CPRE Sussex has been active within Mid Sussex in challenging three significant and inappropriate greenfield development schemes.
The first involves ongoing proposals by Gleesons to develop a greenfield site in Hassocks that would seriously erode the already narrow local gap that separates the distinctive communities of Hassocks and Hurstpierpoint. We first wrote to the Council about this site nearly two years ago. Gleesons are now on the third iteration of their scheme with an unsuccessful planning appeal and an outstanding court case keeping them and us busy in between. Much credit is due to the local action group, Protect Ham Fields, for their robust opposition.
Secondly, we can report that the District Council refused permission to Linden Homes to build up to 200 homes on farmland just outside East Grinstead. CPRE’s objections to this proposed development were clearly heard. Those objections centred on concerns as to its serious impact on the local landscape and agricultural land character and on a significant heritage asset; implications for local traffic infrastructure and Habitats Regulations considerations. It remains to be seen whether the developer will appeal the Council’s decision.
Lastly, in support of the Lindfield Preservation Society, we are opposing, a Wates scheme to build another 200 houses on the outskirts of Lindfield (in addition to the 160 nearby for which they already have consent). Lindfield is a unique jewel of a village, as its conservation status attests. Surrounding it with a mass of incongruous housing estates does significant permanent harm to its heritage value and overwhelms its roads and services. Allowing 200 houses to be built on the outskirts of Lindfield would be incompatible with the evidence from an important Landscape Capacity study commissioned by MSDC in relation to its draft District Plan, which advises that the District’s villages only have the capacity to accept small scale housing. Acceptance of this application would be the antithesis of sustainable planning.
Mid Sussex draft District Plan: yet more madcap ideas, consultation and delay
Mid Sussex District Council consulted last summer on what was supposedly a final draft of its District Plan prior to its submission to the Planning Inspectorate last autumn for public examination and, MSDC hoped, its adoption in the spring of this year. None of that has happened. Instead MSDC has been forced into two further rounds of public consultation on a range of further changes to their draft plan, the second of which closes on 15 January. CPRE Sussex has made extensive comments at each stage of this extraordinarily protracted process.
The most significant of the latest round of changes involves a significant increase in the District's new annual housing target to 800 dwellings (the proposed target that they thought was needed was 530 as recently as 18 months ago). Not only is the Council now expecting to have to build at a rate of 695 dwellings per annum (dpa) to meet the District's own needs, but it is additionally offering to build a further 105 dpa to help Crawley to meet that Borough's needs. And all this takes no account of the continuing risk that the Government will decide in favour of a second runway at Gatwick ...
CPRE Sussex has queried the way in which MSDC has calculated the District's housing needs, and has been arguing for a long time that, with so much of Mid Sussex being classified as specially protected, the District lacks the capacity sustainably to build so many houses. 60% of the District's area is within either the High Weald AONB or South Downs National Park; it borders two areas on Ashdown Forest that enjoy even greater levels of protection under EU law; nearly 16% of the land area is covered in ancient woodland; there are 50 Sites of Nature Conservation Importance within the District and 13 Sites of Special Scientific Interest. In our view the Council has lost sight of the fact that Mid Sussex is a largely rural district (as the introduction to the Council's Plan itself acknowledges), that the evidence base on which the Council itself relies tells them that outside the main towns the District only has the capacity to accept small scale development, and that the planning rules themselves (the National Planning Policy Framework) require planning authorities to take account of capacity constraints in setting their housing target. We have expressed concern that the Council's Plan lacks a proper rural spatial development strategy.
There is, in CPRE's opinion, a serious gulf between the new 800 dpa housing target that the Council is volunteering to set itself and the reality of its ability to deliver. Evidence the fact that MSDC has only been able to deliver an annual average of 493 net completions over the last decade; or 532 pa in the last 5 years to March 2015 – a period during which it mostly operated under the NPPF presumption in favour of allowing planning consent to be granted for any new development proposed anywhere that is sustainable. If the Council falls short in meeting whatever new housing target is approved in its new Plan - and its past record suggests that it may well do so - it will find itself back into the current dire situation where it again loses control over the District's strategic planning, and ever more greenfield sites selected by developers will become free game for building. The Council itself is already predicting that it will need to start looking for yet more new development sites in 2019.
Key to the Council's proposal to contribute to meeting Crawley BC's excess housing needs is its new proposal to allocate a 250 acre "strategic" site for 600 new houses at Pease Pottage. 6 months ago MSDC itself described this same site as "very unsuitable" for development. CPRE Sussex agrees with that description. Not least for the fact that the site is within the High Weald AONB, ignores the wishes of the local Slaugham Parish as expressed in their draft Neighbourhood Plan and makes a mockery of the restrained rural development policies that MSDC intends to include in its own plan. CPRE Sussex will be fighting hard against the allocation of this site in the District Plan and has made extensive representations to MSDC to that end. It is all the more disturbing that as a result of discussions between the Council and Thakeham Homes a planning application has already been submitted for this site even ahead of the decision on whether it should be allocated for development.
CPRE Sussex is concerned that MSDC has been panicked into this last minute proposal substantially to increase its housing target and to allocate the proposed new strategic site in Pease Pottage. It has produced no robust evidence to justify these changes, and has failed to undertake a proper analysis of their implications. In our view the evidence is that they are unsustainable, undeliverable and ineffective, and that the District lacks the capacity to absorb the level of housing proposed. The proposals are inconsistent with the National Planning Policy Framework (NPPF) and fail all the tests required of a sound Plan.
CPRE Sussex is equally disturbed at the unsustainability of another proposal to set a new high housing density policy. This proposal reflects a problem caused by an unrealistic housing target. Its solution lies in reducing that target to one that is achievable and sustainable, not in over-intensive housing density or in threatening to allocate yet more greenfield sites to meet that misguided target.
In our latest representations we make suggestions to strengthen other proposed policy changes, including extending the same broadened protection of the South Downs National Park to the High Weald AONB, and to increase the robustness of a significantly weakened Sustainable Design & Construction policy.
For those of you with the will and strong enough constitutions to do so, the full text of CPRE Sussex's latest representations can be downloaded at the bottom of this page.
