Let us start by highlighting Horsted Keynes. What a particularly special village it is: perched on a hill off the beaten track with splendid 360 degree views across the High Weald AONB with its historic Saxon church (St Giles’s) occupying a pre-Christian religious site, its central conservation area, its Bluebell railway connection and a community of some 620 homes. To thrive, it is a village that needs some development to meet the growing needs of its local community, including younger people. But that development needs to avoid overwhelming it or undermining its sensitive location in the heart of the High Weald. The Community has taken its time, and not without a struggle, to develop a neighbourhood plan that seeks to ensure Horsted Keynes's healthy future in a manner which reconciles these conflicting pressures. That neighbourhood plan identifies the level of growth that the village deems healthy, the types of homes that are most needed and the most suitable locations for those new homes. The Plan has now been submitted for public examination.
In the last couple of years before the adoption of Mid Sussex’s new Plan - whilst the district was failing to meet its housing target and had lost control over the location of new housing - developers were circling Hosted Keynes and had come up with a number of potential schemes on various greenfield sites outside the village that could have seen up to [270] new houses built in unsustainable or marginally sustainable locations; developments that would have had scant regard to the needs of the local people or the conservation objectives of the High Weald. Developments that were strongly opposed by many residents and by CPRE.
The good news is that none of these proposed developments managed to squeeze through the planning system before the new District Plan was adopted or the Neighbourhood Plan submitted for examination. And since the Plan’s adoption one of the main threatened schemes has been withdrawn and a second one has been refused permission based on its incompatibility with housing policies in the New District Plan and the possibility of harm it might cause to Ashdown Forest. Other schemers should be deterred by this outcome.
Huge credit is due to local people who campaigned against these schemes and energised the community against them. CPRE Sussex worked with those local campaigners to see off these insensitive, unsustainable development proposals. We much appreciate their feedback which included the comment: "thank you [CPRE Sussex] for the tremendous work that you have done in supporting us, guiding us through this process and, not least, for the masterful submission that you made on behalf of CPRE. You really have been inspirational!”
As a result of the community’s efforts in developing a neighbourhood plan that works for Horsted Keynes, and their resistance against wholly unsustainable developer schemes, and with the new District Plan now in place we hope that the village's future is assured for years to come.
We can point to recent successful outcomes on other fronts too. We have been active in drumming up opposition to a humungous scheme to redesign Cuckfield golf course - also in the High Weald AONB - that could have involved dumping over half a million tons of waste over a three year period. Mercifully, that proposal has itself now been dumped. Local campaigner, Gerard Conway wrote to us to say “Very many thanks for your invaluable input. You [CPRESx] have been a major driving force in getting underneath the surface of the proposal and cutting through the top spin (both puns intended)”. However the threat remains of a different type of adventure tourism scheme at the same location, and CPRESx is monitoring the position along with local residents.
Aside from these individual successes, the most interesting and significant news is the unexpected approach that MSDC has adopted since its new District Plan came into effect to windfall development applications (i.e. new applications on sites not allocated under that Plan). It is an established fact that diesel emissions from traffic crossing Ashdown Forest - an area protected under the so called Habitats Regulations on account of its very rare heathland habitats - is causing harm to those habitats. MSDC (on dubious evidence) satisfied the Planning Inspectorate that its new Plan with its initial new housing target of 876 dwellings p.a. would not exacerbate pollution levels and that the Regulations did not require the Plan to do anything to improve the existing level of harm. MSDC believes that they can meet that target through a combination of permissions already granted since the 2014 Plan start date, development on sites allocated under the new Plan and up to 490 windfall homes permitted elsewhere. All those assumed 490 windfall homes have already been given planning permission.
Importantly the Habitats Regulations Assessment on which MSDC relies did not assess the impact of a higher level of housing growth, and a new Habitats Regulations Assessment will be required before the proposed increase in the District’s housing target to 1,090 dpa in 2024 can come into effect. The consequence of all this is that, unless and until a new Habitats Regulations Assessment concludes a higher level of housing, and the linked traffic flows, will not add to the damage to the heathlands, MSDC has to manage their new Plan to cap the level of new housing at the current Plan target of 876 dpa. This is unusual - housing targets are normally minima not maxima.
MSDC appears to be seeking to achieve that at the moment by refusing permission for all further windfall development applications. This has led them to reject a number of planning applications in the last couple of months, including for example an application for 167 homes on an unallocated site near the Duke’s Head roundabout between Crawley Down and Copthorne. For so long as MSDC sticks to this way of dealing with windfall applications on unallocated sites, we can expect to see decisions based, as they should be, on the new Plan policies and allocated sites. Whilst we can question the wisdom and deliverability of the housing targets set in the new Plan - as CPRESx did long and hard throughout the Plan development and examination process - we can at least be grateful that the Council now seems committed to following that Plan and refusing ad hoc greenfield development on unallocated sites.
In the medium term, though, we have to prepare ourselves for the potential further uplift in the District’s housing target early in the next decade. That will require MSDC
- to review its current assessed housing need,
- to consider once again offering extra land to accommodate overspill from other Districts,
- to find yet more development sites to allocate, and
- to demonstrate that any proposed increase in the housing target (the Plan presently assumes an increase to 1,090 dpa) can be delivered without further detriment to Ashdown Forest’s air quality.
As a postscript, it is iniquitous that the law seemingly allows a new Development Plan such as MSDC’s new District Plan to do nothing to improve the air quality that has been established as already harming rare habitats that are deemed sufficiently are and special to require special protection from development. The Habitats Regulations prohibit a local plans or development around such a site unless it can be shown that, when considered in combination with other plans and proposed development, it would not cause significant unavoidable harm to it; but, shamefully, those Regulations don’t appear to require a Plan to do anything to rectify an already degraded protected site. Once the harm has happened, nothing has be done to make it right. So much for Government’s oft-repeated commitment “to be the first generation to leave the environment in a better state than we inherited it”.
Michael A. Brown
