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Response to: WD/2021/0174/MEA - MORNINGS MILL FARM, ROAD, WILLINGDON, BN20 9NY Outline application with all matters reserved, except for the means of access from Eastbourne road, for the comprehensive development of a mixed-use urban extension comprising up to 700 dwellings including affordable housing, 8,600 sq.m. of employment floor space, medical centre, primary school, community centre, retail, playing fields, children's play space, allotments, amenity open space, internal access roads, cycle and footpath routes and associated landscaping and infrastructure

Willingdon and Jevington Parish Council OBJECT to the application taking into account both our previous comments and observations when the last application was submitted reiterated here.

Over the last few years the numerous housing developments that have taken place in Hailsham, Hellingly, Westham, Stone Cross and have all had an adverse impact on Willingdon with much more traffic now clogging up the already congested A2270 which runs through Willingdon. Even during the recent Covid lockdown we have been amazed at just how much traffic has still been travelling along the A2270 through our Parish as well as numerous rat runs through our side roads.

If approved this application (and that of Hindsland in our Parish and whatever happens to the County Council adjoining site) would lead to the final urbanisation of the whole of Willingdon and concrete from the sea to the northern edge of Polegate.

We have already had 390 dwellings approved at Brodricklands/Hamlands Farm with a further recent application for 50 more dwellings to be built on that site. This current Mornings Mill Farm plan is for 700 houses and there is still the County Council land and also a large area of Mornings Mill Farm not part of the current application over the railway line. It therefore seems reasonable to suppose that, if passed, we could well end up having over 1200+ extra dwellings being proposed for our Parish and this is considerably in excess of the 700 dwellings proposed for the designated SDA 4 land. In the recent Scoping Opinion received from Danescroft for Hindsland – the former University of Brighton’s land – which we reiterate was originally gifted to them, we note that they are also proposing a medical centre along with 180 homes. If this application for Mornings Mill Farm is approved we will have lost the last remaining green area we have. Surely in the present economic times, we should be encouraging farmers to farm their land, not cover it with concrete which would apart from anything else, exacerbate flooding problems which already occur during periods of high rainfall. The Brown family currently rent much of Mornings Mill Farm for their livestock and we know are keen to continue to be able to do so. If this pandemic and leaving the European Union has shown anything, it is that we need to return to being a self sufficient country and stop increasing the carbon footprint by having to import goods including milk etc. What better way to retain this land than to make it or some of it into a Willingdon/Wealden Park to encourage wildlife to expand and have an appropriate recreational area, at the same time as retaining our local farmers who benefit from being able to use the land at present. The benefit to the local community and to the wider community would be huge and help with people’s social and mental wellbeing and provide somewhere where walking and cycling can be encouraged, not to mention people who have to use mobility scooters. We must remember, although close to the beautiful South Downs (the view from which will be blighted by this estate) not everyone is able to walk to them.

Housing Stock: The increase in housing stock is approximately 35% (440+180+700=1320/3700). There will be no proportionate increase in the existing infrastructure to the degradation of the lives of existing residents. Danescroft informed that their proposal fitted a template for mix of housing in Wealden and offer 434 bedrooms in their 180 dwellings. An increase in population in Willingdon from the three developments will lead to a population increase of over 4000 people in a village with a population of just 7440 in the last Census: an increase of over 55% - is this sustainable development? We very much doubt it. We understand there are already 2,800 additional houses committed to be built in Hailsham, Polegate and Westham, with 2,600 already completed.

Pollution: A further consideration should be the increase in air pollution in the area and in particular adjacent to the A2270 which with the pollution problems already well documented in the past with Ashdown Forest and also with the announcement not long ago that nearby Eastbourne has also been highlighted as the most polluted Town on the South Coast. It is well known that problems with asthma and respiratory diseases have increased over recent years.

Traffic: Over the last few years traffic along the A2270 has increased to such an extent that it is no longer limited to what used to be known as rush hour times, but is virtually all day every day. It only needs one incident on any of the nearby roads to mean that traffic queues result. This increased traffic and the fact that often it is at a standstill can only make the pollution issue worse and have a further knock on affect not only on Ashdown Forest but nearby Eastbourne and the health of local and neighbouring residents.

Infrastructure: Development of this area has always been subject to the necessary road infrastructure being provided. Knowing how the Polegate By-Pass, built to ease traffic onto this road only resulted in a very temporary relief, we feel that the few changes recently being made to the A22 and the A27 will not make the required improvements necessary to relieve the congestion encountered on the A2270 through Willingdon. The additional population will place further pressure on local infrastructure, which is already stretched to the limit. Our local schools which are very popular will be even more oversubscribed.

The current Eastbourne Road was built nearly 100 years ago. Once again the opportunity has not been taken to provide a vehicular access from Dittons Road or Golden Jubilee Way which would open up direct access to the wider road network. Instead the applicants have tried to squeeze more out of Eastbourne Road; a road which we all know is already subject to considerable pressures. Not so long ago, road works in Eastbourne led to traffic queues stretching back as far as Broad Road with vehicles trying to get into Eastbourne town centre and back as far as Polegate at certain times during the day. The queues experienced during the recent road works on the A22 and A27 have also resulted in gridlock at times, despite there being a lock down and less traffic on these roads.

The proposed access arrangements do not take into account the proposals in the Hailsham, Polegate and Eastbourne Movement and Access Corridor (HPE MAC) Consultation. The Stage 1 Safety Audit is not satisfactory clearly showing that more details need to be provided. It is already accepted that car travel will be slowed by the HPE MAC proposals. This application will result in much higher levels of traffic on the A2270 Eastbourne Road making it even slower with more pollution.

Given the level of traffic using the Broad Road junction with the A2270 which has increased with the recent expansion of Willingdon Community School and the proposed Medical Centre (which has already been allocated by way of Medical Facilities on Hindsland in the Danescroft application, and for which they tell us they have the CCG and Assura on board) the opportunity should have been taken to find alternatives to ease the traffic problems, although with the proposed amount of houses we cannot think of anything that would help. Improvements are also needed at the A2270/Gorringe Valley Road junction as well. The extra traffic would in our view also require changes to be made at The Triangle to ease access onto the Eastbourne Road. It also begs the question, why would we need two medical centres when we are told the other one proposed is for both medical practices in our area?

With the creation of 3 possible new access roads for two major developments, plus the HPE MAC proposals on the A2270 and surrounding roads there is a need for joined up thinking to ensure that the Parish does not end up at a standstill if they are all introduced. In addition there appears to be two ‘signalled’ junctions, one just to the south of Broad Road which will make it extremely dangerous for traffic trying to get out of Broad Road, and a further one where the pelican crossing is now within 100 metres, causing further hold ups and issues with further air pollution and danger for pupils accessing the school through Broad Road not to mention further rat runs through Willingdon to try to avoid traffic lights and queues. Improvements pedestrian/bike crossings across the A2270 at each of these new junctions are also needed.

The transport links would need to be improved with a road accessing Dittons Road and Jubilee Way with a bridge over the railway line and away from the residential centre of the village. Given the close proximity of housing near the railway line, an improved crossing will be needed where the 1066 route crosses the railway line. The Travel and transport structure would also need improvement in the hopefully unlikely event that this application receives approval.

The proposal seems to be a stand-alone community without measures being taken to integrate with the rest of Willingdon, with no connectivity to the Brodricklands Farm development site or any attempt to integrate with any other part of Willingdon.

Since the build out is anticipated to take many years and past the end of the Emerging Local Plan period, construction traffic is likely to blight the estate and area for a long time. There is nothing to indicate that there will be a separation of that traffic from the new residents and those using the new paths and roads to the proposed Medical Centre and school.

Medical Provision: Whilst we welcome the proposal for a much needed new medical centre for which we have waited for over 50 years, it is being suggested by the developers of Hindsland that one will be provided there. Is it intended that there will be two on adjacent fields and if only one will be provided, how then will the other field be developed? This also applies to the proposed land for a school. Without any certainty on that it is very difficult to judge whether the proposed access is acceptable.

Cemetery provision: It seems also appropriate to mention that our cemetery will be full over the next few years and there is nothing in this plan that would meet that need. If built, the residents occupying these new homes will all, at some time, need somewhere for them and their loved ones to be buried, whether that be burials or places for their ashes to be deposited. Despite the new Wealden Crematorium, our Cemetery remains a very popular resting place nestled as it is beneath the South Downs overlooking our Parish.

It is clear that the District Council is not in a position to determine applications which still have the potential to adversely affect the Ashdown Forest Special Area of Conservation (SAC) unless it is demonstrated that they will not damage the SAC any further. That is most definitely not demonstrated here or where these new residents will find work in this area without travelling very much further afield. A Business Park on this land would certainly not be appropriate for a Parish that has totally inadequate recreational facilities the need of which will not be satisfied or adequate by what is proposed on this site. They are also positioned on a slope leading to an area of flood plain.

In the outline plans there is no obvious attractive aspect either in the layout of the estate or the character of the development; just further urbanisation and quite unlike the residential developments in towns like Bath and Dorchester, a complete lack of any architectural merit. Any new homes, wherever built in Willingdon, should be of an appropriate design, in keeping with the rest of the village and give some thought to retirement homes or retirement village and care homes of which we have none. We constantly have local bungalow stock being enlarged and changed to houses giving local residents no bungalows or retirement type accommodation to downsize to in order that they may remain in the village.

With the expansion of Polegate Primary School and the expansion of Willingdon Community School, it is now extremely unlikely that a new school as proposed on this site will actually be needed. Additionally, water removal is not clearly indicated and the Pevensey levels Management board have stated this in their document. We remain doubtful that Southern Water would be able to cope with the increased housing numbers which obviously includes the Brodricklands Estate.

The proposed recreational space is very close to the attenuation ponds, which may render these sports pitches unusable due to the amount of water here. These pitches may therefore be of no use to the Council or residents. The last Wealden Local Plan also identified Willingdon as an area of ‘serious water stress’ and surely if anything this has got worse when you see all the residents complaining of waterlogged gardens which didn’t get so wet before. The aquifers obviously fill up and overflow down the South Downs to Willingdon and along towards this site. Along with the issues of climate change this should also be of major concern. An additional issue is the disposal of foul water.

We are also still very concerned about the wildlife in this area, including bats, rabbits (and hares which are rarely seen now) and which our young people will likely never have the pleasure of seeing if this plan is allowed to go ahead.

Recreational Deficit: On a planning matter for the village and indeed both Polegate and Willingdon there is an absence of recreational space in its various categories and in Willingdon to meet the Fields in Trust (National Playing Fields Association) metric of 6 acres per 100 population Willingdon alone requires about 15 hectares of flat land for playing fields plus allotments and green space within a reasonable walking distance. The removal of the green spaces of benefit to existing residents of Hindsland and Mornings Mill Farm raises the question of their replacement as with the playing fields where within a reasonable walk (hint: not up the northern escarpment of the South Downs) - will approval of these applications be the signal for Willingdon residents to travel to Ashdown Forest and create further traffic problems on the A22, A27 & A2270?

Mornings Mill Farm was not included in the last Emerging Wealden Local Plan and we could not understand why it was still included in the development boundary. At the Appeal Hearing in October 2019, the Inspector came to the same conclusion as the Parish Council that the infrastructure was not in place for a development of this size and nothing has changed since this time to suggest that enough measures have been taken to alleviate this shortage.

It was also previously stated by a Planning Inspector that no planning would be approved until the appropriate infrastructure was in place, appropriate being the vital word. This is most certainly not the case at present and it is highly unlikely in the present economic situation that this infrastructure will be provided any time soon. Between Willingdon and Polegate on the A2270, if this latest application is allowed, there will be 4 exits between The Thatchings and the pelican crossing in Willingdon onto the A2270 with the added potential of 900 extra houses and traffic for the medical centre and employment, trying to access the road within a very short distance.

Though the employment statistics for the area have shown reasonably low levels of unemployment (before the Covid pandemic) the statistics also show significant areas of deprivation including local South Weald new estates. The South Weald offers poor employment prospects in a low wage economy so either the new residents will commute necessitating using the already congested road infrastructure or by road to Polegate railway station without making extra parking provision or they will be self employed tradesmen using their 'white vans' as their office or depot which will require large parking spaces and be using the local road infrastructure both at peak times and also during the day which may not be properly factored into the TRIPS models. Until the Brodricklands development is completed and the residents in situ – just where these residents are going to come from and where they are going to work is anyone’s guess.

In addition the application has 8560 sq m of employment space which will attract extra traffic as few or no estate residents may be employed there. The extra burden on the strained road infrastructure will not be measurable until the type of employment is known.

The Council believes there are numerous valid reasons to REFUSE this planning application and ask that the District Council agrees and taking into account the Inspector’s conclusions in January 2020, turns it down. Nothing on the A2270 has changed during this time.

Stephen Keogh

Parish Clerk