Proof of Evidence: Impact of the Proposed Development on the Ashdown Forest SAC Author: Zoe L Wangler BSc (Hons) Ecological Land Limited

Planning appeal: Council, non-determination planning application WD/2017/0340/F

Description: Siting of three temporary agricultural workers’ dwellings for a period of 5 years together with an agricultural barn with PV array and alterations to existing highway access to provide three affordable smallholdings to new entrants to ecological agriculture

Location: Field south of Copyhold Cottages, Arlington, , BN26 6RU

June 2018

CONTENTS

Qualifications And Experience ...... 2 1 Summary ...... 4 2 The Threat to the Ashdown Forest SAC ...... 8 3 Overview of Existing Traffic Through the AFSAC ...... 14 4 Projected Trip Generation & Traffic Flow from the Proposed Development ...... 16 5 Vehicle Trips Removed ...... 30 6 Overall Impact on the AFSAC of the Proposed Development ...... 34 Acronyms and Abbreviations ...... 37 Appendix 1: Details of the Traffic Counter at Greenham Reach Smallholdings ...... 38 Appendix 2: Calculations for Trip Generation and Traffic Generation ...... 39 Appendix 3: Survey of Greenham Reach Residents ...... 40 Appendix 4: Description of Greenham Reach Residents and Farm Businesses ...... 41 Appendix 5: Mileage Reported at Greenham Reach and Mileage Calculations ...... 42 Appendix 6: Calculations for Trips Avoided ...... 43

Figures and Tables Figure 1: Map of Ashdown Forest showing SAC and SPA ...... 9 Figure 2: Relative Contributions of Nitrogen Deposition at AFSAC away from Roadsides ...... 11 Table 1: Measured Traffic Flows at Points Across the AFSAC from WDC ..... 14 Figure 3: Map Showing Locations of Traffic Counters ...... 15 Table 2: Average Annual Mileage of LID Projects against National Averages 17 Table 3: Ecological Footprints of LID Projects against National Averages ..... 18 Table 4: Distance Between Appeal Site and Select Towns and Villages...... 21 Figure 4: Map Showing Proximity of Appeal Site to the Nearest Point within the AFSAC ...... 22 Figure 5: Maps Showing Road Links from Appeal Site to Nearest Primary, Secondary, District and Service Settlements: , , Hailsham and ...... 23 Table 5: Journey Times from the Appeal Site to Points in 6pm, weekday ...... 24 Table 6: Summary of Projected Total Trip Numbers and Trips through the AFSAC Based on Greenham Reach (per Year) ...... 28

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QUALIFICATIONS AND EXPERIENCE

My name is Zoe Lelah Wangler. I hold an honors Degree of Bachelor of Science in Development Studies. In 2007 I co-founded the Ecological Land Co-operative (ELC), taking the role of Managing Director in 2009. I stayed in this post until 2015 at which point I became my mother’s carer. I currently work part-time for the ELC.

I was responsible for the planning application for the appeal site including co- ordinating public and stakeholder consultations. I prepared the planning applications and appeal documentation for an ELC site with a similar scheme of affordable starter agricultural holdings in Mid Devon District and gave evidence at the public inquiry in 2013. I have also been responsible for monitoring, amongst other indicators of sustainability, the traffic generated by the ELC holdings in Mid Devon.

My work, education and training prior to the ELC is relevant to this proof of evidence, as follows. Whilst an independent environmental researcher and consultant I carried out the following: a. a report and briefing for Department for International Development (DFID) providing staff with baseline information and data relating to the scale and significance of horticulture production and exports from Sub-Saharan African countries in driving climate change compared to production in other countries1. This was prepared to inform DFID staff in developing their public statements on the issue of Sub-Saharan exports, and to support them in discussions on future research and on policy formation; b. working with the Food Commission, assessed for the National Consumer Council (NCC) the practicality of benchmarking food retailers’ practices and policies to help consumers to shop more sustainably2. The report for the NCC

1 Wangler, Zoe (2006) Sub-Saharan African Horticultural Exports To The UK And Climate Change: A Literature Review Fresh Insights Number 2, International Institute for Environment and Development, available at: http://www.sustainweb.org/pdf/SSA-airfreight.pdf 2 Dalneny Kath, and Wangler, Zoe (2005) Greening Supermarkets: Do Supermarkets Help Consumers Buy Sustainable Food?, the Food Commission, available at: https://www.sustainweb.org/publications/greening_supermarkets/

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led to multiple surveys and reports from the NCC which I also contributed to, including their 2006 publication “Greening Supermarkets”;

From 2001-2004 I worked as Project Analyst, and a member of the management team at the Tenderloin Neighbourhood Development Corporation. This well- established non-profit organisation builds and manages affordable housing and provides social services to tenants in San Francisco’s Tenderloin district.

The evidence which I have prepared and provide for this appeal in this proof of evidence is true and I confirm that the opinions expressed are my true and honest opinions.

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1 SUMMARY

1.2 This proof of evidence relates to a planning appeal made pursuant to Section 78 of the Town and Country Planning Act 1990 in respect of a field to the south of Copyhold Cottages, formerly part of Wilbees Farm, Arlington, Hailsham, BN26 6RU (the Appeal Site).

1.3 The planning application the subject of this appeal sought permission for:

‘the siting of three temporary agricultural workers' dwellings for a period of 5 years together with an agricultural barn with PV array and alterations to existing highway access to provide three affordable smallholdings to new entrants to ecological agriculture’ (the Proposed Development).

1.4 The application was validated in March 2017 and has not been determined by the LPA, Wealden District Council (WDC). An appeal was lodged October 2017. The appeal was given the reference APP/C1435/W/17/3189734.

1.5 WDC’s view is that the application should be refused for two reasons:

a. The Proposed Development “in combination with other plans and proposals would be likely to result in adverse effects on the integrity of the Ashdown Forest Special Area of Conservation (AFSAC)”. b. That there is “no clearly established essential agricultural need has been demonstrated as required by Saved Policy DC2 and paragraph 55 of the NPPF” and that the “scale and nature of the operation does not suggest strong functional requirements to be on the site, nor a sustainable financial case for the business”.

This proof of evidence addresses the first of WDC’s reasons.

1.6 The Ashdown Forest has been designated as a Special Area of Conservation primarily in order to protect its Northern Atlantic wet heaths and European dry heaths. This heathland is vulnerable to gaseous ammonia and oxides of nitrogen, both from atmospheric pollution and vehicle exhaust emissions. The

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most significant sources of these pollutants are emissions from fossil fuel

combustion and ammonia (NH3) emissions from agriculture.

1.7 Air Quality Consultants (AQC) for WDC have found that the levels of NH3 and oxides of nitrogen (NOx) considered to be safe for healthland vegetation are being exceeded at the upper bounds of the critical levels at some roadsides within the AFSAC and adversely affecting 14 areas within 250m of the roads, representing 0.63 ha of the 1,630 ha of AFSAC. These pollutants they report are also being exceeded at the lower bounds of the critical levels at points across the heathland within the SAC.

1.8 WDC have taken the position that no new development should be allowed in any part of Wealden District or near the Ashdown Forest if the development generates additional vehicle trips or parts thereof. The council’s position is that applicants cannot guarantee that none of the additional trips will be through the AFSAC, and that any additional trip or part thereof will have an adverse impact on the AFSAC.

1.9 The author knows of no other authority which agrees with WDC’s position. This includes Council (RDC) and Tunbridge Wells Borough Council (TWBC). TWBC’s air quality consultants AECOM concluded that the TWBC Local Plan would have negligible or no adverse effect on the AFSAC even in combination with other plans and projects, despite the TWBC Plan increasing trips through the AFSAC by approximately 183,000 trips per year.

1.10 TWBC position is at odds with WDC’s position because AECOM have adopted scenarios which allow for improvements in vehicle technology, whereas WDC have adopted a scenario without said improvements.

1.11 RDC are at odds with WDC’s position because RDC maintain the AFSAC is too far from RDC’s boundary and from its strategic growth area of Bexhill for developments within its district to have a significant effect on the AFSAC; they do not agree with WDC that “many small impacts will add up to a significant impact”.

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1.12 Natural ’s position is that the focus should be on tackling background emissions from fossil fuel combustion and agriculture, and the physical management of the AFSAC, and does not agree that road contributions are a statistically significant contributor to air quality in the AFSAC.

1.13 Traffic flow measurements on roads across the AFSAC total c. 42 million vehicles each year.

1.14 If allowed the Proposed Development could said to be responsible for 0.69 additional light goods vehicles (LGV) trips and 20 car trips per year through the AFSAC. However:

a. the Proposed Development would result in a net reduction on traffic through the heathland by displacing existing and planned car, LGV and HGV trips through the AFSAC at a rate of over 696.23 trips per year. Upwards of 17 of the existing annual trips displaced by the Proposed Development are trips currently made by diesel LGVs which produce ten times the NOx emissions as petrol cars.

b. of the projected 0.69 LGV trips per year, 0.23 trips/year are associated with delivery vehicles making multiple deliveries (e.g. Hermes, DHL, etc.) which would in any event be on the road network.

c. the projected 20 car trips per year are associated with non-local visitors to the Appeal Site. If the prospective smallholders are already living in the Wealden then this figure would be reduced as their family members would already be travelling to the Wealden and the trips would not be additional.

d. the Proposed Development would displace conventional agricultural production with organic fruit and vegetables thereby reducing atmospheric

emissions of NH3 from agriculture, in line with Natural England’s advice.

e. small changes in traffic flow through the AFSAC such as those resulting from the change of use proposed with this application – both positive and negative - lie within the normal or ‘standard’ variation and are not statistically significant. According to RDC, “when converted into NOx

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concentrations, ammonia concentrations or nitrogen deposition rates, such small changes in AADT would only affect those decimal places that are never reported in air quality modelling to avoid false precision”.

1.15 Looking to the wider context, residents of Low Impact Developments (LID), such as being proposed within this application, have less than half the average national ecological footprint. This is true of ELC’s existing developments where the residents’ ecological footprints average 46% of the national average (and where mileage averages 33% of the national average). The Proposed Development would create 6 FTE jobs delivering multiple environmental benefits in an MSOA3 where 89% of the working population commute out for employment.

Structure of this Proof of Evidence 1.16 The following section summarises the threat to the Ashdown Forest SAC from gaseous pollutants. Section 3 provides the reader with a snapshot of current traffic flow levels across the AFSAC. Section 4 looks at the quantity and origin / destination of trips expected to be generated by the Proposed Development. The ELC’s existing cluster of ecological smallholdings, Greenham Reach, is used as a basis for the projection and the first part of Section 4 looks at the transport information collected at Greenham Reach. The second part of Section 4 looks at the Appeal Site’s location including its position and transport links. The final part considers the expected frequency of trips drawing on both the data from Greenham Reach and the specific location of the Appeal Site. Section 5 looks at the trips which will be removed or displaced as a result of the Proposed Development and the trips likely to be generated if the Proposed Development is not allowed. Section 6 provides a summary of the combined impacts.

Relationship with Other Evidence 1.17 This proof of evidence does not address planning policy which is set out within the proof of evidence provided by Brett Spillr BA (Hons) BTP MRTPI MCIWM of Chapman Lily Planning.

3 Middle Layer Super Output Area

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2 THE THREAT TO THE ASHDOWN FOREST SAC

2.1 The Ashdown Forest is designated as a Special Area of Conservation for its Annex I4 habitats, the Northern Atlantic wet heaths with European dry heaths. It is one of the largest single continuous blocks of heath, semi-natural woodland and valley bog in southeast England and supports important assemblages of insects and birds. It is also a Special Protection Area on account of the presence of specific birds, the Dartford Warbler, the Nightjar and Woodlark, and for the presence of Annex II species, specifically Great Crested Newts. It is a Natura 2000 site and known as a European site.

2.2 The Forest covers an area of 2,716 hectares and is managed by Natural England. The heathland (hereafter referred to as AFSAC) covers 60% of the Forest, or c.1,630 hectares5.

2.3 Heathland vegetation is vulnerable to gaseous ammonia (NH3) and oxides of nitrogen (NOx), both from atmospheric pollution and vehicle exhaust emissions.

2.1 NOx can be toxic to the heathland vegetation in high levels. NOx is however principally a threat to the heathland when deposited, effectively fertilising the soil and in turn encouraging more competitive plant species that can force out the less competitive species that characterise the heathland. NOx can also acidify the soil and water which can adversely affect heathland species directly, but more significantly by releasing toxic metals.

2.4 NH3 can be both toxic to plants in low levels and can fertilise the soil as above, leading to soil conditions which encourage plant species which can outcompete heathland species.

4 Annex I habitat and Annex 2 species refers to 189 habitats and 788 species identified in the EC Habitats Directive as most in need of conservation. 5 Natura 2000 – Standard Data Form (2015) Natural England. Available at: http://jncc.defra.gov.uk/protectedsites/sacselection/sac.asp?EUCode=UK0030080. Last accessed: 28/05/2018.

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Figure 1: Map of Ashdown Forest showing SAC and SPA

Source: Guidance Note on Reducing Nitrogen Deposition at the AFSAC and SPA (2013), Mott Macdonald commissioned by WDC

2.2 Air Quality Consultants (AQC) on behalf of WDC investigated the air quality

within the AFSAC6. It found that the levels of NH3 and NOx considered to be safe for healthland vegetation are being exceeded at the upper bounds of the critical levels at some roadsides within the AFSAC. These pollutants are also being exceeded at the lower bounds of the critical levels at points across the heathland within the SAC.

2.5 The most significant source of NOx is the combustion of fossil fuels from electricity generators7. However, vehicle exhausts are also a significant source and significantly for this discussion, are driving the upper exceedances at the roadsides within the AFSAC8. NOx from vehicle exhausts is said to affect vegetation 200m either side of the road9. Beyond 200m emissions from vehicle exhausts are considered to drop to a low level such that they become effectively insignificant10.

2.6 In the UK, agriculture was responsible for 81% of the 280,020 tonnes11 of NH3 emissions (2015) with 81% of these emissions from livestock, principally dairy

cattle, and the remainder from fertiliser production and use12. NH3 from vehicle exhausts is considered to be significant up to 20 metres from the roadside after which they’re considered to drop to ‘background’ levels13. Again, it is the

6 Ashdown Forest SAC Air Quality Monitoring and Modelling (2017), Air Quality Consultants on behalf of WDC. Available from: http://www.wealden.gov.uk/Wealden/Residents/Planning_and_Building_Control/Planning_Policy/Core Strategy/CoreStrategyLibrary/Planning_Evidence_Base_Habitat_Regulations_Assessment.aspx. Last accessed: 22/05/2018 7 Guidance Note on Reducing Nitrogen Deposition at the AFSAC and SPA (2013), Mott Macdonald commissioned by WDC 8 Various sources including: Ashdown Forest SAC Air Quality Monitoring and Modelling (2017), Air Quality Consultants on behalf of WDC; and Tunbridge Wells Borough: Ashdown Forest Air Quality Impact Assessment 2018 (2018), AECOM for TWBC. 9 Appendix A: Ashdown Forest Air Quality impact Assessment 2018, March 2018, AECOM 10 Tunbridge Wells Borough: Ashdown Forest Air Quality Impact Assessment 2018 (2018), AECOM for TWBC. 11 Trends in UK sulphur dioxide, nitrogen oxides, non-methane volatile organic compounds, ammonia and particulate matter (PM10, PM2.5) emissions (2018), Environment Statistics Service. Link: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/681315/trends_in_air_e missions_2016.csv last accessed: 14/05/2018 12 Inventory of Ammonia Emissions from UK Agriculture (2016), Misslebrook et al. on contract from DEFRA. Link: Https://Uk-Air.Defra.Gov.Uk/Library/Reports?Report_Id=928. Last Accessed: 14/05/2018 13 Tunbridge Wells Borough: Ashdown Forest Air Quality Impact Assessment 2018 (2018), AECOM for TWBC.

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NH3 from vehicle exhausts which is considered to be driving the upper exceedances of the critical levels at the roadside within the AFSAC14.

2.7 As vehicle emissions decrease away from the roadside their adverse impact is limited, according to Natural England, to 14 areas within 250m of the roads, representing 0.63 ha of the 1,630 ha of AFSAC15. Across the remainder of the AFSAC, the significant contributors to nitrogen deposition are as shown in Figure 2: imported emissions (electricity generation); livestock production;

road transport; international shipping; and, NH3 from non-agricultural sources.

Figure 2: Relative Contributions of Nitrogen Deposition at AFSAC away from Roadsides

Source: Guidance Note on Reducing Nitrogen Deposition at the AFSAC and SPA (2013), Mott Macdonald commissioned by WDC

14 ibid 15 Natural England Discretionary Advice to Wealden Council, 16 February 2018, available at: http://www.wealden.gov.uk/nmsruntime/saveasdialog.aspx?lID=23850&sID=3484. Last accessed: 15/05/2018.

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2.8 There is no disagreement between the affected local planning authorities that traffic flow through the AFSAC will increase, nor that nitrogen deposition is higher at the road sides than within AFSAC as a whole. There is major disagreement both as to the implications that increases in traffic will have on air pollution and as to the impact that increases in traffic will have on the heathland.

2.9 WDC’s position is that the precautionary principle enshrined within the Habitat Regulations requires planning applications to be considered on the extreme

worst-case scenario which is in their view that NH3 and NOx concentrations will worsen at the roadsides within the AFSAC. WDC’s position is that no development should be allowed if it generates even one additional average daily traffic (AADT) or part thereof through the AFSAC. Other local authorities disagree that an increase in traffic will result in a critical increase in air pollution. For example, TWBC’s air quality consultants AECOM found that the TWBC Local Plan would have negligible or no adverse effect on the AFSAC even in combination with other plans and projects, despite the TWBC Plan increasing trips through the AFSAC by approximately 183,000 trips per year16. They argue that modelling should allow for improvements in vehicle technologies which they claim would see a reduction in pollutants from vehicle exhausts and result in no significant threat to the AFSAC from a projected increase in traffic.

2.10 RDC are also at odds with WDC’s position. RDC maintain the AFSAC is too far from RDC’s boundary and from its strategic growth area of Bexhill for developments within its district to have a significant effect on the AFSAC. RDC disagree with WDC that “many small impacts will add up to a significant impact” and write that the levels of change in traffic flow associated with development in their district are so small that they would not even be captured in air quality models17.

16 Tunbridge Wells Borough: Ashdown Forest Air Quality Impact Assessment 2018 (2018), AECOM for TWBC. Available at: https://democracy.tunbridgewells.gov.uk/meetings/ieDecisionDetails.aspx?ID=1316. Last accessed: 28/05/2018 17 Habitats Regulations Assessments: Interim Approach to Considering Planning Applications and

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2.11 There is also no consensus as to the ecological impact of vehicle emissions on the heathland. Natural England has seen WDC’s draft ecological studies18 and write that:

“the work does show that current pollution may be affecting habitat at Ashdown Forest but it is difficult to then relate this to road traffic and proximity of habitat to the road. In light of this and results of national modelling where APIS Source Attribution indicates that the primary contributor to total nitrogen and local nitrogen respectively are European import and livestock, a strategic approach to tackling background pollution is recommended (such as a SNAP). Generally through the report, it is noted that background air quality is a pressure on Ashdown Forest but much of the specific ecological monitoring and analysis is generally unable to attribute road contributions to be a statistically significant contributor to this” 19.

2.12 Documents prepared by national government, WDC and Natural England are in agreement that the following measures help to reduce atmospheric NOx

and NH320: This is noteworthy in light of the sustainability measures that form part of the Proposed Development:

a. Green travel: car-pooling, public transport, cycling and walking; b. Adoption of low emission vehicles; c. The reduction in fossil fuel combustion for electricity generation; d. Renewables and energy efficiency; and e. Reducing ammonia emissions from livestock and fertiliser use.

Emerging Plans (2018), Rother District Council 18 WDC produced a draft report in December 2017, “Air Quality and Ecological Monitoring and Modelling at Ashdown Forest: Considering the Current and Future Impacts on the SAC caused by Air Quality and Nitrogen Deposition, Report Ref 10678 Draft. This report was not available to the public / ELC at the time of writing. 19 Natural England Discretionary Advice to Wealden Council, 16 February 2018, available at: http://www.wealden.gov.uk/nmsruntime/saveasdialog.aspx?lID=23850&sID=3484. Last accessed: 15/05/2018. This document was only made available to the public as a result of a Freedom of information application. 20 UK Plan for Tackling Roadside Nitrogen Dioxide (2017), DEFRA/DoT; Guidance Note on Reducing Nitrogen Deposition at the Ashdown Forest Special Area of Conservation and Special Protection Area (2013), Mott Macdonald commissioned by WDC; and Atmospheric Nitrogen Theme Plan Developing a Strategic Approach for England’s Natura 2000 Sites (2015) Natural England.

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3 OVERVIEW OF EXISTING TRAFFIC THROUGH THE AFSAC

3.1 WDC’s air quality report (October 2017) provides the following figures for traffic flow through the AFSAC. The sources, as described in detail in their report, are: eight automatic traffic counters commissioned for the study; five East County Council traffic counters; data from ESCC’s Flowpoint Model; and nominal traffic flow (1,000 AADT) assigned for 37 minor roads. Together they provide the following data on vehicle trips through the AFSAC.

Table 1: Measured Traffic Flows at Points Across the AFSAC from WDC21

Identifier AADT Annualised New Road west of carpark 5,648 2,061,520 B2188 south of Lye Green 2,104 767,960 Road near Ellison‟s Pond 3,221 1,175,665 B2026 near Four Counties carpark 3,957 1,444,305 B2026 near Wrens Warren carpark 1,444 527,060 A22 bet Broadstone Warren & 10,228 3,733,220 Colemans Hatch Road bet Lintons & 1,839 767,960 Townsends carparks B2026 near Putland‟s Farm 5,078 1,853,470 A26 at Poundgate 16,398 5,985,270 A275 at 4,602 1,679,730 B2026 near Pylons carpark 5,526 2,016,990 A22 at between A275 & the llama park 12,042 4,395,330 B2110 Road, between Ladies Mile 2,880 1,051,200 and B2188 Kidd’s Hill 1,520 554,800 37 minor roads (at 1,000 AADT each) 37,000 13,505,000

Total 41,519,480

21 Ashdown Forest SAC Air Quality Monitoring and Modelling (2017), Air Quality Consultants on behalf of WDC. Available from: http://www.wealden.gov.uk/Wealden/Residents/Planning_and_Building_Control/Planning_Policy/Core Strategy/CoreStrategyLibrary/Planning_Evidence_Base_Habitat_Regulations_Assessment.aspx. Last accessed: 22/05/2018

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Figure 3: Map Showing Locations of Traffic Counters22

22 The exact locations of the ATCs were removed from WDC’s Ashdown Forest SAC Air Quality Monitoring and Modelling (2017) report due to concerns over vandalism. Therefore, approximate locations have been used in Figure 3.

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4 PROJECTED TRIP GENERATION AND TRAFFIC FLOW FROM THE PROPOSED DEVELOPMENT

4.1 With respect to calculating the generation of vehicle trips, the form of development proposed within this planning application is atypical for three main reasons.

a. It is a condition of the ELC’s agricultural business tenancies that at least one full-time equivalent worker from each of the proposed three smallholdings must work (and live) on their holding and on their farm business. It is also a condition of the proposed S106 Agreement23, planning conditions24 and the Management Plan25 and unusually, this obligation is monitored (by ELC) as part of annual reporting26. This is the same approach used at Greenham Reach, a site of three smallholdings for new entrants to ecological agriculture which the ELC established in Mid Devon in 2013. At Greenham Reach just one adult between the three households of six adults leaves their holding for employment27; all other adults work on their holding.

b. Any prospective residents of the three agricultural workers’ dwellings will be carefully selected by the ELC and will have to abide by said Management Plan which requires them to ensure that the site as a whole does not generate more than a total of 9,125 single trips per year (25 AADT). This has to include all personal and business trips and all those of staff, business and personal visitors, volunteers, deliveries and post, waste and recycling, school visits, etc. This voluntary commitment to limit vehicle use has already operated successfully at Greenham Reach.

23 Appendix 3 to the Planning Statement 24 Appendix 5 to the Planning Statement 25 Appendix 4 to the Planning Statement 26 An example of the ELC’s monitoring reports is Appendix 2 to the Planning Statement 27 Of note is that the adult who works off site at Greenham Reach commutes to work by train, not car. These trips are reflected in the Greenham Reach trip numbers under the item ‘combined, local trips’.

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c. The Proposed Development is also a Low Impact Development28 (LID) with a strong commitment to sustainability. Research on LID evidences that residents of LIDs use a significantly lower amount of the planet’s resources than the UK average29 including owning fewer vehicles, making less trips, particularly compared with other drivers in rural settings, and travelling significantly fewer miles. Data from Greenham Reach reflects this as shown in Tables 2 and 3. Greenham Reach residents travelled in miles a third of the national average and have less than half the ecological footprint.

Table 2: Average Annual Mileage of LID Projects against National Averages 2016 (per individual)

Annual Mileage Percentage National Average National Average30 3,823 Greenham Reach31 1,256 33% Phil Broda32 871 23% Middle Crys (2015)33 1,473 Nant y Cwm (2014)34 975 Hebron Farm35 2,295 60%

28 LID is described as an “approach to housing, livelihoods and everyday living [employing] approaches that dramatically reduce humans’ impact upon the environment” Maxey, L and Pickerill, J (2009) Geographies of Sustainability, Geography Compass 29 The average national resource use is captured in the average UK ecological footprint. This is calculated by a number of organisations, see for example, the Global Footprint Network. 30 Total private car miles driven in Great Britain divided by population. Road Traffic Estimates: Great Britain 2016 (2017) Department for Transport. Available from: https://www.gov.uk/government/statistics/road-traffic-estimates-in-great-britain-2016 31 Agricultural appraisals carried out for Greenham Reach applications for permanent permission (2018), Geo & Co Ltd. 32 Data drawn from published management plans available at: http://www.oneplanetcouncil.org.uk/approved-applications/ 33 ibid 34 ibid 35 ibid

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Table 3: Ecological Footprints of LID Projects against National Averages (per individual)

Ecological Average Percentage Footprint Ecological National Low Impact Development Year (gha) Footprint UK Average (gha)36 Greenham Reach37 2017 2.33 4.8 46% Phil Broda38 2016 1.40 4.8 29% Middle Crys39 2015 1.91 4.8 40% Lammas40 2014 1.55 4.8 32% Nant y Cwm41 2013 1.54 4.9 31% Pentiddy Woods42 2008 2.32 5.3 44% Trevalon43 2007 2.53 6.2 41% Landmatters44 2006 2.47 6.2 40%

4.2 There are no examples of the Proposed Development contained in the transport database TRICS which is used for validating assumptions about transport impacts of new development. A bespoke methodology has therefore been used to ascertain trip generation and traffic flow.

4.3 This section looks at the quantity and origin / destination of trips expected to be generated by the Proposed Development based on the needs of the proposed businesses and those of its prospective residents. Greenham Reach is used as a basis for the projection and the first part of this section looks at the transport information collected at Greenham Reach. The second part looks at the Appeal Site’s location including its position and transport links in relation to markets for the proposed farm produce and services for the prospective residents. The final part considers the expected frequency of trips to markets and services, and trips made by others to the Appeal Site drawing

36 From http://data.footprintnetwork.org/#/. Most recent ecological footprint from 2014. 37 2017 Review of the Ecological Footprints of the Households at Greenham Reach (2017), Geo & Co Ltd. 38 Data drawn from published management plans available at: http://www.oneplanetcouncil.org.uk/approved-applications/ 39 Abid. 40 Annual Monitoring Report For Tir y Gafel Ecovillage 1st January 2014 – 31st December 2014 (2015) Tir y Gafel. Available from: 41 Data drawn from published management plans available at: http://www.oneplanetcouncil.org.uk/approved-applications/ 42 Ecological Footprint Report prepared for Pentiddy Woods (2009) 4th World Ecological Design. 43 The Ecological Footprint Report Prepared for Mark Simon (2008) 4th World Ecological Design. 44 The Ecological Footprint of Landmatters Coop (2007) 4th World Ecological Design.

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on both the data from Greenham Reach and the specific location of the Appeal Site.

PART 1: TRAVEL INFORMATION FROM GREENHAM REACH

4.4 To calculate trips expected to be generated by the Proposed Development, data from Greenham Reach has been analysed. Greenham Reach is very similar to the Proposed Development although Greenham Reach is more isolated than the Appeal Site. A full description of Greenham Reach, its location, the make-up of the residents and the farm businesses is set out in Appendix 4.

4.5 Data from Greenham Reach has been gathered from three sources:

a. Mileage taken from the residents’ family/business vehicles and reported to Geo & Co Ltd, agricultural assessors of the three farm businesses at Greenham Reach (January 1 – December 31 2017) 45; b. Data from the automatic traffic counter installed by Edgarsson Ltd at the entrance to Greenham Reach (February 1 2016 – 31 January 2017)46; and c. A survey conducted by the ELC of the residents in March 201747.

4.6 The information shows that:

a. The site generated an average of 12.78 daily trips (including all residents, volunteers, staff, deliveries and visitors).

b. Based on vehicle mileage divided by trips made by residents, the average trip distance is 4.6km. This compares with the national average of 14.2km48.

45 Figures provided to the agricultural assessor for planning applications 18/00563-5/FULL (Mid Devon District Council) and set out in Appendix 5. 46 Appendix 1 provides information on the traffic counter and the daily traffic count figures in more detail. 47 The survey results are reproduced in Appendix 3. 48 Analysis from the National Travel Survey (2018), DoT.

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c. According to the survey, 99.6% of trips made by Greenham Reach residents were within the local49 area.

4.7 The residents estimated that their trips (as opposed to those of visitors, deliveries, etc.), to be approximately 10 AADT of 12.78 AADT, consisting of the following:

a. Local50 business and personal trips including personal and business shopping, accessing the train station, visiting friends, and accessing local amenities51 (42%); b. Children’s primary and secondary schools (42%); c. Trips to deliver and sell produce: box scheme recipients, cafes and restaurants, and farmers’ markets (15%); and d. Non-local personal trips (0.4%).

4.8 The Greenham Reach residents estimated that the remaining trips generated by non-residents and approximately 2.8 AADT of 12.78 AADT, consisted of the following:

a. Local residents coming to work or volunteer on the farm business (49%); b. Local visitors, including school visits (20%); c. Non-local visitors, including those attending workshops, site monitoring, services, and open days (18%); d. Deliveries from outside of the area, such as parcel deliveries (9%); and e. Deliveries from local sources such as manure from neighbour’s farm, (4%).

4.9 The data indicates that around 95% or 12.12 AADT of the 12.78 AADT were local52 journeys, either made by the residents or their visitors, employees,

49 Within the Greenham Reach context, local trips refers to trips not further than the nearest primary centre, Tiverton, which is 13 miles from Greenham Reach. Of note is that the average trip distance for Greenham Reach residents is 3.4 miles, 50 Within the Greenham Reach context, local trips refers to trips not further than the nearest primary centre, Tiverton, which is 20km from Greenham Reach. However, average trip distance for Greenham Reach residents is 4.6km, 51 Residents aren’t able to separate their business and personal trips to local shops and services as these are by default combined (i.e., a trip to buy groceries would be combined to a trip to the post office to send out a plant nursery order). 52 Within the Greenham Reach context, local trips refers to trips not further than the nearest primary centre, Tiverton, which is 20km from Greenham Reach. However, average trip distance for Greenham Reach residents is 4.6km,

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deliveries, etc. Approximately 5% or 0.66 AADT were reported by the residents as stemming from outside of the locality.

PART 2: THE APPEAL SITE: LOCATION, TRANSPORT, MARKETS AND SERVICES

4.10 The Appeal Site is 25 km to the south by road from the Ashdown Forest at its nearest point, and 27 km by road from the closest part of the Special Protection Area (Figure 4).

4.11 The Appeal Site is well connected to a trunk road network away from the AFSAC, specifically, the A27 is 3.4 km to the south by road at its closet point from the Appeal Site and links the Site to multiple primary, secondary, district and service centres, including Polegate, Eastbourne, , Bay, Hastings, Lewes and on to the A23 and and Gatwick. None of these routes are through AFSAC. Distances to these destinations are shown in Tables 4 and 5, and routes in Figure 5.

Table 4: Distance Between Appeal Site and Select Towns and Villages. Settlements within or accessed through the AFSAC are highlighted. Population (2011 Distance by Distance by Settlement Centre type53 census) road (km) road (m) Arlington Unclassified 627 0.8 0.5 Berwick (station) Neighbourhood n/a 3.6 2.2 Upper Dicker Neighbourhood 551 4.9 3.0 Hailsham District 19,977 6.7 4.2 Polegate Service 9,034 8.2 5.1 Seaford 22,584 13.3 8.3 Eastbourne Primary 109,185 14.1 8.8 Pevensey Bay Local service 2,864 15.4 9.6 Lewes Secondary 17,297 16.8 10.4 District 15,213 19.7 12.2 Newhaven* 13,222 20.0 12.4 Brighton & * 229,700 28.8 17.9 Crowborough District 20,607 33.3 20.7 Forest Row Service 5,278 37.0 23.0 East Grinstead Secondary 23,942 45.0 28.0 * settlements not referenced in WDC’s Settlement Hierarchy.

53 According to WDC Settlement Hierachy, Adopted Core Strategy 2013, WDC

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Figure 4: Map Showing Proximity of Appeal Site to the Nearest Point within the AFSAC

Nursery Lane represents the nearest point to the Appeal Site within the AFSAC. The point BN26 6RU is the Appeal Site.

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Figure 5: Maps Showing Road Links from Appeal Site to Nearest Primary, Secondary, District and Service Settlements: Eastbourne, Lewes, Hailsham and Polegate

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4.1 London and the M25 can be accessed using the A22 through the AFSAC or using the A27/M23. The latter route has a quicker journey time including to the east of London and on to Essex. The journey times to five points in London from the Appeal Site via the A27 and A22 are set out in Table 5.

Table 5: Journey Times from the Appeal Site to Points in London 6pm, weekday

Destination A27 A22 Notting Hill 1 h 54 min 2 h 13 min Stratford 1 h 48 min 1 h 54 min Clapham Common 1 h 40 min 1 h 50 min Archway 2 h 12 min 2 h 20 min

4.2 The Appeal Site is also served by a number of key A roads. This includes the A259 which links the Appeal Site to the coastal communities of Seaford and Newhaven. Again, these routes are not through AFSAC.

4.3 The Appeal Site is well served by rail. Berwick Station is 2.4 km as the crow flies, and 3.6 km by road from the Appeal Site, and has a regular service to Lewes, Brighton and further beyond to coastal towns, and to Gatwick and London. Weekdays there are 7 direct and 17 indirect services to London and 26 direct services to Eastbourne. The mainstay of the road to Berwick Station also forms part of a cycle route.

4.4 The Appeal Site is served by a weekly bus to Berwick and Hailsham (no. 42) and six further bus services from Berwick Station with daily connections including to Polegate, Pevensey Bay, Brighton, Glynde, , Eastbourne, Eastbourne General Hospital, Hailsham, and Seaford.

4.5 The Appeal Site also benefits from a significant network of public paths including the footpath #41A Wilmington which crosses the site.

4.6 As illustrated in Table 4 above, there are dozens of settlements which are closer to the Appeal Site than settlements within or accessed through the AFSAC. These include the city of Brighton, Eastbourne (primary centre), Lewes (secondary centre), and Hailsham and Uckfield (district centres).

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4.7 Significantly, these closer settlements offer more services and markets than available in settlements in or through the AFSAC. In the settlements listed in Table 4 and outside of the AFSAC there are:

a. Nineteen farmers markets54; b. Over 400 pubs, cafes and restaurants; c. Dozens of primary and secondary schools as well as higher education facilities Plumpton (agricultural) College, Sussex University and Brighton University. Within 14 km of the Appeal Site there are 17 primary and 11 secondary schools. The closest primary and secondary schools in Hailsham, at 6.7 km. d. A large range of shops and leisure facilities including cinemas, swimming pools, and theatres. The nearest supermarket (Lidl), petrol station, library and GP are all within 7 km of the Appeal Site; and e. Two major hospitals. The nearest A&E is in Eastbourne, again away from the AFSAC. Emergency vehicles are diverted to the Royal Sussex or the Conquest hospitals when Eastbourne General is full, again both away from the AFSAC55

4.8 Ashdown Forest as a popular visitor destination and it may be argued that the prospective residents would want to travel to the Forest for walks. The Appeal Site is however closer to other special destinations including the ; Friston Forest; Birling Gap and the coast.

4.9 The Appeal Site is 27km south of the AFSAC. It is situated in a well populated area with good transport links, access to markets for farm produce, and access to shops, services and amenities, all well away from the AFSAC.

PART 3: PROJECTIONS

4.10 The Appeal Site is 27km from the AFSAC. It is close to many settlements including the large towns of Hailsham, Seaford, Lewes and Eastbourne, all away from the AFSAC. There is a large offering of schools, amenities,

54 See Appendix 1 to the business plans: Markets for Arlington Smallholdings Produce 55 Interview with St John Ambulance, 08/06/2018

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services, shops and markets closer to the Appeal Site than the AFSAC. There are no shops, services or markets within the AFSAC that cannot be accessed in locations closer to the Appeal Site which would also be the residents’ place of work.

4.11 Based on the trips generated at Greenham Reach where 95% of the trips were local, and an average trip was 4.6km, it can be said to be highly likely that the trips generated by the Proposed Development will almost entirely be within the locality or to the larger settlements which offer more markets, shops and services: Lewes, Eastbourne and Brighton.

4.12 Should the Proposed Development attract visits from the council, these would originate in Hailsham, and monitoring visits and visits from ELC staff would originate from Brighton. There is no need to travel through the AFSAC to access the Appeal Site from either of these points of origin.

4.13 There are a number of reasons to believe that volunteers and staff would not travel from the AFSAC to the Appeal Site: there is some distance between the AFSAC and the Appeal Site; and there are clusters of people working in and / or studying organic farming at Plumpton, Eastbourne, Brighton and Lewes and none of these points of origin would generate trips through the AFSAC. ELC has sustainability at the core of its work and would ensure that residents were educated on the issue of the AFSAC and recruit volunteers and staff accordingly. From the author’s experience, work in organic farming attracts volunteers and staff with a strong commitment to sustainability who themselves are already likely to be minimising their vehicle use and mileage. This is reflected in the lower than average ecological footprints and mileage of residents of low impact developments.

4.14 Non-local visitors travelling independently to the Appeal Site would be informed of the threat to the AFSAC from vehicle emissions. Visitors would be encouraged to use public transport, and/or make use of the minibuses and collections from public transport organised by the ELC and/or its residents whenever there is a workshop, Open Day or Work Day. However, trips made by visitors are outside of the ELC’s control. Based on the experience at

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Greenham Reach where approximately 100 trips a year are generated by non-local visitors, and considering that the A22 is one of five main routes to the Appeal Site, it can be considered that c. 20 trips / year through the AFSAC may be generated by non-local visitors. This analysis is somewhat speculative as such trips would not be directly caused by the development; I have included them on a precautionary basis. This figure would be reduced if the prospective smallholders were already living in the Wealden; some of these journeys represent visits by family members who would already be travelling to the Wealden.

4.15 The remaining trips are those from deliveries and services. The ELC and its residents have no control over these trips and accordingly, 0.00189 AADT or 0.69 annual trips through the AFSAC can be attributed to deliveries and services. The calculations were provided with the appeal documentation and have been provided again in Appendix 2.

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Table 6: Summary of Projected Total Trip Numbers and Trips through the AFSAC Based on Greenham Reach (per Year)

Trip Reason Comments No. Total trips through (year) AFSAC Personal There are dozens of schools 1,560 closer to the Appeal Site than schools within the AFSAC and School ‘run’ no reason for residents to travel to the AFSAC for their children’s schooling. Longer journeys, for example to 14 the West Country or Manchester Distance journeys (e.g. to do not pass through the AFSAC. see family) If travelling to London the faster routes are not through the AFSAC (see Table 4). Business There is established demand for 532 more certified organic produce Produce deliveries & both locally and from established markets food markets in Lewes and large retailers in Brighton. Combined Local trips other than school Services and shops, post office, 1,548 or produce delivery GP, library, etc. can all be accessed in locations both nearer and in larger settlements

Residents’ Trips than within the AFSAC56. Local personal visitors 106 All non-local visitors will be made aware of the need to avoid the AFSAC but as the ELC does not have control of these trips, nor know the origin of visitors; the Proposed Development could

generate trips through the Non-local visitors AFSAC from non-local visitors. 16 3.2

Trips

Business visitors (local) Local staff & volunteers 496 These come from within the local Workshops & groups area. 80

Visitors’ Open Days 48

56 This figure includes weekday trips made by one of the smallholders’ partners to Tiverton train station to go to work off-site.

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Annual School Visits 20 Deliveries 36 Business visitors (non-local) Work Days Those attending ELC events 12 2.4 such as Work Days are asked to travel by public transport and collected from the local station. From our experience at Greenham Reach, a small Workshops & groups percentage will travel by car. 72 14.4 Point of origin is Brighton, route Monitoring is not through the AFSAC. 16 Point of origin is Hailsham, route Council is not through the AFSAC. 8 Services A proportion of these would 8 0.46 travel through the AFSAC, Deliveries calculations in Appendix 2. 96 0.23

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5 VEHICLE TRIPS REMOVED

5.1 The Proposed Development, if allowed, would remove at least 698 annual trips or 1.91 AADT through the AFSAC. By producing organic produce in an area which is currently a net importer of organic produce, the Proposed Development would reduce trips through the AFSAC currently generated by the transportation of organic produce into . It would result in the conversion of land from conventional agriculture supplying national markets to organic agriculture supplying local markets, reducing trips out of East Sussex and reducing ammonia emissions. The Proposed Development would be providing housing affordable to the new entrants to farming in an area which is unable to demonstrate a 5-year housing land supply and has a housing shortage. Arguably, the Proposed Development would also remove the trips which would be generated by three new conventional housing units which would be needed to meet housing needs. Finally, it would provide employment for 6 FTE in an MSOA where 89% of the working population commute out for work57.

Reducing Organic Produce Imports 5.2 As a net importer of organic produce, the demand for certified organic fruit and vegetables from East Sussex exceeds supply from within its borders. This has been supported by organic growers supplying the farmers markets identified in Appendix 1 to the business plans58, and the two organic retailers in Brighton: HiSBe and Infinity Foods. For this Proof of Evidence the supply routes of just one of these buyers was looked at, Barcombe Nurseries in Barcombe, Lewes.

5.3 Barcombe Nurseries farms on their 10-acre site and have insufficient space to grow all the produce they need. They currently buy in carrots and onions all year around from a Herefordshire wholesaler to supplement their vegetable boxes. They also buy in beetroots for half the year and potatoes a third of the year, with ad hoc additions as needed. They would like to replace this produce

57 WU01EW - Location of Usual Residence and Place of Work (MSOA level) (2011) Office of National Statistics 58 Appendix C to the supplementary planning information submitted 17/11/2017

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with produce grown locally59 and the businesses proposed within the Proposed Development would meet their needs for bought in produce both in terms of quantity and price with the exception of potatoes. Barcombe Nurseries have expressed their preference for local produce and stated that they would pay a higher price for local produce.

5.4 Barcombe Nurseries currently receive a weekly delivery of produce from Heredfordshire. According to S & S Distribution60, the delivery route is Herefordshire to Birmingham, to Tonbridge distribution hub and then down the A26 to Barcombe. This is directly through the AFSAC and passes the point within the AFSAC with both the highest flows of traffic and the highest concentrations of NOx.

5.5 According Barcombe Nurseries61, their vegetable delivery typically uses a sixth of the delivery vehicle, and a third of the vehicle for 1 in 3 of their weekly deliveries. By providing a local source of carrots, onions and beetroot the Proposed Development could potentially displace two thirds of these weekly journeys and remove 17.33 trips annually from the AFSAC. These are trips made by diesel LGVs which produce over ten times the NOx as petrol cars62. Calculations are in Appendix 6.

5.6 As stated above, this is just one of the potential buyers of just three crops proposed to be grown at the Appeal Site and further research is likely reveal a greater reduction in trips through the AFSAC as a result of the Proposed Development.

Converting from Conventional to Organic Farming 5.7 The previous occupant of the Appeal Site was the farmer Peter Appleton at Primrose Farm, Arlington. Mr Appleton rented the Appeal Site on an annual tenancy to grow maize conventionally to feed his dairy cows. This use has

59 The organisation Making Local Food Work writes that “there is no universal definition of local food, but it is generally considered to be food grown or produced, processed, traded and sold within a geographic radius of 30-50 miles”. The Appeal Site is however just 13 miles from Barcombe Nurseries. 60 Telephone interview, 07/06/2018 61 Telephone interview, 08/06/2018 62 UK Plan for Tackling Roadside Nitrogen Dioxide Concentrations: Detailed Plan (2017) DEFRA & DoT

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now ceased, but should the Proposed Development not be allowed, it is quite likely that maize for dairy (or other conventional farming) would be re- established as this is a common use and was the previous use for both the Appeal Site and the Greenham Reach site. The maize produced at the Appeal Site would have fed an additional c. 24 dairy cows producing c. 190,000 litres of milk a year. Mr Appleton sells his milk through Arla Foods63. Arla Foods’ processing plant is in Aylesbury64 and every day three milk tankers are sent from Aylesbury to Arlington, Upper Dicker and Lower Dicker to collect milk. According to Arla Foods65, their tankers use two routes into the area including through the AFSAC. Although this is just an example, it illustrates that by displacing conventional farming supplying national markets the Proposed Development decreases demand to transport produce further afield. If the Proposed Development is not allowed and the land used again for dairy feed, there would arguably be additional HGV trips through the AFSAC at a rate of c. 7 / year.

5.8 By displacing conventional for organic farming, and in particular, vegetables and fruit for dairy cow feed, there will be a decrease is ammonia emissions from manure and from the production and use of chemical fertiliser.

Reducing the Demand for New Conventional Housing 5.9 It is well known that WDC does not yet have a five-year housing supply and that and that affordability is an acute problem. AQC have stated in their report that when new housing is delivered, each new dwelling will generate 0.62 AADT through the AFSAC. For a development of 3 dwellings this would be 1.86 AADT. Arguably therefore, should the businesses proposed within this planning application be successful and a permanent consent be granted after 5 years, three new housing units would be provided, reducing the number of conventional houses that would need to be built to meet the district’s housing needs. It can be argued therefore that the Proposed Development removes

63 Information provided by Primrose Farm neighbour John McCutchan MBE. Available from: https://www.bluebellwalk.co.uk/history-arlington-bluebell-walk. Last accessed 07/06/2018. 64 https://www.arlafoods.co.uk/overview/arla-in-the-uk/aylesbury/ 65 Telephone interview with logistics staff on 18/05/2018

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another 1.86 AADT or 678.90 annual trips from the AFSAC. Again, calculations are in Appendix 6.

Reducing Commuting 5.10 Also, according to data from the Office for National Statistics66, the Middle Super Output Area within which the Appeal Site lies, E02004420: Wealden 018, there are 3,316 working adults of which only 11% work within the MSOA, the remainder (89%) commuting out, including to other parts of the Wealden and to London. By providing employment the Proposed Development could also be reducing the need for local residents to travel outside of the area for employment. Although unquantifiable, some of these journeys could be through or to the AFSAC considering that within the AFSAC there are two biodynamic farms, Tablehurst and Plawhatch, who employ staff from outside the SAC.

66 WU01EW - Location of Usual Residence and Place of Work (MSOA level) (2011) Office of National Statistics

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6 OVERALL IMPACT ON THE AFSAC OF THE PROPOSED DEVELOPMENT

6.1 It is impossible to predict without uncertainty the number of trips that the Proposed Development will generate and displace or remove, and how many of these would be through the AFSAC. However, as set out in the previous sections, we do know that:

a. The businesses proposed with this planning application will produce certified organic produce in an area which is currently importing certified produce from outside the county.

b. The businesses displaces an alternative agricultural activity. If this is feed for milk production supplying a national market and distribution system this could create trips through the AFSAC. By displacing dairy

cows, the Proposed Development also removes the associated NH3 emissions from livestock. By removing conventionally produced crops,

it also removes the associated NH3 emissions from fertiliser production and use. Natural England advocate for the reduction in both of these sources of pollutants as a way to reduce nitrogen deposition in the AFSAC67.

c. WDC need in any event to provide housing. A LID with on-site employment would provide housing with significantly lower trip generation and mileage than a typical housing development. Put another way, if all of the 11,456 houses in the WDC Local Plan generated the same number of trips through the AFSAC, rather than creating an additional 7,119 AADT, there would be 216 AADT.

d. The Proposed Development would create employment for 6 FTE68 in an MSOA where 89% of the working population currently commute out for work69.

67 Need to add reference here 68 The business plans provide for full-time employment for one adult from each of the three proposed smallholdings, and an additional paid employee on each smallholding (which could be a second adult from the smallholding households), totally 6FTE. 69 Need to add reference here

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e. Data from an almost identical but slightly more isolated cluster of three smallholdings, Greenham Reach, shows that 12.78 AADT were generated by three households (4.26 AADT per household) and that 95% of these trips, or 12.14 AADT, were local and only 0.64 AADT were not-local. Average trip mileage for Greenham Reach is 4.6km compared with the national average of 14.2km70.

f. In the last ten years the ELC has established itself as a not-for-profit community organisation with extremely high standards of responsibility with regard to environmental sustainability. It is the developer of this Proposed Development and would be responsible for managing the site in perpetuity, including monitoring trip generation.

6.2 Daily traffic flow is not a fixed number but fluctuates from day to day. Small changes in traffic flow through the AFSAC such as those resulting from the change of use proposed with this application – both positive and negative - lie within the normal or ‘standard’ variation and are not statistically significant. According to RDC, “when converted into NOx concentrations, ammonia concentrations or nitrogen deposition rates, such small changes in AADT would only affect those decimal places that are never reported in air quality modelling to avoid false precision”71.

6.3 One AADT is equivalent to a one thousandth of 1% (0.001%) increase in nitrogen deposition. The 0.0567 AADT projected to be generated by the Proposed Development represents an increase in roadside nitrogen deposition of 0.0000567%72. Even if it was felt that there was not enough evidence to conclude that trips would be removed as a result of the Proposed Development, this 0.000567% increase in nitrogen deposition is infinitesimal. Natural England Commissioned Report 210 makes it clear that this change in rate would not have an adverse impact on the AFSAC73. Natural England’s

70 Analysis from the National Travel Survey (2018), DoT. 71 Habitats Regulations Assessments: Interim Approach to Considering Planning Applications and Emerging Plans (2018), Rother District Council 72 Based on the benchmark 1,000 AADT increase over existing flows that is taken to be significant on the basis this would equate to an approximate 1% increase in the level of nitrogen deposition. 73 Caporn, S., et al. (2016). Assessing the Effects of Small Increments of Atmospheric Nitrogen Deposition (Above the Critical Load) on Semi-Natural Habitats of Conservation Importance. Natural

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advice to WDC is that even proposals that generate 1,000 AADT (529,000 times the projected amount generated by the Proposed Development) may not adversely affect the AFSAC protected habitats74.

England Commissioned Reports, Number 210. Available at: http://publications.naturalengland.org.uk/publication/5354697970941952. Last accessed: 10/06/2018. 74 Natural England Discretionary Advice to Wealden Council, 16 February 2018, available at: http://www.wealden.gov.uk/nmsruntime/saveasdialog.aspx?lID=23850&sID=3484. Last accessed: 15/05/2018.

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ACRONYMS and ABBREVIATIONS

AADT Average Annual Daily Traffic AFSAC Ashdown Forest Special Area of Conservation APIS Air Pollution Information Service DCLG Department for Communities and Local Government DFID Department for International Development DfT Department for Transport ELC Ecological Land Limited, trading as the Ecological Land Co- operative GHA Global Hectares per capita GHG Greenhouse Gases HRA Habitats Regulations Assessment LID Low Impact Development LPA Local Planning Authority MDDC Mid Devon District Council

NH3 Ammonia NOx Nitrogen Oxide NPPF National Planning Policy Framework PINS Planning Inspectorate SAC Special Area of Conservation TWBC Tunbridge Wells Borough Council WDC Wealden District Council

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APPENDIX 1: DETAILS OF THE TRAFFIC COUNTER AT GREENHAM REACH SMALLHOLDINGS

The traffic counter at Greenham Reach is buried across the (only) entrance to the site. The pressure from vehicles entering and leaving the site cause pulses to be sent to the counter unit which sends a daily count via SMS text message to a mobile device. The counter unit is powered by batteries which are kept recharged by the ELC. The counter was installed by Edgarsson Ltd. on 18/11/2013. The data capture ratio for the counter of the period 18/11/2013 – 23/01/2018 was 74%. Days in which data was not captured the annual average daily count was used as there have been no significant seasonal variations for traffic at Greenham Reach.

Table A sets out the daily average traffic count for Greenham Reach for the period 18/11/2013 – 17/11/2017. These figures are the average daily single vehicle count associated with the three households and their farm businesses. This includes the trips generated by volunteers, staff, school visits, open days, work days, courses, deliveries, site monitoring.

Table A: Average Daily Traffic Count, Greenham Reach

Date Range Average Daily Count 18/11/2013 – 17/11/2014 5.69 18/11/2014 – 17/11/2015 10.24 18/11/2015 – 17/11/2016 12.01 18/11/2016 – 17/11/2017 15.99

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APPENDIX 2: CALCULATIONS FOR TRIP GENERATION AND TRAFFIC GENERATION

We have no reason to assume Arlington will generate a greater or lesser number of visits from service providers or deliveries. Following our experience at Greenham Reach, we would therefore expect the Scheme to generate 0.28 daily traffic movements from these two sources. Deliveries. Deliveries to Greenham Reach, other than for one-off deliveries in the set-up of the site, are for on-line purchases. An average delivery round for items such as those purchased on-line has been determined by the Logistics Research Centre. Typically, a van-based delivery round consists of 120 drops on a 50-mile round. Taking the data from Greenham Reach of 96 single trips for deliveries per year, the Scheme would be responsible for generating c. 0.8 delivery trips per year. However, the principle distribution hub for deliveries for Arlington is Gatwick, with Department for Transport data showing the A23/A27 route a faster and more popular route for LGVs in and out of Gatwick to the A264 by a factor of 5:2. This reduces the projected delivery trips travelling through the AFSAC generated by the Scheme to 0.23 per year. Service Visits. Using this same data from Greenham Reach, we have projected the average number of service visits to be 8 per year. This figure needs to be adjusted to reflect that service professionals visit more than 1 site per day, and again adjusted to reflect that the site lies just 3km from the A27 which is at any rate, a more popular route. For the purpose of this calculation, we have assumed that a service provider visits 5 sites per day, and that the preferred route is the A27 over the roads through the Forest at a ratio of 5:2. This reduces the projected service trips associated with the Scheme to 0.46 per year. This provides a total figure of 0.23 + 0.46 = 0.69 LGV trips per year which would probably travel through the AFSAC as a result of the Proposed Development. Of note is that traffic already on the road network is disregarded in transport assessments.

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APPENDIX 3: SURVEY OF GREENHAM REACH RESIDENTS

The residents of Greenham Reach were surveyed by way of an email followed by informal interview in March 2017. A representative from each of the 3 households were asked to quantify their household’s journeys and to provide information on the nature of these journeys with respect to frequency, purpose and distance. The answers have been calibrated against:

• the traffic data provided by the vehicle counter installed at the entrance to the site to ensure the quantities provided by the residents tallied with the data provided by the counter; and • their vehicle mileage provided by their vehicles’ odometers.

Trip Reason Plot 1 Plot 2 Plot 3 Site Total Personal School ‘run’ 780 0 780 1,560 Distance journeys (e.g. to 14 see family) 2 0 12 Business Produce deliveries & 532 markets 52 192 288 Combined Local trips other than school 442 706 400 1,548

Residents’ Trips or produce delivery Local personal visitors 26 26 52 2 106 Non-local visitors 4 12 16 Business visitors (local) Local staff & volunteers 104 288 104 496 Workshops & groups 40 20 20 80 Open Days 48 48 Annual School Visits 20 20 Deliveries 16 16 4 36 Business visitors (non-local) Work Days 12 12 Workshops & groups 20 20 20 12 72 Monitoring 16 16 Council 8 8 Services 8 8 Deliveries 96 96

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APPENDIX 4: DESCRIPTION OF GREENHAM REACH RESIDENTS AND FARM BUSINESSES

The ELC’s first development is Greenham Reach, a cluster of three affordable smallholdings for new entrants to ecological agriculture, located in Devon. A 5-year temporary planning permission was granted in 2013, allowing the ELC to use the 22 acre greenfield site for three farm businesses including constructing a barn, track and three temporary residential agricultural workers’ dwellings, each tied to an agricultural holding of between 5.5 and 8.5 acres. The ELC was granted permission by PINS in April 2013 and the residents moved on between January 2014 and April 2015. Like the Appeal Site, Greenham Reach is located close to an A road, the A38 at 2.5km. However, the nearest primary settlement is Tiverton, at a distance of 20km, compared with the Appeal Site’s distance to Eastbourne, at 14km. The nearest village to Greenham Reach is Holcombe Rogus at 2.7km, compared with the Appeal Site which is 0.8km from Alrington village centre. Berwick train station is also closer at 3.6km, compared with Tiverton Parkway at 6.5km. The Appeal Site is served by far more frequent bus and rail sites than Greenham Reach. The farm businesses at Greenham Reach are mixed but largely horticultural businesses. Elder Farm is a business centred around herb production; Wild Geese Acres focuses on intensive salad production and recently expanded to include sheep, pigs and flowers; and Steepholding is a mixed enterprise including fruit, a veg box scheme and a micro dairy herd of Golden Guernsey goats. Two of the holdings are non-certified organic and third is certified organic. They do not use synthetic fertilisers and pesticides, making use of locally sourced manure, municipal compost and mineral salts. Other farm business supplies are small in quantity and largely sourced locally. Value-adding produce processing (e.g. salad bag packing and herb drying) happens on site. Produce is sold direct to local residents and businesses. Two of the households are families with 1 and 2 children respectively living on site with them and the third household is a couple.

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APPENDIX 5: MILEAGE REPORTED AT GREENHAM REACH AND MILEAGE CALCULATIONS

Part 1 The following annual mileage for the year up until 31 December 2017 was reported to agricultural assessor Bill Knight of Geo & Co Ltd and submitted as part of the agricultural assessments for planning applications 18/00563, 4, and 5/FULL (Mid Devon District Council): Elder Farm: 1,656 miles per person, 3 person household Wild Geese Acres: 1,553 miles per person, 2 person household Steepholding: 560 miles per person, 4 person household The average for Greenham Reach was calculated as 1,256.33 miles per person (per year) and the total mileage for the site 10,314. Part 2 The number of trips generated by Greenham Reach was taken from the document submitted with the planning application Effect of the Proposed Scheme on the Ashdown Forest SAC. The trip data in this document covered the period 1 February 2016 – 31 January 2017. This is not the most recent trip data but was at the time of writing the document (March 2017) and the author did not wish to introduce a new data set as this could create confusion. The number of trips generated by Greenham Reach in period 1 February 2016 – 31 January 2017 was 4,664 (individual trips) of which the residents estimated 78.25% were generated by the residents, and 21.75% by non-residents. The annual trips made by Greennham Reach residents in the period 1 February 2016 – 31 January 2017 was then 3,650. Part 3 To calculate the average mileage per trip, the author divided the total miles driven by the site (Part 1) by the number of trips made by residents (Part 2), i.e. 10,314 miles / 3,650 trips = 2.826 miles per trip or 4.6 km per trip.

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APPENDIX 6: CALCULATIONS FOR TRIPS AVOIDED

Barcombe Nurseries Barcombe Nurseries requires the use of one a sixth of a delivery vehicle every week, but a further sixth of the vehicle for one in three of their weekly deliveries. The businesses proposed with this planning application could replace two thirds of these trips as they could supply all of the produce bought in except potatoes which are bought in for a third of the year only. Potatoes never occupy more than a sixth of a delivery vehicle when bought in weekly for the period of the year that Barcombe grows insufficient potatoes.

Currently Barcombe nursery generates: - 2 trips per week / 6 for two thirds of the year OR ((2/6) * (52*(2/3))) = 11.556 - 2 trips per week / 3 for one third of the year OR ((2/3)* (52*(1/3))) = 11.556

If the proposed businesses displaced the need to buy in all but potatoes, Barcombe nurseries would require: - 2 trips per week / 6 for one third of the year OR ((2/6) * (52*(1/3))) = 5.78

Therefore, this example illustrates a trip saving of (11.556+11.556) – 5.78 = 17.33 per year.

Reducing the Demand for New Conventional Housing AQC have stated in their report that when new housing is delivered, each new dwelling will generate 0.62 AADT through the AFSAC. For a development of 3 dwellings this would be 1.86 AADT, or 678.9 per year.

Total Trip Reduction Total trip reduction has been calculated as the two reductions above, or 17.33 + 678.9 = 696.23.

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