sussex
BN11 1HS

Dear Mr Appleton,

AWDM/0961/17  Hybrid planning application seeking (1) Full planning permission for the demolition of existing buildings and erection of 249 dwellings with temporary access via Grinstead Lane, a Country Park, relocation and extension of the Withy Patch Gypsy and Traveller site, permanent access via a new roundabout on the A27, landscaping, and other associated infrastructure (including pumping facility at the River Adur); (2) Outline planning permission (with only landscaping reserved) for a non-food retail store (Use Class A1); and (3) Outline planning permission (with all matters reserved other than access) for the erection of a further 351 dwellings, community hub, primary school, and landscaping.  Land West of New Monks Farm, Mash Barn Lane, Lancing West Sussex

This letter is a holding response from CPRE Sussex in response to the above application, pending receipt of further information on a number of important matters which bear significantly on the planning merits of this case (for example, the Adur Local Plan Inspector’s Report and additional information on the impact of the proposed development on the A27 trunk road and on managing flood risk and surface water drainage). Accordingly, we reserve the right to make further comments when this information becomes available.
CPRE Sussex works to promote the beauty, tranquillity and diversity of the Sussex countryside by encouraging the sustainable use of land and other natural resources in town and country. We encourage appropriate and sustainable land use, farming, woodland and biodiversity policies and practice to improve the well-being of rural communities.

We have considered the planning policy background, the planning application and the supporting information provided with it and we have the following comments to make:

(a) Planning policy

1. The application site is in open countryside which is not allocated for development in the adopted Adur Local Plan (1996). It comprises the western part of a “strategic gap” of open land between Lancing and Shoreham. Although the adopted plan was intended to run only to 2006, some of its policies have been “saved” and remain in force as part of the development plan for the area. These include the following policies:

• AC1- Protection of the countryside : this protects the countryside for its own sake and strictly controls outside which does not need to be located there
• AC4- Protection of strategic gaps: this protects countryside which forms an important gap between built up areas in order to prevent their coalescence and to retain their separate character ad identity.
• AP4 and AP5- Development and land drainage: these policies seek arrangements to provide appropriate land drainage arrangements in order to avoid, manage or mitigate flood risk problems both on and off development sites.
• AH3- Housing to meet local need: negotiation of an element of social housing to meet local need
• AP11- Listed buildings: protection of the setting of listed buildings.

2. As the application proposals clearly conflict with policies AC1 and AC4, they would be a departure from the development plan, requiring reference to the Secretary of State to see if the proposals should be “called in” for his own determination following a public inquiry. In doing so, the Secretary of State will need to consider the impact of the proposals over a large area extending beyond Adur District in terms of loss of a significant part of one of the few gaps of open countryside on this part of the Sussex Coast; the impact of a large “out of town” retail development on nearby town centres; impact on the adjacent National Park landscape; and impact on the A27 trunk route.  

3. The 1996 Local Plan is being replaced by a new local plan. Adur District Council submitted a new local plan to the Secretary of State for examination in 2016. The examination was held in January- February 2017. The Inspector’s report is not yet available, although he indicated his preliminary findings, and suggested some matters requiring further attention if the plan is to be considered “sound” in May 2017. The new Local Plan has had to consider provision of additional land to meet the need for more housing and employment over the period to 2031. CPRE accepts that this is a very difficult task in a district which is small geographically and where there is little available land between the South Downs National Park and the sea, and where extensive areas are also subject to various forms of flood risk.

4. As part of its strategic development provision, the new local plan is proposing a major allocation of land at New Monks Farm, which largely coincides with the application site. The proposed allocation in Policy 5 of the new local plan comprises:

• Around 10,000 square metres of commercial floor space
• 600 new homes, of which 30% would be affordable
• A primary school
• A relocated and enlarged site for Gypsies and Travellers
• A community hub
• A country park

5. This proposal has been very controversial and has prompted considerable local debate, particularly in terms of its impact on the strategic gap between Lancing and Shoreham; flood risk; the A27 trunk road; and the local landscape and heritage. CPRE Sussex has raised significant concerns on all these matters throughout the local plan process. Although preparation of the new local plan is well advanced, its “soundness” and overall planning strategy, including the major allocation at New Monks Farm, have not yet been endorsed by an independent inspector. Therefore, CPRE Sussex considers that any decision to grant planning permission in advance of the Inspector’s report would be premature and prejudicial to the local plan process.

6. Publication of the Inspector’s report is expected in the near future. Accordingly, CPRE Sussex would like to reserve the right to come back with further comments on the application proposals once this report is published. Even when the inspector’s report is available, there are material differences between the proposed local plan allocation and the current planning application, (for example, in the extent of the strategic gap taken by development and in the size of commercial floor space – both of which are larger in the application, the latter considerably so.) This means that careful detailed consideration of the planning merits of application proposals will be necessary, even if Policy 5 receives the Inspector’s broad endorsement.

(b) Strategic gap between Lancing and Shoreham

7. The safeguarding of this strategic gap has been a longstanding feature of local planning policy in the area. Policy AC4 from the 1996 plan has been carried through into the new local plan, where Policy 14 seeks to maintain the gap between Lancing and Shoreham in order to prevent their coalescence and preserve their separate character and identity. Notwithstanding the new local plan work and the applicants’ declaration of a “landscape-led approach”, there is no getting away from the fact that you cannot protect a strategic gap by building over a large part of it and thus narrowing the open countryside which separates the two settlements.

8. To a limited extent, the strategic gap has been compromised by the Brighton & Hove Albion FC training complex immediately to the south of the application site. However, the training complex has a relatively small building footprint in comparison with the extensive open areas given over to playing pitches, albeit with some floodlighting and high netting fences (both urbanising features). As such, it does not set a precedent for the much more extensive and intensive form of development proposed in the current application, which has a far greater visual impact on the strategic gap.

9. This impact is offset by the country park proposals on the eastern side of the application site, but nevertheless the strategic gap between Lancing and Shoreham is reduced by about one-third, leaving only the airport – with a narrow ribbon of development along the A259 frontage- as an intervening open area.

(c) Flood risk 

10. The application site is on the tidal flood plan of the Adur and falls predominantly within Flood Zone 3a in the national classification of flood risk (high probability). The site is at risk not only from tidal flooding, but also from surface water flooding and groundwater flooding. The whole site and surrounding areas have a greater than 75% risk of flooding from groundwater. This is not a theoretical risk: parts of the site have flooded at various times in recent years, most recently in the winters of 1994 and 2003 with flooding in the surrounding area in the winters of 2012/13 and 2013/14 2014/15 and 2015/16.

11. CPRE Sussex have submitted extensive comments on the flood risk issue as part of its submissions on the 2016 pre-submission Local Plan, where we set out in detail our concerns over flood risk on the proposed allocation site. Notwithstanding the efforts of the applicants to address flood risk issues in the current application proposals, we remain concerned that surface water drainage and groundwater issues have not been adequately addressed and that, accordingly, the scheme does not accord with national guidance on development and flood risk.

12. The Environment Agency’s Shoreham Adur Tidal River Walls project will raise and strengthen flood defences along the west bank of the river and so mitigate some of the tidal flood risk arising from rising sea levels and increased risk of storm surges. The application proposals will benefit from this investment in improved flood defence. However, CPRE Sussex remains concerned about surface water drainage and groundwater flooding for the following reasons:

• The flatness of the site means that there is only a minimal hydraulic gradient to drain off surface water and groundwater into the two outfalls into the Adur
• Effective drainage of the site requires a very high standard of maintenance on surface water drains and ditches across the application site, and beyond, eastwards to the Adur. There do not appear to be any long-term arrangements, with dedicated funding (including an instant access performance bond) to ensure that this takes place
• The two outfalls on the Adur are tide-locked for about half of any given 24 hour period. The application fails to consider the effects of sea level rise on the effectiveness of the sluices over the lifetime of the development. This is a significant omission as over time the sluices will be tide-locked for longer and longer periods increasing the need for attenuation within the whole Lancing Brooks ditch network. Unless this is addressed, the outcome would be increased risk of flooding in the surrounding area.
• The applicants place undue reliance on “filtration” methods of surface water drainage, which are unlikely to be effective in an area with high ground water levels and the illustrative masterplan appears to offer little in the way of “attenuation” methods (to store and slow water run-off in extreme rainfall events) such as swales and holding ponds
• The application proposals include some land raising and the impact of this on surface water drainage and flood risk elsewhere needs to be explicitly assessed
• Monitoring data which has informed the FRA is too limited and takes no account of the effects on groundwater from 1/100 year events. Monitoring should have been carried out for a longer period to fully understand the implications of groundwater on the drainage systems, particularly in extreme weather conditions.

13. These concerns are reinforced by the conclusions of C2HM Hill’s Lancing Surface Water Management Plan for West Sussex County Council in September 2015, which concludes that:
Even with all of these ( mitigation ) measures in place , Lancing will still be at risk of flooding during more extreme weather events. This is because drainage systems (both natural and man-made) and any other flood risk infrastructure will become overwhelmed during extreme weather events. In addition, Lancing is highly vulnerable to groundwater flooding (or drainage is affected by groundwater levels), which is significantly more technically and economically challenging to manage

14. In light of these concerns, and any further comments on flood risk issues in relation to the proposed allocation site by the Local Plan Inspector, Adur District Council should rigorously apply the “sequential” and “exception” tests to the application proposals to ensure that the development of this low-lying site can be justified and is safe for users and occupants of the buildings for its lifetime without increasing flood risk elsewhere, as per the National Planning Policy Framework (NPPF.)

(d) Transport

15. The site adjoins the A27 trunk road which already carries around 60,000 vehicles per day in this area, about two-thirds of which is local traffic and one-third through traffic along the south coast. The standard of the A27 is very variable. To the east of the application site, the Brighton & Hove By-Pass is a high capacity dual carriageway road with grade separated junctions. However, to the west through Lancing and Worthing, the standard of the road varies between single and dual carriageway. In addition, there are many busy junctions at grade with roundabouts and traffic lights, together with residential and business properties with access directly onto the A27, all of which slow traffic. As a result, the road is very often congested and has a poor accident record. Highways England has recently published for consultation a package of improvements to the A27 between Worthing and Lancing. The proposals focus on improving the capacity, safety and free flow of traffic around key junctions.

16. The addition of a set of large scale traffic generators on the application site – particularly the proposed retail store - will add considerably to traffic on the A27. The applicants have proposed a new signal-controlled roundabout to act as the main access to the site. CPRE Sussex is concerned about the capacity of the local highway network to handle this extra traffic, particularly given the propensity of the proposed retail use to generate longer distance trips. We note that both Highways England (responsible for the A27) and West Sussex Highways (the local highway authority) have a number of concerns in relation to the Transportation Assessment accompanying the application and are seeking further information to clarify the impact of the proposed development. At this stage, it remains unclear whether the application proposals are satisfactory in traffic terms and how - and when- any necessary off-site highway improvements would be financed and delivered. We understand that the applicants are seeking external grant assistance for some elements of off-site infrastructure. In addition, it is not clear how the application proposals relate to Highways England’s current proposals for A27 improvements. 

(e) Heritage

17. The application site immediately adjoins the South Downs National Park, which lies to the north of the A27. It is understood that the applicants are clarifying with the National Park Authority whether any part the application site extends over into the designated area. The two statutory purposes of the national park are:
To conserve and enhance the natural beauty. wildlife and cultural heritage of the area
To promote opportunities for the understanding and enjoyment of the special qualities of the National Park by the public

18. Although all (or perhaps almost all) the application site lies outside the South Downs National Park, the impact of the proposed development on the purposes and setting of the national park are material planning considerations . This means that the impact of the proposed development on views out from the higher ground to the north within the national park and views into the national park from the application site and other undesignated areas to the south, both have to be taken into account. CPRE Sussex is concerned that this material consideration has not been given due weight in the application proposals.

19. Two examples illustrate this failure to properly consider impact on the setting of the national park. First, the applicants own analysis indicates a “moderate to major” visual impact from the commercial housing elements of the application proposals, but fails to indicate how these impacts will be managed and mitigated to make them a harmonious neighbour to the national park. The bulk, colouring and branding of the retail building are plainly driven by commercial requirements rather than fitting it into its surroundings, as a “landscape-led” approach would require. Secondly, from many public vantage points, the scheme sits in the foreground of one of the best-loved views of the South Downs, namely the iconic collection of Lancing College buildings (many of which are listed) on a downland ridge above the Adur Valley.

20. The second national park purpose of promoting public understanding and enjoyment will be affected by the application proposals for changes to pedestrian and cyclist access to the national park from residential areas south of the A27. This has been the subject of many objections to the application proposals by local residents, equestrians and cyclists. CPRE Sussex shares these concerns.

(f) Cumulative impact

CPRE Sussex is aware that another major application has recently been submitted by Albermarle (Shoreham Airport) Ltd. on a nearby site at Cecil Pashley Way Shoreham Airport (AWDM/1093/17)

The application is for "Outline planning permission for the erection of new commercial buildings with an overall height of 14ms to provide up to 25000m2 of floorspace for Light Industrial (Use Class B1c), General Industrial (Use Class B2) and Storage and Distribution (Use Class B8) with access, landscaping and associated infrastructure (including a new pumping facility on the River Adur)"

Whilst Adur DC is legally obliged to consider New Monks Farm and this other application on their own individual planning merits, there are clearly overlapping issues which will require their cumulative impact to be considered. These issues are:

• Compatibility with Policy 5 and Policy 7 of the emerging Adur Local Plan (if that is endorsed by the Inspector)
• Impact on the integrity of the strategic gap of open countryside between Lancing and Shoreham
• Impact on flood risk and land drainage over the two application sites and adjacent areas on the tidal flood plain
• Traffic impact on the A27 and the local highway network
• Impact on local natural and historic heritage, particularly the National Park and the setting of important listed buildings

CPRE Sussex urges Adur DC to give careful consideration to these cumulative impact issues which, if both applications proceed, can only intensify our concerns about the harmful impact of these major developments on the local area.

Conclusion 

CPRE Sussex wishes to lodge a holding objection to the application proposals for the reasons set out in paragraphs 1-20 above.

We urge Adur District Council not to determine this application until the Local Plan Inspector has published his conclusions on New Monks Farm, and further information is provided on the technical issues highlighted above. At that time, CPRE Sussex would like the opportunity to review this submission and add to, or modify it as necessary.

We trust these points will be taken into account in determining this application.

Yours sincerely,

Kia Trainor CPRE Sussex

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