Wealden District Council Local Plan

Development of the Proposed Submission Strategic Sites Local Plan

Pre Submisson Modifications to the Strategic Sites Local Plan

December 2013 How to Contact Us

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A copy of Wealden’s Pre Submission Modifications to the Strategic Sites Local Plan and associated documents can be downloaded from the Planning Policy pages of the Wealden website, www.wealden.gov.uk or scan the QR code below with your smart phone.

If you, or somebody you know, would like the information con- tained in this document in large print, Braille, audio tape/CD or in another language please contact Wealden District Council on 01323 443322 or [email protected] Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

1 Introduction 3 2 Background 5 3 Land at West Uckfield 11 4 Land at East Hailsham 19

5 Land at North Hailsham 25 Contents 6 Land at South and East Willingdon 31 7 Land at Dittons Road, Polegate 37 8 Land at Stone Cross 41 9 Land at Pine Grove, Crowborough 65 10 Land at Jarvis Brook, Crowborough 73 11 Land at South East Crowborough 79 12 Land adjacent to Tunbridge Wells 85 Appendices 91 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) Contents Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

1 Introduction

1.1 The initial Background Paper for the Proposed Submission Strategic Sites Local Plan was published in June 2013, prior to the start of the Regulation 19 consultation period, with the first consultation taking place between 17th June 2013 and 29th July 2013. The paper set out the background to the 11 chosen strategic sites and explained the choice of land for delivering development within each of the Strategic Development Areas (SDAs) identified within the adopted Core Strategy Local Plan (CSLP). It included an explanation of how site areas were selected for allocation, as well as the site specific policy background and justification for specific policies, including those relating to the density of development, green infrastructure, affordable housing and public open space. 1 Introduction

1.2 This amended Background Paper incorporates updates and further information relating to the pre-submission modifications to the Proposed Submission Strategic Sites Local Plan (PSSSLP). The modifications relate to consultation responses received as part of the initial Regulation 19 consultation period in June and July 2013, as well as reflecting further work on viability testing and on the Habitats Regulations Assessment (HRA).

1.3 This background paper should be read in conjunction with other background papers which together form the evidence base for the PSSSLP, including the Sustainability Appraisal Report (SAR), the HRA, the Equalities Impact Assessment, and the Housing Background Paper.(1)

1 http://consult.wealden.gov.uk/portal/planning/strategic_sites/pssslp 3 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 1 Introduction

4 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

2 Background

Core Strategy Local Plan 2013

2.1 Altogether the CSLP makes provision for around 4525 additional dwellings, 40,000 sq. metres additional employment floorspace and 17,000 sq. metres additional retail floorspace across the District. The CSLP identifies eleven SDAs, generally within or adjacent to Wealden’s key towns, which will deliver the majority of this strategic growth and indicates how the overall District provision will be distributed between these.

2.2 Policy WCS4 of the CSLP identifies eleven SDAs: 2 Background

SD1: Land at West Uckfield SD2: Land at East Hailsham SD3: Land at North Hailsham SD4: Land at South Polegate and East Willingdon SD5: Land at Dittons Road, Polegate SD6: Land at East and South East of Stone Cross SD7: Land at North Stone Cross SD8: Land at Pine Grove, Crowborough SD9: Land at Jarvis Brook, Crowborough SD10: Land at South East Crowborough SD11: Land adjacent to Tunbridge Wells, in the Parish of Frant

2.3 The Strategic Sites Local Plan will allocate the land required to deliver development within the eleven SDAs identified in the CSLP, and will provide the necessary policies to achieve sustainable development, in conformity with the CSLP.

Strategic Housing Land Availability Assessment (SHLAA)

2.4 The original District-wide comprehensive SHLAA exercise was carried out in 2008/09, and the results of the assessments were published in 2010. Since this time a number of additional sites have been submitted and previously submitted sites have been reviewed and reassessed where necessary. An updated SHLAA Report, entitled SHLAA for the PSSSLP, forms part of the evidence base to support the PSSSLP.The SHLAA informed the choice of options for development of sites within the broad areas of search, as identified in the Strategic Sites Issues and Options Consultation Paper, and has continued to inform the choice of reasonable alternatives and preferred options for development within each strategic site. As part of the National Planning Policy Framework (NPPF) requirement for all Local Planning Authorities (LPAs) to show that they have a five year deliverable supply of housing land it is necessary to identify and update our land supply figures by assessment of a number of factors including the suitability, viability and deliverability of sites.

5 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 2 Background Issues and Options Consultation Paper 2011

2.5 The Strategic Sites Issues and Options Consultation Paper (I & O) January 2012, presented a number of options for development within each SDA, including the location of development, the percentage of affordable housing to be provided, and key guiding principles for the development in each location. The number of options put forward for accommodating development within the SDAs varied for different SDAs, taking account of all information about the sites available at the time of publication. This is analysed further in the site specific background papers for each SDA(2).

2.6 As part of the consultation on the I & O Paper, consultees were invited to suggest any other reasonable alternatives for development of the identified sites which had not already been considered in the I&O process. This resulted in the submission of additional sites within the wider SDAs identified in the CSLP, as alternative options for development. These alternatives were considered through the Sustainability Appraisal (SA)(3) process and helped to inform the final preferred options for development as identified in the PSSSLP.

2.7 Maps to show the land put forward as options for development within each SDA, as outlined in the I&O Paper, can be found in the Appendices to this Background Paper.

National Planning Policy Framework (NPPF)

2.8 The key issue underpinning the allocation of the strategic sites and the policies within the PSSSLP is the need to achieve sustainable development, in conformity with the NPPF and as set out in Policy WCS14 of the CSLP.

2.9 Consideration of the options for development of the SDAs began prior to publication of the NPPF and a number of the assumptions made are based on requirements of the former Planning Policy Statements (PPS) or Planning Policy Guidance Notes (PPG) which have now been superseded by the NPPF.The NPPF aims to make the planning system less complex and more accessible; to protect the environment and to promote sustainable growth. Where relevant, it summarises and replaces the previous PPGs and PPSs, which were assessed through the SA Scoping Report 2011 and the preceding Scoping Reports, as well as the Background Papers and evidence base informing the choice of sites within the I & O process.

2.10 The NPPF confirms that there should be a presumption in favour of sustainable development and that all plans should be based upon, and reflect this presumption, with clear policies to guide how the presumption will be applied locally.The NPPF also confirms that there are three clear dimensions to sustainable development: economic, social and environmental. The policies within the PSSSLP provide clear guidance on how the presumption in favour of sustainable development will be applied on the strategic sites within the District, taking into account the three dimensions of sustainable development.

2 http://www.wealden.gov.uk/ Wealden/ Planning_and_Building_Control/ Planning_Policy/ Local_Plan/ StrategicSites/ Planning_Policy_Strategic_Sites_Issues_and_Options_Consultation.aspx 6 3 http://consult.wealden.gov.uk/portal/planning/strategic_sites/pssslp Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

2.11 The policies within the PSSLP comply with the presumption in favour of sustainable development and, through the Core Principles policy and individual site specific policies, ensure that the requirements of the NPPF are met across the three dimensions of sustainable development in relation to the design and delivery of each strategic site.

Dwelling Mix

2.12 A significant amount of investigation has been undertaken into the future housing needs of the District and the types and sizes of dwellings that are needed between 2006 and 2027. The PSSSLP specifies the size and type of housing required in relation to

individual strategic sites. This approach accords with the NPPF which states (at paragraph 2 Background 50) that local planning authorities should “identify the size, type, tenure and range of housing required in particular locations” (4). This has been done by examining the nature of the forecast population growth and in particular the forecast changes in certain household types following the methodology used in compiling the Wealden Strategic Housing Market Assessment (SHMA) published in 2009.

2.13 A detailed assessment of household projections has been undertaken by Wealden District Council which generated a dwelling mix profile for Wealden for the types of dwellings which will be required over the period 2006 – 2027. This profile has been used to generate site specific dwelling size mixes in relation to both market and affordable housing for each strategic site, in conjunction with viability testing. The Local Housing Requirement Assessment Working Group, which is an informal grouping of the major professional and representative bodies with an interest in planning for housing in England (see Housing Background Paper(5)) produced a set of results for LPA areas across the country which generally supported the findings of the Council's study.The revised Housing Background Paper (November 2013) supports the pre-submission modifications of the PSSSLP and explains the detailed requirements for each strategic site as proposed in the PSSSLP and summarises the housing mix for Wealden as a whole.

Affordable housing

2.14 The NPPF states that local authorities should plan for a mix of housing which should meet the needs of different groups in the community and also that plans should identify the tenure of housing that is required in particular locations. The Housing Needs Assessment for the District recommends the following mix based on housing needs in the area: 82% social rented housing, 16% intermediate rent and 2% shared ownership. The Housing Background Paper for the pre-submission modifications of the PSSSLP explains the full consideration of housing need in relation to individual site viability and the justification for the tenure mix required within Policy SCP1 (a).

Density

2.15 The densities proposed for development of each strategic site, as identified within the site specific policies in the PSSSLP, have been calculated to accommodate the residential development and associated road infrastructure only. Residential development

4 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 5 http://www.wealden.gov.uk/nmsruntime/saveasdialog.aspx?lID=12862&sID=4346 7 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 2 Background and associated road infrastructure does not include, although is not limited to, land to be used for open space, green infrastructure, education, employment, community use (including health care provision) and environmental mitigation.

2.16 The densities proposed within the PSSSLP make allowance for homes being built to Lifetime Homes standards, as required by the Core Principles Policy SCP1 (p), and as such it is ensured that these standards can be accommodated within the strategic sites. Further information on the Lifetime Homes requirement is contained within the Housing Background Paper to the PSSSLP.

Green Infrastructure and Public Open Space/Amenity Provision

2.17 The Background Paper to the PSSSLP on Green Infrastructure and Public Open Space and Amenity Provision(6) outlines the calculations and reasoning used to quantify the requirements identified within the relevant policies for each site.

Other Evidence Base

2.18 Several additional documents which form part of the evidence base for the PSSSLP have helped to inform the preferred options for development at each of the 11 strategic sites and the formulation of site specific policies. These documents can be found on the Council’s website.

Strategic Flood Risk Assessment (SFRA)(7)

2.19 A Level 1 and 2 SFRA was undertaken as part of the evidence base for the CSLP, to ensure that Flood Risk within Wealden is understood and is managed effectively using a risk-based approach as an integral part of the strategic planning process. The SFRA has informed the selection of sites within the PSSSLP.

Ecological Assessment of the Strategic Sites Issues and Options Consultation Paper(8)

2.20 This assessment was carried out by an ecological consultancy for the Council in 2011 and comprised an extended Phase 1 habitat survey and protected species risk assessment for each of the SDAs. The aim of the assessment was to provide detailed information to inform the process of identifying suitable sites for future development. The report presented a desk top survey for each SDA and field surveys for each of the options identified in the I & O Paper. The report identified specific habitats of value and sensitivity and made recommendations for the protection, maintenance, enhancement, restoration and creation of habitats. The report also identified opportunities to improve the District’s Green Infrastructure (GI) provision and GI network and made recommendations on options for mitigation, compensation and enhancement for ecological purposes within the SDAs.

6 http://consult.wealden.gov.uk/portal/planning/strategic_sites/pssslp 7 http://www.wealden.gov.uk/ Wealden/ Planning_and_Building_Control/ Planning_Policy/ Local_Plan/ CoreStrategy/ CoreStrategyLibrary/ Planning_Core_Strategy_Library.aspx 8 http://www.wealden.gov.uk/ Wealden/ Planning_and_Building_Control/ Planning_Policy/ Local_Plan/ StrategicSites/ 8 Strategic_Sites_Library/ Planning_Strategic_Sites_Evidence_Ecology.aspx Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Habitats Regulations Assessment (HRA) for the PSSSLP(9)

2.21 The initial assessment cumulatively built on the HRA for the CSLP and identified and analysed effects on the ecological integrity of European and Internationally designated sites. The HRA has been amended to address consultation responses and further bespoke work in relation to avoidance and mitigation measures and the pre-submission modifications reflect recommended changes from the HRA for each of the allocations where a significant effect was deemed likely as a result of the plan. Subject to the implementation of avoidance and mitigation measures it can be concluded that the PSSSLP will not result in an adverse effect on any European or International site, either alone or in combination with other

projects or plans. 2 Background

Landscape Character Assessment and Development Option Evaluation Study, February 2009. Volumes 1-3 (10)

2.22 The Landscape Group of East Sussex County Council (ESCC) was commissioned in September 2007 by Wealden District Council to carry out a Landscape Character Assessment and Development Option Evaluation Study. The study was intended to inform the preparation of the CSLP, and helped to inform the broad areas of search for the SDAs. The study has subsequently been used to help inform the I&O process and choice of preferred options for development of the strategic sites in the PSSSLP.

Equalities Impact Assessment (EqIA) for the PSSSLP(11)

2.23 The EqIA is a way of helping to identify the likely or actual effects of policies on people in respect of their age, race, disability, gender, sexual orientation, religion or belief. The aim of the assessment is to make sure that, as far as possible, any negative consequences for minority groups are eliminated or minimised, and opportunities for promoting equality are maximised. The requirement to undertake an EqIA stems from the duty placed on local authorities to ensure that unlawful discrimination against different groups within the community is eliminated and opportunities to promote equality are maximised. This is a requirement of the Equality Act 2010. The EqIA has been prepared in accordance with the Wealden Equality Scheme for assessing the impact of the PSSSLP on the aforementioned groups.

Viability Testing Study of the Strategic Development Areas(12)

2.24 An external consultant was commissioned by the Council to provide viability testing of the strategic sites identified within the PSSSLP. The strategic sites were initially tested in February 2013 to ensure that the combined impact of the Council’s proposed Community Infrastructure Levy (CIL), affordable housing policies and other Section 106 demands together with the general requirements of planning policies would be both affordable and deliverable by the private sector. Further testing was carried out subsequent to the initial

9 http://consult.wealden.gov.uk/portal/planning/strategic_sites/pssslp 10 http://www.wealden.gov.uk/ Wealden/ Planning_and_Building_Control/ Planning_Policy/ Local_Plan/ CoreStrategy/ CoreStrategyLibrary/ Planning_Core_Strategy_Library.aspx 11 http://consult.wealden.gov.uk/portal/planning/strategic_sites/pssslp 12 http://www.wealden.gov.uk/ Wealden/ Planning_and_Building_Control/ Planning_Policy/ Local_Plan/ StrategicSites/ Strategic_Sites_Library/ Planning_Strategic_Sites_Evidence_Housing.aspx 9 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 2 Background Regulation 19 consultation period in June and July 2013 and a final report was produced in November 2013. Recommendations for alterations to housing mix, density and affordable housing are therefore reflected in the pre-submission modifications to the PSSSLP as appropriate.

2.25 For each strategic site for which housing development is proposed the following was tested:

A bespoke economic viability assessment for alternative scenarios of development for each site; The impact of different affordable housing requirements on viability; The impact of the operation of Section 106 and CIL on viability; and Wider infrastructure implications and the impact of green infrastructure and biodiversity policies.

2.26 The final report (November 2013) supports the introduction of a CIL and the development of the strategic sites as outlined in the pre-submisssion modifications and the PSSSLP and was carried out as per Valuation Standards 1 of the RICS Valuation Standards – Global and UK Edition 3. Appendices of the Viability Testing Studies provide viability appraisals for each strategic site in relation to alternative scenarios.

10 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

3 Land at West Uckfield

3.1 The comprehensive SHLAA undertaken by the Council in 2008-2009 identified that land was suitable, available and achievable on land to the south west of Uckfield. This land subsequently formed part of the broad area of search for new strategic development to serve Uckfield as identified in the adopted CSLP. At this time the majority of the land which made up the area of search was within one ownership, comprising Ridgewood Farm, however a second, smaller area, identified as ‘Thorncrest’, which is a residential dwelling with associated land, including a former quarry, was also submitted.

3.2 At I&O stage, the opportunities and constraints of developing the Land at West Uckfield were identified in the Uckfield Background Paper, and these are summarised below:

Opportunities

Secure odour mitigation measures at Uckfield Waste Water Treatment Works (WWTW) – will benefit existing and new residents, and occupiers of the adjacent industrial Land at West Uckfield West 3 Land at estate. Improve connectivity to the local area – great opportunities with existing on site footpaths and provision of new pedestrian and cycle links to town centre, existing local facilities and the countryside. Enhance biodiversity of the site and reduce flood risk and surface water run off – could be achieved through retention, protection and enhancement of existing features of ecological value and incorporation of SUDS, such as swales, balancing ponds, open watercourses and attenuation ponds. Vehicular access – opportunities for provision of new access from the A22 and potential for limited access from Lewes Road. Address climate change issues and include renewable energy – the site is predominantly south and west facing and could support renewable energy. Create open space/green infrastructure provision, including provision of Suitable Alternative Natural Green Space (SANGS) and enhancement of existing green infrastructure in SDA and locally. Removal of prominent buildings on ridgeline and re-use of small areas of previously developed land Retention of good landscaping elements to form and enhance green infrastructure in layout of future development, such as the significant range of strong landscape features, including ancient woodland, woodland/copse, water courses, and mature hedgerows.

Constraints

Proximity of WWTW – level of odour, operational disturbance etc., could constrain development in the northwest part of the SDA and mitigation measures will be required and funded through the site development.

11 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 3 Land at West Uckfield Proximity of A22 trunk road and adjacent industrial estate – potential for noise disturbance. Appropriate acoustic mitigation measures would be required within the design of future development. Loss of agricultural land currently used for grazing. Vehicular access – existing access to the site would not have capacity for additional vehicular traffic and new access points will be required. There is Ancient woodland on and adjacent to the site and there will be a need for a 15m buffer zone to this from all new development. Flood Zone (2 and 3) adjacent to Ridgewood Stream which runs along the western boundary and through the southern part of the SDA within which development cannot take place. Exposed and prominent site within the landscape – the southern part of the SDA is exposed to long range views and creative design of new development will be required. Retention of habitats and features of ecological importance.

3.3 The consideration of the opportunities and constraints informed the guiding principles for development of the SDA at West Uckfield and these were comprehensively consulted upon within the I & O exercise.

PSSSLP Policy and Site Area for Land at West Uckfield

3.4 The land proposed for allocation as the strategic site at Uckfield, and the accompanying policies, have been informed by the consultation process and the constraints and opportunities identified.

Additional land incorporated within the proposed Strategic Site but not included within the Issues and Options Paper

3.5 Subsequent to I & O stage, and during the formulation of the PSSSLP, additional land at Cress Farm and the adjacent Sawmill was put forward for consideration. These two sites adjacent to Lewes Road to the southeast of the SDA, were considered under the SHLAA methodology and deemed suitable, available and achievable in conjunction with development of the wider SDA to the west. In addition, land at Springfield to the north of the additional sites, previously submitted under the SHLAA but deemed unacceptable due to access issues, would now be appropriate due to the links between the three sites.

Land at Cress Farm, Ridgewood – Opportunities and Constraints

3.6 The site lies on the urban edge of Uckfield, adjacent to land to the west that has been identified for strategic development of the town, and could potentially help to deliver housing, employment and educational facilities required within the SDA.

3.7 Pedestrian and cycle access could be provided on to Lewes Road. The site has good accessibility to local services, including a Post Office, bus stops and school. The railway station and town centre are only around 1.7km to the north east.

3.8 The topography of the site would not prevent development. Mitigation may be 12 required in relation to road noise; however the location of the site to the rear of properties Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

facing on to Lewes Road would help to reduce noise impact. Vehicular access would be required across third party land, from the Ridgewood Farm site to the west.

3.9 There are good opportunities to enhance biodiversity and green infrastructure in the general area through development in combination with other sites.

3.10 Mitigation would be required to address the requirements of the Habitat Regulations Assessment in relation to the designated European Sites on the Ashdown Forest through provision of SANGS and Strategic Access Monitoring and Management framework (SAMMS).

Land at The Sawmill, Ridgewood – Opportunities and Constraints

3.11 The site lies on the urban edge of Uckfield, adjacent to land to the west that has been identified for strategic development of the town, and could potentially help to deliver housing, employment and educational facilities required within the SDA.

3.12 Pedestrian and cycle access could be provided on to Lewes Road. The site has good accessibility to local services, including a Post Office, bus stops and school. The Uckfield West 3 Land at railway station and town centre are only around 1.7km to the north east.

3.13 The topography of the site would not prevent development. Mitigation may be required in relation to road noise; however the location of the site to the rear of properties facing on to Lewes Road would help to reduce noise impact. Vehicular access would be required across third party land, from the Ridgewood Farm site to the west.

3.14 There are good opportunities to enhance biodiversity and green infrastructure in the general area through development in combination with other sites.

3.15 Mitigation would be required to address the requirements of the Habitat Regulations Assessment in relation to the designated European Sites on the Ashdown Forest through provision of SANGS and SAMMS.

3.16 This is an existing employment site and redevelopment for residential use only is proposed by the landowner. Such a development could result in the loss of employment land which could have a detrimental impact on the wider economy of the area and therefore mitigation would be required in the form of additional provision elsewhere within the strategic site.

Land at Springfield, Ridgewood – Opportunities and Constraints

3.17 The site lies on the urban edge of Uckfield, adjacent to land to the west that has been identified for strategic development of the town, and could potentially help to deliver housing, employment and educational facilities required within the SDA.

3.18 Pedestrian and cycle access could be provided on to Lewes Road. The site has good accessibility to local services, including a Post Office, bus stops and school. The railway station and town centre are only around 1.7km to the north east. 13 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 3 Land at West Uckfield 3.19 The topography of the site would not prevent development. Mitigation may be required in relation to road noise; however the location of the site to the rear of properties facing on to Lewes Road would help to reduce noise impact. Vehicular access would be required across third party land, from the Ridgewood Farm site to the west.

3.20 There are good opportunities to enhance biodiversity and green infrastructure in the general area through development in combination with other sites.

3.21 Mitigation would be required to address the requirements of the Habitat Regulations Assessment in relation to the designated European Sites on the Ashdown Forest through provision of SANGS and SAMMS.

Site Area

3.22 A total of 82ha has been identified within the PSSSLP to deliver development of 1000 houses, employment floor space and educational facilities, identified as site UC1 (see Appendix 1 for map). Initially the site area comprised land submitted at Ridgewood Farm and Thorncrest, and this formed the original preferred option for development. The inclusion of the three additional sites (Cress Farm, Springfield and the Sawmill), would provide scope for pedestrian and cycle access on to Lewes Road to the south and east, with associated facilities and public transport links.

3.23 The inclusion of the three additional site areas into the preferred strategic site allowed reconsideration of the previously included land at Thorncrest. This land comprises a dwelling with extensive gardens, including a former quarry with local ecological value and connectivity to important off-site habitats at Boothland Wood, which is ancient woodland. The quarry area would require a substantial ecological buffer to any new development and long term management to realise its full ecological potential. Links to the wider habitat in the local area would also be required and these matters together would substantially reduce the land available for development within this site. Taking this into account, it was not clear whether the inclusion of Thorncrest within the preferred strategic site area could have an impact on the wider viability of development, particularly affordable housing provision, due to the reduction in land take for development purposes and the costs of long term ecological management. Although the site owner is keen to retain the land at Thorncrest within the strategic site allocation boundary, the developer with the option on the land at Ridgewood Farm was approached to discuss the removal of land at Thorncrest, and made no argument at the time for its retention within the preferred strategic site.

Density and Housing Numbers

3.24 The residential development of Land at West Uckfield is guided by a number of constraints including the Habitats Regulations (housing numbers and provision of SANGS), the sloping topography, odour from the WWTW, the Flood Zone adjacent to Ridgewood Stream, noise, and the need to provide substantial green infrastructure and public open space in addition to SANGS. 14 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

3.25 The HRA for the Core Strategy identified the number of new residential dwellings that would be acceptable for Uckfield and would not have an adverse impact on the Ashdown Forest SPA and SAC, in combination with other planned development, with mitigation in the form of SANGS and SAMMS. The PSSSLP identifies that the site at Uckfield is required to provide 18.4ha of SANGS and around 12ha of this is to be on site. This provision would constrain the amount and the location of land within the strategic site available for development. The SANGS provision outlined is in addition to the requirement to provide public open space and leisure facilities to serve the new development, further constraining the site area available for development.

3.26 The land area available for development would also be constrained by four further factors: the requirement to provide a 15m buffer between development and ancient woodland on or adjacent to the site; the need to avoid development in Flood Zones 2 and 3 in the vicinity of Ridgewood Stream; the need to avoid residential development on land that may be affected by odour from the WWTW unless suitable mitigation can be agreed, or in such proximity that it would effect the future operation of the WWTW; and provision of on-site mitigation for road noise from the A22, which is on lower ground than the majority

of the strategic site. Uckfield West 3 Land at

3.27 The Ridgewood Stream and its associated Flood Zone borders the western side of the site and also bisects the southern part of the site. Notwithstanding the constraint to developing in areas of Flood Risk, the southernmost part of the strategic site is divorced from the remainder of the land by the route of the stream. Access to development on the southern part would be prohibited by the expense of crossing the stream and flood zone area in a manner acceptable to the Environment Agency.

Employment Floorspace

3.28 The site area identified to provide the employment floor space was originally based on the ratios within the Employment Land Review (ELR) and the 13,495m² net floor space equated to around 1.7ha. However, more recent planning proposals for employment floor space within the District would increase the site area required to around 3.82ha to ensure all relevant accompanying infrastructure can be accommodated appropriately.

Education Facilities

3.29 Around 2ha is required, based on ESCC requirements, to provide a 1 form entry primary school with early years’ provision. However, further land may be required if secondary school provision is needed on site, and discussions are on going with the education authority on this point.

Pre-submission modifications to the PSSSLP

3.30 The representations received as part of the Regulation 19 consultation in June and July 2013 relate to a number of specific matters, including the odour mitigation requirements, SANGS provision, biodiversity policies, access arrangements and open space provision. 15 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 3 Land at West Uckfield 3.31 In order to address the representations, amendments have been made to the policies relating to the Land at West Uckfield to clarify when development can be occupied with regards to odour mitigation matters. Amendments have also been proposed to provide more flexibility regarding biodiversity, access and the siting of the required employment provision. Further clarification has been given to open space requirements.

3.32 The final viability assessment of the Strategic Sites was completed by the Council's appointed consultants in November 2013. The study shows that minor modifications were required to policies in the PSSSLP and supporting text to enhance viability and the changes have been derived to ensure compliance with the NPPF whilst ensuring viability. At Land at West Uckfield, the proposed changes relate to an increase in density from 25dph to 30dph and a proposed change in the dwelling mix.

3.33 In relation to SANGS provision, work has progressed significantly since the PSSSLP was published. This work has shown that the simple quantitative standards were not fit for purpose in the Wealden context and therefore have been removed from the Policy for both Uckfield and Crowborough. The SANGS guidelines have been amended to reflect this position and which now reflects a more qualitative and bespoke solution for any particular site . In addition, and to facilitate a more flexible approach to SANGS provision and development, the policy has been reworded to allow for SANGS to be provided off-site.

3.34 There is one omission site submitted as part of the representations procedure; Land at Thorncrest, Ridgewood Road. This site has been part of the Sustainability Appraisal process and therefore has already been considered as a potentially reasonable alternative and was also considered in the text above within this chapter. Notwithstanding this, on further consideration of the representations received by both the majority landowner of the allocated site and the landowners of Thorncrest it is proposed to not include the site within the allocation for Uckfield. In addition, the Viability Testing Study (November 2013) considers the viability of site CRA to provide the housing, employment and educational uses proposed as being viable without the land at Thorncrest. Thorncrest comprises a substantial detached house and associated land, likely to have a high land value and therefore, likely to have an adverse impact on the viability of the wider site within the viability parameters tested.

16 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Summary for Land at West Uckfield

Overall available land area: 82 hectares

Land Requirements:

Housing land at 30dph : 33.3 hectares

Employment area: 3.82 hectares(13)

Education area: 2 hectares

SANGS: To be included within remaining land area. No specific quantity now proposed.

Public Open Space: 7 hectares

Total land requirement: 46.12 hectares Land at West Uckfield West 3 Land at Land remaining: 35.88 hectares

Summary

3.35 The increase in density from 25dph to 30dph reduces the land take required to accommodate the housing from 40ha to 33.3ha. The originally proposed 12ha of land required for SANGS is removed from the figures above as a qualitative rather than quantitative approach is now being sought, with SANGS on site forming part of a wider suite of SANGS, incorporating land off site. Therefore, the total land requirement has reduced from 64.82ha to 46.12ha, leaving a remaining land area of 35.88ha (an increase of 18.7ha) to incorporate green infrastructure, odour mitigation and SANGS, and the potential for secondary school land, if required in future.

Constraints Commentary

3.36 Development cannot take place within Flood Zones 2 and 3 and this equates to around 5.48ha on this site, although it may be possible to provide Sustainable Urban Drainage Systems (SUDS) in parts of these areas, subject to further assessment works.

3.37 In addition, although the site area is further constrained by the requirement for a buffer between built development and ancient woodland (approximately 2.7ha in total) it may be possible to provide some public open space in these areas. Although the odour mitigation zone around the WWTW amounts to approximately18.8ha in total, it may actually be partially suitable to accommodate certain types of development, including potentially new residential uses should an appropriate mitigation strategy be agreed by all parties.

13 The employment floor space is calculated on 1sqm of employment floor space requiring 0.00028292ha to ensure all relevant infrastructure can be accommodated appropriately. 17 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 3 Land at West Uckfield 3.38 Taking these issues into account, it is considered that sufficient land is available at Land at West Uckfield, Site UCA, to provide around 1000 dwellings at the density required, along with the employment floor space and education facilities, SANGS and public open space, despite the known constraints to development on parts of the site.

18 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

4 Land at East Hailsham

4.1 The comprehensive SHLAA undertaken by the Council in 2008-2009 identified that land was suitable, available and achievable and on land to the east of Hailsham. This land subsequently formed part of the broad area of search for new strategic development to serve Hailsham, as identified in the adopted CSLP.

4.2 At I & O stage, the opportunities and constraints of developing the land East of Hailsham were identified in the Hailsham Background Paper and these are summarised below:

Opportunities

Secure odour mitigation measures at Hailsham North WWTW – this will benefit occupiers of both existing and new development through improving air quality. Enhance and create open/green infrastructure provision. Enhance biodiversity value of the site and reduce flood risk and surface water run off – including retaining and enhancing existing trees, hedgerows and ecological

features. Part of the SDA is within a Biodiversity Opportunity area and there is 4 Land at East Hailsham opportunity to improve the biodiversity and ecological value of the site as part of the Green Infrastructure provision as well as through the incorporation of SUDS. Improve the rate and quality of discharge to water courses and the Pevensey Levels in line with the Water Framework directive objectives – the use of SUDS will also assist climate change objectives through reducing surface water flow and absorption and reducing the level of run off to local streams, rivers and the Pevensey Levels. Vehicular access – opportunities for several points of access from Battle Road and from Amberstone Road. Footpath/cycle routes – good opportunities through creative design to incorporate the many public footpaths that extend through the site, to increase connectivity to the countryside and additional green infrastructure provision, together with providing greater connectivity to the town centre and wider locality. Address climate change issues and include renewable energy – utilising site orientation which is predominantly south and east facing.

Constraints

Proximity of WWTW – level of odour, vehicular movements and noise/operation disturbance from the WWTW is a constraint to development. Mitigation measures will be required and costs funded through development. The site within the landscape – the southerly parts of the land to the north of Harebeating Lane enjoy long range views to the south and southeast towards the Pevensey Levels and design of development will need to mitigate the impact. The loss of agricultural land use for grazing. Vehicular access – traffic modelling required regarding impact of development on Battle Road, the A271, the Boship roundabout and the A22. Road improvements required in accordance with South Wealden and Transport Study (SWETS). 19 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 4 Land at East Hailsham Biodiversity – the SDA is around 200m from the Pevensey Levels Ramsar Site and Site of Special Scientific Interest (SSSI). Development on the SDA will have to be considered in relation to potential impacts on biodiversity within the Levels and assess opportunities to enhance biodiversity. Retention of existing trees and hedgerows within the SDA could provide a challenge to design of development. Flood Zones 2 and 3a extend into the north-eastern and south-eastern parts of the SDA and buffer zones to development will be required to accommodate the effects of climate change, thereby impacting on the land available for development.

4.3 The consideration of the opportunities and constraints informed the guiding principles for development of the SDA at Land East of Hailsham and these were comprehensively consulted upon within the Issues and Options exercise.

PSSSLP Policy and Site Area for Land at East Hailsham

4.4 The land identified in the PSSSLP for the strategic site at Land at East Hailsham and the accompanying policies have been informed by the consultation process and the constraints and opportunities identified. The strategic site is split into three defined areas identified as sites HHA, HHB and HHC (see Appendix 2 for Map).

Site Area

4.5 The proximity of the Pevensey Levels and potential for odour nuisance from the WWTW are key issues to consider and has lead to the preferred site allocation boundary as shown in the PSSSLP.

4.6 The guiding principles for development clearly raised the issue of the need to concentrate built form within the western side of the strategic site, closest to Battle Road, early within the process of considering options for developing the site and to utilise the remainder of the site area for the provision of green infrastructure and biodiversity requirements. This stance is reinforced by the Landscape Character Assessment and Development Option Evaluation Study, which was published February 2009. Volumes 1-3 of the Study note that the town centre abuts on to countryside with hedge patterned slopes descending towards the Pevensey Levels, providing an area of countryside that is both visually and physically accessible. This attractive countryside to the east of the town is highly visible from the sensitive countryside of the Pevensey Levels. The consultation response from Natural England on the proposed options for development at East Hailsham also highlighted the close proximity of the land to the Pevensey Levels Ramsar site and SSSI. Concerns were raised that the sloping parts of the site and the watercourses which traverse the land run into the Pevensey Levels. Consequently, changes in the existing hydrological regime, either via changes in water quality or quantity through development, will require appropriate assessment for any development in this location to investigate any potential likely significant effect on the adjacent international wildlife site. Natural England summarised in their response that whichever option provides the best opportunity to safeguard existing wildlife features, protect the Pevensey Levels and provides potential for future biodiversity interest, should be the preferred option. 20 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

4.7 The eastern boundary of Site HHC has therefore been drawn relatively tightly towards the existing eastern urban edge of the town, utilising the natural hedge and footpath feature in the northern part of this site, and then following the contour line to incorporate higher land in the south eastern part of the site. This approach should minimise the visual encroachment of development on the landscape of the Pevensey Levels to the east, as outlined in the Landscape Character Assessment and Development Option Evaluation Study of February 2009, by restricting development on areas of land which are prominent in more long distant views and would also minimise the potential hydrological impacts of development.

4.8 Constraining development tightly to the eastern edge of Hailsham is a natural continuation of the current built edge of the town in this area, and would allow for an appropriate environmental buffer to the open countryside of the Pevensey Levels to the east of the strategic site. This buffer area could also include SUDS provision, open space provision and other green infrastructure, all of which could ensure a net gain in biodiversity can be achieved on the site, whilst minimising impact on the existing hydrological regime of the Pevensey Levels and reducing visual impact on the landscape to the east.

4.9 It is envisaged that the environmental buffer would be continuous along the eastern 4 Land at East Hailsham edge of all three sites and would create a soft edge to the landscape of the adjacent Pevensey Levels. Substantial tree planting in this area would be out of character and, therefore, the amount of land available for the environmental mitigation reflects the need to respect the existing character of the strategic site, but should also provide effective scope for appropriate mitigation for the visual impact of development.

4.10 The central and northern parts of the proposed strategic site are also partially constrained by potential odour nuisance from the WWTW. The 300 metre odour mitigation zone reflects the two main concerns raised by Southern Water, namely that the WWTW are essentially subject to industrial processes with corresponding potential of disturbance to nearby neighbours and that any odour mitigation measures will not be able to be consistently applied (due to maintenance requirements and potential leaks). Whilst there is potential to allow development within 300m, subject to consideration of nuisance issues, the allocation has been formulated to draw back the built form from the Pevensey Levels, respect the landscape and to use the land efficiently, taking into account the capacity of the WWTW to accommodate growth. In this case the 300m is inflexible, as there is no need to infringe in this area. It should also be recognised that the most sustainable location for development is closest to the Town Centre. The 300m zone does not impact on the southernmost site (HHC), therefore giving some flexibility, with justification, for housing in the Environmental Mitigation Area, subject to Habitat Regulations Assessment and Landscape Impact Assessment, should additional land area be required to deliver the 700 units allocated. Policy SHH1 (as modified) addresses this issue and is discussed below.

4.11 The developable area of land, not including the environmental mitigation area on the eastern edge of the strategic site, comprises around 33.71ha, and this land is to deliver the housing allocation of 600 dwellings at a density of 29dph, or 129 habitable rooms per hectare, across the three identified sites (HHA, HHB and HHC). This density should 21 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 4 Land at East Hailsham ensure that the rural edge character of the area can be reflected, that the land can be used efficiently and effectively, but also that appropriate and sensitive green infrastructure can be incorporated within the development together with public open space.

4.12 The housing numbers across the three sites has been restricted by the capacity of the WWTW to accommodate new development, in combination with other allocated housing in the CSLP, without further detriment to water quality on the Pevensey Levels.

Pre-submission modifications to the PSSSLP

4.13 The representations received as part of the Regulation 19 consultation in June and July 2013 relate to a number of specific matters, including principle of development, the land area available and ownership issues.

4.14 A number of representations have been received about the principle of development of this area as well as policy specific representations. Landowners have submitted arguments that parts of the site are not large enough to accommodate growth and that additional land should be allowed to be developed. Other developers consider that the land in multiple landownership will not be delivered within the time frame of the plan and that alternative sites should be allocated.

4.15 Some of the concerns received suggest that without allowing more land this could in fact have the opposite effect of the Council’s overall objective, namely to maintain a soft and landscaped eastern edge to the development of the town and ensure adequate protection of the Pevensey Levels. In order to address some of the concerns raised it is proposed to enlarge the environmental mitigation area, in order to provide for the open space, green infrastructure and drainage requirements, whilst protecting the Pevensey Levels. However, to ensure that there is not a hard line of built development against the backdrop of the Pevensey Levels, the proposed modifications allow residential development within the environmental mitigation area where this leads to an appropriate and acceptable form of development. This is subject to the developer proving it is required to mitigate landscape impact and subject to HRA. The density has also been rationalised to 30 dwellings per hectare, reflecting the overall higher densities in this area and therefore slightly decreasing the land-take required to accommodate the housing to be provided.

4.16 The final viability assessment of the Strategic Sites was completed by the Council's appointed consultants in November 2013. The study shows that minor modifications were required to policies within the PSSSLP and supporting text to enhance viability and the changes have been derived to ensure compliance with the NPPF whilst ensuring viability. At Land at East Hailsham, the proposed changes relate solely to an increase in density from 29dph to 30dph.

4.17 In order to reflect amendments to other similar policies in the plan, proposed modifications have also been made to biodiversity and open space policies.

22 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Summary for Land at East Hailsham

Overall available land area across the three sites: 33.71 hectares

Land Requirements:

Housing land at 30dph: 20 hectares

Environmental Mitigation Zone: 12.62 hectares (to include the Public Open Space)

Total land requirement: 32.62 hectares

Land remaining: 1.09 hectares

Summary

4.18 The increase in density from 29dph to 30dph reduces the land take required to 4 Land at East Hailsham accommodate the housing from 20.68 ha to 20ha. Therefore, the total land requirement has reduced from 33.30ha to 32.62ha, leaving a remaining land area of 1.09ha (an increase of 0.58ha).

Constraints Commentary

4.19 In order to ensure that the housing development can be confined to the area of the strategic site closest to the existing eastern urban edge of Hailsham, only a small element of total additional land across all three identified sites has been allowed for (1.09ha). The proposed average density of 30dph should enable flexibility in the design and layout of the development of 600 net dwellings and the accommodation of green infrastructure to ensure a net gain in biodiversity is achieved. The public open space requirement of 4.45ha can be provided within the environmental mitigation zone on the eastern edge of the sites to help ensure that a soft edge to the development is provided with the countryside to the east.

23 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 4 Land at East Hailsham

24 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

5 Land at North Hailsham

5.1 The comprehensive SHLAA undertaken by the Council in 2008-2009 identified that land was suitable, available and achievable at North Hailsham. This land subsequently formed part of the broad area of search for new strategic development to serve Hailsham as identified in the adopted CSLP.

5.2 At I & O stage, the opportunities and constraints of developing the land North of Hailsham were identified and these are summarised below.The individual site references are those used in the I & O Paper and may differ to those in the PSSSLP (see Appendix 3 for map).

Opportunities

Road access – opportunities to provide several points of access from both New Road and Park Road. Footpath and cycle routes – opportunities to link to the National Cycle Route (NCR) to the west of the SDA and incorporate existing footpath network into the design of development. Development could also enhance accessibility,

connectivity and green infrastructure in the local area. 5 Land at North Hailsham Reduction in flood risk and surface water run off, along with an enhancement to biodiversity and the green infrastructure network – there are a range of opportunities for SUDS. Enhancement and improvement of open space provision to support development of the SDA, to include green infrastructure, including accessible play facilities and teenage facilities. Enhancement of the biodiversity and green infrastructure value of the site especially as the SDA is adjacent to the Hailsham North Biodiversity Opportunity Area. Retention and enhancement of areas identified as being of ecological importance, including woodland, ancient woodland, species rich hedgerows, mature trees, semi-improved grassland and discrete areas of marshy grassland. Creation and enhancement of a green infrastructure network to improve connectivity and accessibility and to enhance integrated transport networks. Use of existing footpath routes to increase connectivity and provision of new walking and cycling networks and linkages to existing facilities including the Cuckoo trail to provide access to extensive tracts of open countryside and a range of employment, social and community facilities, open space and recreation facilities. Improvement of the rate and quality of discharge to water courses and the Pevensey Levels in line with Water Framework Directive objectives through the use of SUDS to reduce surface water flow and absorption and level of run off. Addressing climate change issues through the design and layout of development through utilising the predominantly south facing orientation of the site. Inclusion of renewable energy.

25 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) Land at North Hailsham 5 Land at North Constraints

Access to main roads from the sites will need to be upgraded and improved and junction improvements on the A271 and A22 may also be required. Footpaths could constrain the development of Site C where there is a criss-crossing network of statutory footpaths, thereby requiring some diversions, depending on usage and popularity of routes. Part of the site is within Flood Zones 2 and 3 requiring the implementation of a 50m buffer zone and will reduce the land available for development, but will provide opportunities to incorporate a range of SUDS and promote opportunities to enhance the biodiversity of the site and the green infrastructure network. Due to the proximity of the land to the Pevensey Levels Ramsar Site and SSSI, development will have to be considered in relation to potential impacts on biodiversity within the Levels. In addition, areas of ecological importance on the site including Ancient Woodland areas and habitat restoration will impact on land available for development. The development of the land at North Hailsham will involve the loss of agricultural land. There is an overall deficit of formal and informal open space provision in the area and the incorporation of new facilities will help to address some of the current deficiencies, and ensure the provision of facilities for new residents. A number of drainage ditches on the site drain into the Pevensey Levels and mitigation measures will be required on site through the use of SUDS to ensure development meets the requirements of the Water Framework Directive.

5.3 The consideration of the opportunities and constraints informed the guiding principles for development of the SDA at Land North of Hailsham and these were comprehensively consulted upon within the Issues and Options exercise.

PSSSLP Policy and Site Area for Land at North Hailsham

5.4 The land identified in the PSSSLP for the strategic site at North Hailsham and the accompanying policies have been informed by the consultation process and the constraints and opportunities identified. The strategic site is split into two defined areas identified as Sites HHD and HHE.

Site Area

5.5 The protection of Hellingly Village from visual coalescence with development at North Hailsham is a key issue and has led to the preferred site area as shown in the PSSSLP, identified as Sites HHD and HHE (see Appendix 3 for map).

5.6 The northern boundary of the proposed Site HHD has been drawn to minimise the visual impact of new development on Hellingly Village and to reduce the perception of visual coalescence between the north of Hailsham and the historic village of Hellingly. The proposed northern boundary to Site HHD continues the existing hedge line running east - west from Park Road, across the open field, to link with the northern tip of the 26 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

ancient woodland on the western boundary. This should enable the creation of new green infrastructure comprising a substantial wildlife corridor to help ensure a net gain in biodiversity can be achieved. The eastern, western and southern boundaries of the site are contained by existing features, namely Park Road, the Cuckoo Trail, woodland, existing built development on the A271 and allotments.

5.7 The north western boundary of the proposed Site HHE has been drawn to link with the northern boundary of Site HHD to the west to ensure that the development of the two sites can be read together as a cohesive urban extension to the north of Hailsham. Restricting any built form in the north western part of the field, beyond the boundary line for Site HHE, would also minimise the visual impact of new development on Hellingly Village and reduce the perception of visual coalescence between the north of Hailsham and the historic village. The remainder of the northern boundary of the site follows the route of New Road, which forms a natural edge to the strategic site and would link the current sporadic development on the road to the north of Hailsham.The eastern boundary of the developable area of the strategic site is constrained by the Hurst Haven Stream, which feeds directly into the Pevensey Levels, and the associated environmental mitigation area. The southern boundary is formed by existing urban development on the northern edge of Hailsham. 5 Land at North Hailsham 5.8 The chosen option for the proposed strategic site comprising Sites HHD and HHE would ensure that the new development can retain a close relationship to the existing urban area of North Hailsham, enabling the creation of sustainable links to existing services and facilities in the town. The choice of the two sites and the restriction in spread of development to the north-west would also ensure that Hellingly village can remain as a distinct and separated settlement and would not be subsumed into the town.

Alternative land submitted during consideration process

5.9 Alternative land was submitted as part of the SHLAA comprising the Sussex Plants Nursery site to the north of HHD. This site falls within the broad area of search within the SDA and could potentially help to deliver housing, employment and educational facilities required within the strategic area in combination with other sites. The site has good linkages for pedestrians and cyclists, and is close to the Cuckoo Trail. Public transport facilities are available along Park Road.

5.10 However, this is an existing employment site and redevelopment for residential use only is proposed by the landowner. Such a development could result in the loss of employment land which could have detrimental impact on the wider economy of the area and therefore mitigation would be required in the form of additional provision elsewhere within the strategic site.

5.11 In addition, development of this area would impact upon the existing visual gap between Hellingly in the west and the north of Hailsham and may lead to the perception of urban coalescence with the historic village and designated Conservation Area . The Landscape Study, which forms part of the evidence base, states that this should be avoided and this land does not form part of the site allocation boundary as proposed in the PSSSLP. 27 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) Land at North Hailsham 5 Land at North Density and Housing Numbers

5.12 The developable area of land, not including the environmental mitigation area on the eastern edge of the strategic site, comprises around 41ha. This land is proposed to deliver the housing allocation of 700 dwellings at a density of 27dph, or 120 habitable rooms per hectare, across the two identified sites (HHD and HHE). This density would ensure that the rural edge character of the area can be reflected, that the land can be used efficiently and effectively, but also that appropriate and sensitive green infrastructure can be incorporated within the development, together with public open space.

5.13 The housing numbers across the two sites have been restricted by the capacity of the WWTW to accommodate new development, in combination with other allocated housing in the Core Strategy, without further detriment to water quality on the Pevensey Levels.

Other Uses

5.14 The proposed strategic site allocation also includes a requirement for land for education facilities comprising around 2ha in size (as advised by ESCC as Education Authority) and employment land for the provision of 8,650m² net floor space of around 2.45ha. This latter area is based on a plot size greater than that shown in the ELR and is based on a recent stand alone scheme in the District to provide modern standard employment facilities.

5.15 In addition to education facilities and employment floor space, an element of retail use has also been allocated to the proposed strategic site and it is envisaged that an area of around 0.07ha would be required to provide 300m² of retail floor space with associated car parking and ancillary areas based on recent similar development in the District.

5.16 Pre-submission modifications to the PSSSLP

5.17 The representations received as part of the Regulation 19 consultation in June and July 2013 relate to a number of specific matters, including the fact that planning applications were under consideration for the development of the two sites that make up Land at North Hailsham. In addition, representations also have been received regarding site specific issues such as ecological and landscape matters, land which has been omitted, the percentage of affordable housing provision and the requirement for sewerage connections.

5.18 At the time of compiling the Background Paper on the Development of the PSSSLP including pre-submission modifications, Site HHD had been granted planning consent and the Council's Planning Committee South had resolved to grant permission on Site HHE, subject to Section 106. The proposed changes in the policy reflect these consents; including the additional parcel of land to the northwest of site HHD (around 2.27ha) being included in the allocated area for Site HHD. This additional land area allows for landscape mitigation to prevent the perception of visual coalescence with Hellingly Village. Consideration has been given to all the representations received and modifications have 28 been proposed regarding open space provision, to clarify requirements, as well as other Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

requirements including sewerage infrastructure provision. These policy considerations will be relevant at the detailed application stage and during the consideration of any reserved matters applications.

5.19 The final viability assessment of the Strategic Sites was completed by the Council's appointed consultants in November 2013. The study shows that minor modifications were required to policies in the PSSSLP and supporting text to enhance viability and the changes have been derived to ensure compliance with the NPPF whilst ensuring viability. At Land at North Hailsham, the proposed changes relate to an increase in density from 27dph to 30dph and a proposed change in the affordable housing provision from 40% to 35%.

5.20 Representations were also received in relation to land omitted to the north of modified site HHD, at Sussex Plants Nursery. The omission of this site was reconsidered, but the considerations outlined above in this document are still relevant and the site has also been part of the Sustainability Appraisal process and therefore has already been considered as a potentially reasonable alternative.

5.21 Further consideration has been given to the request arising from Joint Planning Committee North and South (October 2013) to strengthen the wording regarding the

distribution of uses between the sites that make up North Hailsham. The policy has been 5 Land at North Hailsham changed to reflect the request. Further amendments have been made to rectify typographical errors also raised.

Summary for Land at North Hailsham

Overall available land area across the two sites: 43.54 hectares (as modified)

Site HHD: 16.55 hectares (as modified)

Site HHE: 26.99 hectares

Land requirements across the two sites

Housing land at 30dph: 23.33 hectares (HHD = 8.8ha and HHE = 17.03 ha)

Employment area: 2.45 hectares

Education area: 2 hectares

Retail: 0.07 hectares

Public open space: 5.06 hectares

Total land requirement: 32.91 hectares

Land remaining: 10.63 hectares

29 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) Land at North Hailsham 5 Land at North Summary

5.22 The increase in density from 27dph to 30dph reduces the land take required to accommodate the housing from 25.92ha to 23.33ha. Therefore, the total land requirement has reduced from 35.44ha to 32.91ha, leaving a remaining land area of 10.63ha (an increase of 4.8ha which also includes the additional landscape mitigation area).

Constraints commentary

5.23 There are areas of ancient woodland on or adjacent to both sites and a buffer of 15m would be required between this woodland and new development. In addition, there is existing green infrastructure in the form of mature hedge and tree lined boundaries and a network of footpaths crossing both sites that would need to be incorporated into the design of new development. The remaining 10.63ha would provide flexibility for the design of development to address these constraints and the requirement for green infrastructure to ensure a net gain in biodiversity on the site can be achieved.

30 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

6 Land at South Polegate and East Willingdon

6.1 The comprehensive SHLAA undertaken by the Council in 2008-2009 identified that land was suitable, available and achievable to the south of Polegate and East of Willingdon. This land subsequently formed part of the broad area of search for new strategic development to serve Polegate and Willingdon as identified in the adopted CSLP.

6.2 At I & O stage, the opportunities and constraints of developing the land at South Polegate and East Willingdon were identified and these are summarised below:

Opportunities

Housing development – the size of the site provides opportunity to diversify the range and tenure of dwellings and address housing need, whilst having the scope to provide a distinctive layout which promotes a sense of place, feels secure, and addresses climate change. Employment and community facilities – the size of the site provides opportunity to provide a range of employment and community facilities to serve new and existing residents, and also reducing the need to travel. Green infrastructure – opportunity to provide additional open space, leisure and recreation facilities as part of green infrastructure of the site. Open Space – opportunities to provide open space and recreational provision to cater for the increased population. SUDS – opportunities to incorporate a range of SUDS within site layout. Biodiversity – the site is adjacent to the Eastbourne Levels Biodiversity Opportunity area and careful layout and landscaping of development as part of the green infrastructure provision will improve the biodiversity and ecological value of the site. There are several habitats of ecological value within the site that can be retained, protected, enhanced, managed or restored as appropriate. Connectivity – opportunities to improve connectivity through the enhancement of existing and provision of new walking and cycling networks within the site and linkages to existing facilities in the area. Addressing climate change – this can be achieved through the design and layout of

the development; landscaping and green infrastructure; and inclusion of renewable Willingdon and East 6 Land at South Polegate energy generation, subject to visual impact on the South Downs National Park.

Constraints

Flood Risk – parts of the site are within Flood Zones 2 and 3 and these areas will require a 50m buffer zone to any development. Biodiversity and trees – the site is within 2km of the Pevensey Levels Ramsar Site and SSSI and development will have to be considered in relation to potential impacts on biodiversity within the Levels. Existing habitats of ecological value on the site will require retention, protection, enhancement, management and/or restoration and will need to be incorporated into a sensitive layout of development. Possible contamination – there are four localised possible contamination points which will require further investigation. 31 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 6 Land at South Polegate and East Willingdon Access – current points of vehicular access to the site are inappropriate for the proposed development and new access will be required, together with adequate footpaths and crossing facilities. Noise – the southwest boundary of the site with the A2270 Eastbourne Road is impacted by road noise and this aspect will need careful consideration in any layout design for development. In addition, there is some noise from the railway on the northern boundary and potential mitigation measures may be required. Infrastructure on site – there exist overhead power lines and a large electrical sub-station on the site, as well as a gas mains housing. Railway crossing point – there is a self-controlled pedestrian gate to facilitate crossing over the railway along the route of the Long Distance 1066 Way public footpath. The issue of safety and increased use of this crossing through development of the site will need to be addressed. Loss of agricultural land – development will involve the loss of agricultural land. Open Space provision – there is an overall deficit of formal and informal open space provision in the area and development of the site may address some of the current deficiencies.,Provision of public open space will however be a constraint on the layout options for development of the site. Site of Archaeological Importance (SAI) – the site is designated as an SAI and any development of the site will be subject to the carrying out of a programme of archaeological assessment and any resultant evaluation works. Drainage/Water Framework Directive – a number of drainage ditches currently existing on site which drain into the Willingdon Levels, which are part of the Cuckmere and Pevensey Levels catchment area. Mitigation measures will be required through the use of SUDS to ensure that water quality standards as required by the Water Framework Directive for the South East are achieved.

6.3 The consideration of the opportunities and constraints informed the guiding principles for development of the SDA at South Polegate and East Willingdon and these were comprehensively consulted upon within the Issues and Options exercise.

PSSSLP Policy and Site Area for Land at South Polegate and East Willingdon

6.4 The site area identified in the PSSSLP for the strategic site at South Polegate and East Willingdon and the accompanying policies have been informed by the consultation process and the constraints and opportunities identified.

Site Area

6.5 Through the SHLAA process a substantial area of land was submitted by various landowners covering the whole, presently largely undeveloped, area bounded by Eastbourne Road to the southwest, the Seven Sisters Estate to the southeast, the railway line to the northeast and the existing edge of Polegate to the northwest. Around half this land area, closest to the existing urban edge of Polegate, was included for consideration for options for development at I&O stage.

32 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

6.6 As a result of detailed consideration of the opportunities and constraints of development within the wider area of search, together with consultation responses received during the I&O process, land within the northern and western part of the SDA has been included within the proposed site allocation boundary to deliver the 700 dwellings, education, employment and other community facilities. This is identified as Site PW1 (see Appendix 4 for map).

6.7 The strategic site as shown in the PSSSLP provides a focus for development towards the western side of the site, in order to ensure that new development is concentrated in close proximity to the existing facilities in Polegate and also ensures the most effective and efficient use of previously developed land in the area. In addition, Natural England highlighted at an early stage the preference for development of land closest to the existing urban edge of Polegate, as this would represent the least damaging effect on land with potential for biodiversity.

6.8 Natural England also highlighted the potential for development of the strategic site to have an adverse visual impact on the South Downs National Park (SDNP). Consequently, policies in the PSSSLP clearly require built form to be concentrated in the western part of the site, closest to the existing urban edge of Polegate, thereby allowing the opportunity to create a softer edge to the eastern boundary of the site, with open space provision predominantly accommodated in this part of the site. The eastern boundary has been drawn in a staggered line to follow existing field boundaries. Although these boundaries are presently marked predominantly by relatively week hedgerow features, these offer potential for retention and reinforcement to help create a soft natural edge to the strategic site as part of the wider green infrastructure of the area.

6.9 The policies also ensure that an appropriate green frontage on to Eastbourne Road can be retained to respect the existing character of the area, and to provide containment to the hard built edge of new development in views from the adjacent road and from the SDNP.

6.10 In summary, the site area selected is restricted to land required for the efficient and effective delivery of the allocation, and should ensure that the development would not have an adverse landscape visual impact by allowing reinforcement and enhancement

of the green infrastructure across the site, which would also help to ensure that a net gain Willingdon and East 6 Land at South Polegate in biodiversity can be achieved on the site.

Land to the south east of the proposed Strategic Site

6.11 The SAR comprehensively considers the alternative of developing on land to the south east of the chosen strategic site. This land was submitted within the SHLAA and, subsequently, the site has been promoted as an extension to the strategic site. Submissions included an indicative layout which proposes residential development in two areas – within the north and west of the SDA, and within the south and eastern corners of the adjoining land. This layout retains a substantial landscaped area to the centre of the combined site. Vehicular access is proposed off a single point on Eastbourne Road, with long internal feeder roads to the land in the southeast. Employment land is proposed 33 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 6 Land at South Polegate and East Willingdon adjacent to Eastbourne Road. Pedestrian and cycle access is proposed to the Seven Sisters Estate to the south.

6.12 The indicative layout demonstrates that development would lie within areas at risk of flooding in the proposed additional land area and also does not account for appropriate buffer zones for climate change and biodiversity to flood risk areas, or water courses and marshy areas. The single point of access on to Eastbourne Road presents a convoluted series of feeder roads throughout the wider option for development which is likely to have an impact on the biodiversity of the site. Highways advice confirms that vehicular access on to the Seven Sisters Estate could not be satisfactorily accommodated. The development of this area is likely to lead to the perception of an isolated area of housing, integrated neither with existing housing to the south or new development to the north.

6.13 There are few opportunities to increase accessibility to the south-eastern land, no public footpaths cross this area and it is distanced from Eastbourne Road and the associated public transport route, including that to Polegate Railway Station. In addition, the development in the south-eastern element is unlikely to help to regenerate Polegate Town Centre due to the lack of connectivity between the additional land and the north / west.

6.14 The retention of a large part of the central area of the combined sites would enable a substantial landscaped area to be retained, which could accommodate public open space, community and education facilities. However, the amount of development on the Eastbourne Road frontage would not help to reduce the perceived reduction in the ‘open’ aspect of this area.

Density and Housing Numbers

6.15 The proposed strategic site area comprises around 43.83ha, and this land is identified to deliver the housing allocation of 700 dwellings at a density of 27dph, or 121 habitable rooms per hectare, across the site identified in the PSSSLP as Site PWA. This density should ensure that the rural edge character of the area can be reflected, that the land can be used efficiently and effectively, but also that appropriate and sensitive green infrastructure can be incorporated within the development, along with public open space, and that the visual impact of developed can be contained and mitigated as much as possible.

6.16 The housing numbers proposed for the strategic site have been restricted by the capacity of the WWTW to accommodate new development, in combination with other allocated housing in the Core Strategy, without further detriment to water quality on the Pevensey Levels.

Other Uses

6.17 The proposed strategic site allocation also includes the requirement for land for education facilities comprising around 2ha in size (as advised by ESCC as Education Authority) and employment land for the provision of 8,600m² net floor space of around 34 2.43ha. This latter area is based on a plot size greater than that shown in the ELR and Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

is based on a recent stand alone scheme in the District to provide modern standard employment facilities.

Pre-submission modifications to the PSSSLP

6.18 The representations received as part of the Regulation 19 consultation in June and July 2013 relate to a number of specific matters. Landowners within the SDA identified within the CSLP have submitted a number of representations regarding site specific issues which relate to building in flexibility to the policies including the allocation itself, increasing density and taking into account phasing of development.The polices have been reviewed, and modifications have been proposed to ensure there is flexibility whilst providing the necessary certainty. In addition, the biodiversity issues raised by other parties have been considered and alterations made as appropriate.

6.19 The infrastructure requirements, which have been questioned by other parties, are based upon work with the Council's partners and no further changes have been proposed to these strategic requirements. It is understood that concern has been raised about the Parish/ Town in which infrastructure is located. Although the practical issues are understood, these can be considered in the detailed design and layout of the development at planning application stage.

6.20 An omission site was also included as part of the representations procedure, which relates to land to the south east of the allocated site, as outlined above. The issues relating to this site have already been addressed in this document and through the Sustainability Appraisal of the PSSSLP. It is not considered there is any need to change the allocation proposed in the PSSSLP.

6.21 The final viability assessment of the Strategic Sites was completed by the Council's appointed consultants in November 2013. The study shows that minor modifications were required to policies in the PSSSLP and supporting text to enhance viability and the changes have been derived to ensure compliance with the NPPF whilst ensuring viability. At Land at South Polegate and East Willingdon, the proposed change relates only to an increase in density from 27dph to 30dph. Land at South Polegate and East Willingdon and East 6 Land at South Polegate

35 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 6 Land at South Polegate and East Willingdon Summary for Land at South Polegate and East Willingdon

Overall available land area across the site: 43.83 hectares

Land requirements across the site

Housing land at 30dph: 23.33 hectares

Employment area: 2.43 hectares

Education area: 2 hectares

Community facilities: 0.5 hectares

Public open space: 5.3 hectares

Total land requirement: 33.56 hectares

Land remaining: 10.27 hectares

Summary

6.22 The increase in density from 27dph to 30dph reduces the land take required to accommodate the housing from 25.92 ha to 23.33ha. Therefore, the total land requirement has reduced from 37.15ha to 33.56ha, leaving a remaining land area of 10.27ha (an increase of 3.59ha).

Constraints Commentary

6.23 In the north western corner of the site there is an area of flood risk falling within Flood Zones 2 and 3, measuring approximately 0.35ha, within which no development can take place, other than water compatible uses and essential infrastructure. Other constraints to development identified in the policies in the PSSSLP include the requirement to provide SUDS on site, the protection and retention of areas of identified habitats, including marshy grassland, woodland and the woodland/hedgerow belt adjacent to footpath no. 5, and the protection, retention and reinstatement of watercourse corridors and wetland habitats on site, including a minimum of a 5m grassland buffer zone from development. In addition, there is existing green infrastructure in the form of mature hedge and tree lined boundaries and footpaths crossing the site that would need to be incorporated into the design of new development. Noise mitigation may be required in the form of physical works or landscaping in relation to Eastbourne Road and the railway line.The remaining 10.27ha would provide flexibility for the design of development to address these constraints and the requirement for green infrastructure including the prospect of enhanced water habitats on site to ensure a net gain in biodiversity can be achieved on the site.

36 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

7 Land at Dittons Road, Polegate

7.1 Land at Dittons Road in Polegate was identified within the Core Strategy for the purposes of providing new employment floorspace.

7.2 At the I & O stage in the development of the Strategic Sites Local Plan, the opportunities and constraints of developing the land for employment purposes at Dittons Road were identified.

Opportunities

Range and mix of uses – opportunities to provide a range and mix of small and medium sized modern B1, B2 and B8 units to address the current demand in this prominent location adjacent to Dittons Road/A22/Golden Jubilee Way roundabout. Location – the site is in close proximity to existing Dittons and Chaucer Employment areas, the strategic road network and existing public transport provision which makes the site potentially very marketable for employment use. Opportunities to enhance signage and the profile of the site – although the site is currently tucked away, there are opportunities to indicate the presence of existing and new facilities in this location. Opportunities to enhance connectivity and use of other transport modes – creation of strong physical links between the site and the Cuckoo Trail to the south with appropriate signage, links to other existing footpaths and cycling routes. Open Space – there is potential for provision of some informal open space/amenity

space provision for use by employees of businesses on the site. 7 Land at Dittons Road, Polegate Green infrastructure and biodiversity – the site is within 2km of the Pevensey Levels Ramsar Site and SSSI and any development on the site will have to be considered in relation to potential impacts on biodiversity within the Pevensey Levels and options to enhance biodiversity within the area. There are opportunities for good landscaping of the site to enhance green infrastructure, and creation of appropriate links to the existing Willingdon Levels Recreational Area. In addition, provision of SUDS and measures to enhance Biodiversity Action Plan (BAP) habitats and species will help to enhance biodiversity in the area. Climate change and renewable energy – opportunities to address these issues through site layout and use of renewable energy sources, however visual impact on the SDNP will need consideration.

Constraints

Access – current access to the site is informal and from Dittons Road. Any new site layout would need to provide an appropriate access to serve the development. Loss of proposed landscape buffer – the Landscape Character Assessment and Development Option evaluation study of February 2009 advocated that this land could be used as a landscape buffer zone to provide a ‘gap’ in association with potential development sites in the Polegate, Willingdon and Stone Cross areas. However as there are already buildings in this area, namely the Dittons Farmhouse 37 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 7 Land at Dittons Road, Polegate and Employment Area buildings, this site is not considered part of a ‘gap’ in the way in which other sites identified in the Study are. Drainage and Water Framework Directive – the site is within 1km of the Willingdon Levels and Langney Sewer, which form part of the Cuckmere and Pevensey Levels catchment area, and mitigation measures may be required to achieve appropriate water quality standards through the use of SUDS within the green infrastructure network for the site.

7.3 The consideration of the opportunities and constraints informed the guiding principles for development of the SDA at Dittons Road and these were comprehensively consulted upon within the Issues and Options exercise.

PSSSLP Policy and Site Area for Land at Dittons Road, Polegate

7.4 The proposed site allocation boundary of the strategic site at Dittons Road and the accompanying policies have been informed by the consultation process and the constraints and opportunities identified. The proposed strategic site is formed of two parcels of land identified as PWB and PWC (see map at Appendix 5).

7.5 Site PWB is immediately adjacent to the existing Chaucer Industrial Estate and Dittons Business Park and its development would create a natural extension to the existing commercial uses in the area. The site boundaries are physically constrained to the north by Dittons Road, to the west by the Chaucer Industrial Estate, to the south by the Cuckoo Trail and to the east by the boundary of Site PWC and the Dittons Business Park. Appropriate vehicular access could be gained either via the adjacent Chaucer Industrial Estate or via Dittons Road to the north, subject to investigation into any highways constraints and/or requirements. However, access from Dittons Road could lead to a conflict with the existing access to Dittons Farm Business Park to the east and the residential development north of Dittons Road.

7.6 Site PWC lies to the immediate south east of Site PWB and would form a natural further extension to business use in the area. Access would be required from Site PWB in to Site PWC, therefore, development of site PWB in isolation must be required not to prejudice future access to Site PWC.

7.7 There is potential to enhance the green infrastructure on the site boundaries, particularly those adjacent to the Cuckoo Trail to the south, which would also help to mitigate any visual impact of new development on the Willingdon Levels Recreation Area. Green infrastructure can also be provided in the form of SUDS to serve the new development and together, this will help to ensure a net gain in biodiversity can be achieved on the site.

38 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Summary for Land at Dittons Road

Overall available land area: 3.1ha hectares split between the two sites

PWB: 2.39 hectares

PWC: 0.71 hectares

Land requirements across the sites

Employment land: 2.35 hectares

Total land requirement: 2.35 hectares

Land remaining: 0.75 hectares

Constraints commentary

7.8 Constraints to development include the requirement for SUDS, appropriate access from either Dittons Road or the Chaucer Industrial Estate and the provision of footpath/cycle links to the Cuckoo Trail to the south. In addition, development of the site must take into account views from the SDNP. Therefore, the remaining 0.75ha would ensure some flexibility in the design and layout of development to account for the identified constraints and the requirement for green infrastructure, including protecting, retaining and where appropriate, buffering, enhancing, restoring and strengthening existing wildlife corridors and habitats of biodiversity value, to ensure a net gain in biodiversity can be achieved on 7 Land at Dittons Road, Polegate the site.

39 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 7 Land at Dittons Road, Polegate

40 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

8 Land at Stone Cross

8.1 The comprehensive SHLAA undertaken by the Council in 2008-2009 identified that land was suitable, available and achievable to the north and east of Stone Cross. This land subsequently formed part of two broad areas of search for strategic development to serve Stone Cross, to the north and to the east, as identified in the adopted Core Strategy.

8.2 At I & O stage, the opportunities and constraints of developing the land at Stone Cross were identified on a site by site basis and are summarised below. The individual site references are those used in the I & O Paper and differ to those in the PSSSLP (see map at Appendix 6).

8.3 Site A – Land at Friday Street

Opportunities

Vehicular, pedestrian and cycle access – provision of a vehicular access into the site from Penrith Way and Pennine Way. Potential also exists to increase connectivity 8 Land at Stone Cross from the site to the existing routes providing pedestrian/cycle access to local services and facilities at Stone Cross and Langney Shopping Centre, including incorporation within the design of development of the existing Public Right of Way that runs from Oak Tree Lane across existing open countryside to Westham. Creating open space/green infrastructure provision – there are opportunities to provide additional play space, amenity space and recreation space and to increase the level and quality of publicly accessible open space through the provision of green infrastructure and improvement of connectivity through the provision and improvement of physical linkages to the wider area. Opportunities to address climate change issues and include renewable energy – through design of development and inclusion of renewable energy generation and use of SUDS. Enhance biodiversity value of the site – there are opportunities through the design and layout of the development and through the incorporation of SUDS, together with the retention of boundary hedges, trees and enhancement of planting with native species within the site to increase the biodiversity value.

Removal of utilitarian agricultural buildings/Previously Developed Land - opportunities exist through the development of the site to remove/replace the existing prominent agricultural buildings located on the ridgeline which are clearly visible within the local area.

Constraints

Vehicular access - whilst potential exists to physically provide a new vehicular access onto Penrith Way and Pennine Way, transport modelling would be required to determine the scale of development that would be acceptable from a highway perspective. The topography of the site may cause problems in achieving access; particularly where access needs to be taken across the contours and this may impact upon the density of development. In addition, the access will need to cross the stream 41 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross within the Flood Zone areas and whilst the Environment Agency has not raised an objection to this site being promoted for development, any proposal would need to be supported by a Flood Risk Assessment. Any culverting of water courses associated with providing access to the site may need to be mitigated in relation to the impact upon the hydrology of the surrounding Levels. Bus services, pedestrian crossings and traffic calming in the area are likely to require enhancement. Topography - this presents some challenges on this site, particularly in relation to provision of access from Pennine Way. The gradient of the site to the western part adjacent to Pennine Way is quite steep and access at this point would be at 90° to the slope. Going with the contours may be preferable but may not be possible in all options for development of the area. This constraint has been taken into account in relation to the possible land take required, in the generation of options and density considered achievable. Exposed/ prominent site within the landscape - the south western part of the site is subject to short range views from within the built up areas of Eastbourne to the south of the site. The more elevated eastern and north-eastern parts of the site are exposed to long range views within the wider landscape and towards the Pevensey Levels located some 2 kilometres to the north and north-east. Creative building design together with creative landscaping would be required to provide a satisfactory quality of development on the more prominent and exposed parts of the site.

Loss of agricultural land - The development of the site would involve the loss of agricultural land, however, given the location of the site on the edge of the built up area of Stone Cross and adjacent to the town of Eastbourne, the value of the site for agriculture has already been diminished. Potential for coalescence of the built up areas of Stone Cross and Eastbourne - concern has been expressed by Eastbourne Borough Council regarding the potential for the development of this SDA, and in particular this site closest to the Eastbourne boundary, to result in the coalescence of the built up areas of Stone Cross and Eastbourne.

8.4 Site B – South of Rattle Road, Stone Cross

Opportunities

Vehicular, pedestrian and cycle access - opportunities exist to provide vehicular access into the site from Rattle Road.There is also potential for providing an additional pedestrian point into the site from the north west via Beggars Lane, thus enhancing connectivity from the site to the existing linkages along Rattle Road, although the delivery of this option is uncertain due to the private legal status of Beggars Lane. Another potential pedestrian access, to facilitate connections to the west, would be to provide a new access to Blachington Mill Drive. Creating open space/green infrastructure provision – there are opportunities to provide additional play space, amenity space and recreational space to support the development as part of the green infrastructure provision.. 42 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Opportunities to address climate change issues and include renewable energy – renewable energy measures and use of the topography of the site and SUDS will help to assist climate change objectives.

Enhance biodiversity value of the site - opportunities exist to enhance the biodiversity and ecological value of the site, through the incorporation of SUDS, together with the retention of boundary hedges, trees and enhancement of planting with native species within the site to increase the biodiversity value.

Constraints

Vehicular access - whilst potential exists to physically provide a new vehicular access onto Rattle Road, a speed survey would be required to determine the required visibility splay. Furthermore, vehicular access to this site should not prejudice vehicular access to Site C, opposite. Provision of a footway and pedestrian crossing would be required along Rattle Road to improve pedestrian accessibility and linkages with the existing footway network into Stone Cross. Enhancement of bus stops would also be required. 8 Land at Stone Cross Prominent site within the landscape - the prominence of this largely sloping site on the fringe of Stone Cross makes it essential that the layout of the built development is carefully planned to incorporate structural landscaping to help to redefine the edge of the settlement, when viewed from the Pevensey Levels and the Mountney Levels. The framing of the site by the adjacent countryside to the south east and existing belt of mature trees/hedgerow along the southern boundary of the site would assist in the creation of a definitive edge to this part of the settlement. Loss of agricultural land - the development of the site will involve the loss of agricultural land however, given the location of the site on the edge of the built up area of Stone Cross, the value of the site for agriculture has already been diminished. Impact of development upon the setting of Stone Cross Windmill (Listed Building) - given the proximity of Stone Cross Windmill to the site, careful design and layout of the future development of the site will be required to ensure that the intrinsic architectural interest of the Listed Building and its setting are safeguarded.

8.5 Site C – Land North of Rattle Road

Opportunities

Vehicular, pedestrian and cycle access - opportunities exist to provide vehicular access into the site from Rattle Road and to enhance accessibility to the existing public footway which skirts the western boundary of this site. This could provide pedestrian and cycle access and link to an existing pedestrian link (Peelings Lane) and provide an alternative pedestrian access to the amenities and facilities within Stone Cross. Topography and setting in the landscape - the topography of the site provides opportunities to consider a range of density and scale throughout the development. The northern part of the site presents an opportunity to create a definitive edge to

43 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross the edge of Stone Cross through landscaping along the northern and north-eastern parts of the site. Creating open space/green infrastructure provision - the site provides opportunities to provide additional play space, amenity space and recreation space to support the development as part of the Green Infrastructure provision and by improvement of physical linkages to the wider area, the accessibility to recreation and open space facilities could also be improved.

Opportunities to address climate change issues and include renewable energy - opportunities exist for renewable energy generation and SUDS to be incorporated into the design of the development.

Enhance biodiversity value of the site - opportunities exist through the incorporation within the design and layout of the development to enhance biodiversity and ecological value of the site, through the incorporation of SUDS options together with the retention of boundary hedges, trees and enhancement of planting with native species within the site to increase the biodiversity value.

Constraints

Vehicular access - Whilst potential exists to physically provide a new vehicular access onto Rattle Road, traffic and speed surveys would be required to determine the required visibility splay. Furthermore, vehicular access to this site should not prejudice any future vehicular access to the opposite site (Site B). The enhancement of bus stops would also be required. Loss of agricultural land - the development of the site will involve the loss of agricultural land, however, given the location of the site on the edge of the built up area of Stone Cross, the value of the site for agriculture has already been diminished. Potentially contaminated land - uncertainty exists regarding the extent to which the potentially contaminated land adjacent to the western boundary of the site would constrain the layout and design of the development of this site. Further investigation would be required to determine the extent of any contamination present on site and on land adjacent to this area and the level of mitigation that may be required.

8.6 Site D – Land to the north of Dittons Road and north of Barn Close

Opportunities

Vehicular, pedestrian and cycle access – The opportunity exists to provide a vehicular access into the site from Dittons Road and potential exists to increase connectivity from the site to the surrounding area; including provision of pedestrian/cycle linkages from the south-east part of the site into Barn Close and St. Michaels Close. In addition, if Site G - Dittons Nursery - is developed, there may be opportunities to provide a pedestrian/cycle link into the adjacent site to the west.

44 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Creating open space/green infrastructure provision - the site provides the opportunity for open space and recreational space to support the development as part of the Green Infrastructure provision for the area. Opportunities to address climate change issues and include renewable energy - there are opportunities to develop renewable energy sources and SUDS within the development, thereby assisting in delivering climate change objectives.

Enhance biodiversity value of the site - opportunities exist through the design and layout of the development to enhance the biodiversity and ecological value of the site. The incorporation of SUDS options together with the retention of hedgerow features, and enhancement of planting within the site with native species, as part of the provision of Green Infrastructure, can help to create biodiversity corridors linking the existing woodland to the east and west of the site.

Constraints

Proximity of A27 trunk road - the noise emanating from the A27 trunk road, which 8 Land at Stone Cross skirts the northern boundary of the site represents a constraint to development and noise mitigation measures would be required within the layout/design of the development. Location of Ultra High Pressure Gas Mains - an Ultra High Pressure Gas Main (UHPG) runs through the north east corner of the site and will require protection through the design and layout of the development with a buffer of 9 metres either side of the gas main from built development. Loss of agricultural land - the development of the site will involve the loss of agricultural land, however, given the location of the site within Stone Cross, between the A27 trunk road and Dittons Road, the value of the site for agriculture has already been diminished. Ancient Woodland - the existence of ancient woodland to the west of the site will require a 15 metre buffer from the built form of any proposed development on the site. Vehicular access - whilst potential exists to physically provide a new vehicular access onto Dittons Road, a Traffic Survey would be required to establish the required visibility splays. Furthermore, bus stops and footways in the vicinity of the site may require upgrading.

8.7 Site E – Land off Hailsham Road and Peelings Lane

8.8 The opportunity and constraints exercise highlighted that there are serious constraints in relation to providing adequate accessibility to the site from Hailsham Road. In addition, the combination of providing adequate noise attenuation and buffering to the Ancient Woodland reduces the land available for development at the western end of the site, producing a scenario where a long access road would be provided to serve a development to the flatter and wider eastern end of the site. However, housing in this location would be rather remote from the main centre and would be exposed to views from the Pevensey Levels. 45 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross 8.9 Although the western end of the site could become part of the Green Infrastructure provision on site, it would be some distance away from the new development and may possibly still be impacted by noise from the A27.

8.10 These aspects severely compromise the deliverability of the site. Given that other deliverable sites are available which in combination can deliver the quantum of development allocated for Stone Cross, it was decided at Issues and Options stage that Site E would not be considered further in the generation of Options for development.

8.11 Site F – Land south of Dittons Road adjacent to Golden Jubilee Way

Opportunities

Vehicular, pedestrian and cycle access - The opportunity exists to provide a vehicular access into the site from Dittons Road and to increase connectivity from the site via the existing public footpath,providing pedestrian/cycle access to the services and facilities at Stone Cross. Creating open space/Green Infrastructure provision-the site provides the opportunity for provision of additional open space and recreation space to support the development as part of the Green Infrastructure provision. Opportunities to address climate change issues and include renewable energy - opportunities for energy generation to be incorporated into the design of dwellings and SUDS within the layout of development to assist in delivering climate change objectives.

Enhance biodiversity value of the site - opportunities exist to enhance the biodiversity and ecological value of the site, through the incorporation of SUDS and retention of the central hedgerow/tree boundary, together with the enhancement of planting within the site with native species, which would enhance the biodiversity of the area through creating green corridors linking in with the surrounding woodland/hedgerows.

Constraints

Vehicular access - whilst potential exists to physically provide a new vehicular access onto Dittons Road, transport modelling would be required at both roundabouts to the west of the site. Furthermore, bus, cycle and pedestrian infrastructure provision or improvements would be required. Potentially Contaminated Land - investigative surveys will be required to establish whether contamination exists within the south-eastern part of the site and to determine the level of any mitigation measures that may be required. Proximity of A27 trunk road and electricity sub-station - noise emanating from the adjacent A22 trunk road, which skirts the western boundary of the site, may represent a constraint to the development within the western part of the site. Furthermore, a level of noise emanates from the electricity sub-station, located to the north-east of the site. Noise surveys for both aspects are recommended to assess appropriate mitigation measures to be incorporated within the layout/design of the development. 46 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Proximity of the road could also mean a lessening of the attractiveness of a residential environment Loss of agricultural land - the development of the site will involve the loss of agricultural land, however, given the location of the site on the edge of the built up area of Stone Cross and adjacent to the A22 trunk road, the value of the site for agriculture has already been diminished.

8.12 Site G – Dittons Nursery

Opportunities

Previously Developed Land - opportunities exist to redevelop the existing part of the site currently occupied with Garden Centre buildings and structures, thereby making the best use of previously developed parts of the site. Vehicular, pedestrian and cycle access - opportunity exists to utilize and upgrade the existing vehicular access into the site from Dittons Road and to incorporate the existing public footpath that runs through the site into the layout and design of the 8 Land at Stone Cross development to increase connectivity from the site to the services and facilities at Stone Cross. Furthermore, potential exists to provide a pedestrian/cycle link into the adjacent Site D. Creating open space/green infrastructure provision - the site provides the opportunity for provision of additional open space and recreational space to support the development as part of the green infrastructure provision. Opportunities to address climate change issues and include renewable energy - opportunities exist to incorporate renewable energy generation in the design of dwellings and SUDS within the layout of development, thereby assisting in the delivery of climate change objectives. Enhance biodiversity value of the site -opportunities exist through the design and layout of the development to enhance biodiversity and ecological value of the site, through the incorporation of SUDS and the retention of boundary hedges and significant trees, together with the enhancement of planting within the site to enhance the biodiversity of the area through creating green corridors linking in with the woodland to the east and south-east of the site.

Constraints

Vehicular access -whilst potential exists to physically provide a new vehicular access onto Dittons Road, transport modelling would be required at both roundabouts to the west of the site to assess access requirements. Furthermore, bus, cycle and pedestrian infrastructure provision or improvements would also be required. Potentially Contaminated Land - investigative surveys will be required to establish whether contamination exists within the south-eastern part of the site (from the existing nursery use) and to define any mitigation measures required, which may impact upon the land available for development. Proximity of A27 and A22 trunk roads - noise emanating from the adjacent A22 and A27 trunk roads, which skirts the western and northern boundaries of the site represent a constraint to the development of the site. Detailed noise surveys are recommended 47 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross to assess the most appropriate noise mitigation measures for the visually sensitive site. Notwithstanding this, it is considered that appropriate noise mitigation measures could be incorporated within the layout/design of the development. Proximity of road could also mean a lessening of the attraction of the site as a residential environment . Exposed/prominent site within the landscape - the western and northern parts of the site are exposed to short range views from the adjacent A27 and A22 trunk roads. Creative building design together with creative landscaping would be required to provide a satisfactory quality of development on this prominent and exposed site. Loss of agricultural land - the development of the site will involve the loss of agricultural land, however, given the location of the site on the edge of the built up area of Stone Cross and adjacent to the A22 trunk road, the value of the site for agriculture has already been diminished. Loss of employment land - the development of the site would involve the loss of existing employment land, currently provided through the garden centre/ nursery and golf training facilities. Buffer to ancient woodland - Provision of an appropriate buffer (around 15 metres) between new development and the existing Ancient Woodland would be required. This would impact upon the potential land available and the layout of the development.

8.13 The consideration of the opportunities and constraints informed the guiding principles for development of the SDAs at Stone Cross and these were comprehensively consulted upon within the I & O exercise.

PSSSLP Policy and Site Area for Land at Stone Cross

8.14 The site allocation boundary of the proposed strategic site at Stone Cross and the accompanying policies have been informed by the consultation process and the constraints and opportunities identified. Subsequent to the I & O process additional land to the east of Stone Cross was submitted via the SHLAA process. In addition, previously submitted land in this area was reconsidered as a result of further work on potential options for development. The opportunities and constraints for development of this additional land are outlined below and have been subject to sustainability appraisal in the SAR which forms part of the evidence base for the PSSSLP.

Additional alternative land considered and incorporated into the proposed strategic site in the PSSSLP

Land to the north of Site C – Opportunities and Constraints

8.15 Whilst this site relates well to other potential sites identified and could help to deliver the 650 homes proposed for the Stone Cross area within SDA6 and SDA7, it would be reliant on the allocation of Site C to the south for access on to Rattle Road. There is potential to enhance pedestrian and cycle linkages throughout the area with existing facilities (including employment, public transport and community uses) in Stone Cross, Westham, Polegate and Eastbourne. This site, along with other sites identified within the 48 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

SDAs could help to regenerate Stone Cross and support existing facilities as well as providing new community facilities.

8.16 There is a substantial network of existing hedgerows and mature trees worthy of retention along field boundaries, and along the roadside boundary with Peelings Lane which are of biodiversity and ecological interest, and as much as possible of this existing green network would need to be retained and enhanced. This would help to maximise the biodiversity potential on site and to retain and enhance green wildlife corridors. Of particular note is the route of the stream on the southern boundary.The provision of SUDS and buffers to the existing water course will be required to enhance biodiversity on the site.

8.17 Good design of development, both built form and hard and soft landscaping, would help to reduce the impact of future development on the surrounding landscape and the existing built environment.

8.18 There is a public footpath on the western boundary of the site and this would provide opportunities to optimise possibilities for incorporating new links to this existing 8 Land at Stone Cross route within the layout of the new development. In doing so this could increase accessibility and connectivity to the wider footpath / cycle way network, including the Cuckoo Trail to the east and therefore the north and south of the district, to the wider Polegate and Stone Cross area and to Westham and Eastbourne.

8.19 Provision of strong landscape structure and boundaries, with the provision of landscape buffers between the roads and residential areas and the provision of multi-functional green infrastructure networks, to link with existing and to enhance the existing landscape, would help to soften the impact of development on this part of Stone Cross.

Land to the East of Site C, Land at Rattle Garden Farm – Opportunities and Constraints

8.20 This site relates well to other potential sites identified to the west and could help to deliver the 650 homes proposed for the Stone Cross area within strategic sites SDA6 and SDA7, but would be reliant on the allocation of Site C to the south for access on to Rattle Road. There is potential to enhance pedestrian and cycle linkages throughout the area with existing facilities (including employment, public transport and community uses) in Stone Cross, Westham, Polegate and Eastbourne. This site, along with other sites identified within the SDAs, could help to regenerate Stone Cross and support existing facilities as well as providing new community facilities.

8.21 There is a substantial network of existing hedgerows and mature trees worthy of retention along field boundaries, and along the roadside boundary with Peelings Lane which are of biodiversity and ecological interest and as much as possible of this existing green network would need to be retained and enhanced. This would help to maximise the biodiversity potential on site and to retain and enhance green wildlife corridors. Of particular note is the route of the stream on the northwest boundary. The provision of SUDS and buffers to the existing water course and the area of flood risk in the northeast corner of the site would be required to enhance biodiversity on the site. 49 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross 8.22 Good design of development, both built form and hard and soft landscaping, would help to reduce the impact of future development on the surrounding landscape and the existing built environment.

8.23 Linking this site with other potential sites to the west, including Site C, would provide opportunities to optimise possibilities of incorporating new links to existing public rights of way in the area in the layout of new development and, consequently, to increase accessibility and connectivity to the wider footpath / cycle way network, including the Cuckoo Trail to the east and therefore the north and south of the district, to the wider Polegate and Stone Cross area and to Westham and Eastbourne.

8.24 Provision of strong landscape structures and boundaries, together with the provision of landscape buffers between the roads and residential areas and the provision of multi-functional green infrastructure networks to link with existing and to enhance the existing landscape, would help to soften the impact of development on this part of Stone Cross.

Land at Uplands Farm – Opportunities and Constraints

8.25 This site relates well to other potential sites identified to the west and could help to deliver the 650 homes proposed for the Stone Cross area within strategic sites SDA6 and SDA7, but would be reliant on the allocation of Site B to the west for the connectivity of built form with the existing urban edge of the settlement. There is potential to enhance pedestrian and cycle linkages throughout the area with existing facilities (including employment, public transport and community uses) in Stone Cross, Westham, Polegate and Eastbourne. This site along with other sites identified within the SDAs could help to regenerate Stone Cross and support existing facilities as well as providing new community facilities.

8.26 There is a substantial network of existing hedgerows and mature trees worthy of retention along field boundaries, and along the boundary with the railway to the south which are of biodiversity and ecological interest and as much as possible of this existing green network would need to be retained and enhanced. This would help to maximise the biodiversity potential on site and to retain and enhance green wildlife corridors. The provision of SUDS and buffers to the flood risk area in the south eastern corner of the site would be required to enhance biodiversity on the site.

8.27 Good design of development, both built form and hard and soft landscaping, would help to reduce the impact of future development on the surrounding landscape and the existing built environment.

8.28 Linking this site with Site B to the west would provide opportunities to optimise possibilities of incorporating new links to existing public rights of way in the area in the layout of new development and to increase accessibility and connectivity to the wider footpath / cycle way network.

50 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

8.29 Provision of strong landscape structures and boundaries, together with the provision of landscape buffers between the roads and residential areas and the provision of multi-functional green infrastructure networks to link with existing and to enhance the existing landscape, would help to soften the impact of development on this part of Stone Cross and within the more sensitive landscape views across the Mountney Levels to the south.

Site Area

8.30 The total site area of the proposed strategic site at Stone Cross is 30.12ha and this is identified to deliver 612 of the 650 dwellings allocated in the Core Strategy. Planning permission has already been granted for 38 dwellings at land at Friday Street, part of Site A in the I & O Paper.

8.31 The remaining 612 dwellings have been allocated across 7 sites, identified in the PSSSLP as sites SCA, SCB, SCC, SCD, SCE, SCF and SCG (see map at Appendix 6).

8.32 Planning permission was granted on appeal earlier in 2013 for 120 units on Site 8 Land at Stone Cross SCE and this is discussed further below.

Site SCA (formerly site G in the I&O Paper)

8.33 Site SCA is well located in relation to the centre of Stone Cross and currently accommodates Dittons Nursery. It is constrained by the topography which slopes down from Dittons Road to the north, however, an artificial plateau has been created across part of the site behind a bank to the road, on which the garden centre and associated car parking is presently located. The site is constrained by road noise from Dittons Road to the south and the A27 to the north, as well as road noise from the roundabout junction of the main roads further to the west. In addition, there is ancient woodland surrounding a pond in the southeast part of the site as well as a larger area of ancient woodland that divides Sites SCA and SCB. At least a 15m buffer zone would be required for all development from the two areas of ancient woodland towards the eastern end of the site.

8.34 An additional constraint to development on Site SCA is the requirement to retain the employment use. It is most appropriate to provide residential development at the eastern end of the site, closest to Stone Cross village and furthest away from the road junction. Part of this area already accommodates the garden centre. Therefore, a requirement of the proposed Policy SSC1 is the relocation of the garden centre towards the western end of the strategic site to ensure that employment use is retained. The garden centre would also provide a buffer to noise and disturbance from the roundabout junction further to the west. The remaining site to the east is considered appropriate for 40 dwellings and this takes into account the topography, shared access with the garden centre, the need to provide at least a 15m buffer to the areas of ancient woodland and the requirement for physical acoustic mitigation for road noise from the A27 and Dittons Road. In addition, appropriate green infrastructure to create new wildlife corridor links with the ancient woodland would be required on site to ensure a net gain in biodiversity and the route of the public footpath would need to be appropriately accommodated within the design of development. Appropriate physical acoustic mitigation along the roadside 51 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross with the A27 would also help to reduce the perception of proximity of new development to the busy road, both for future occupiers of properties within the development, and for road users. This stretch of the A27 is currently characterised by either hedged boundaries with open fields beyond, or by steep embankment sides, with few available views of the urban area to the south. It is considered important to retain this character.

Site SCB (formerly site D in the I&O Paper)

8.35 Site SCB was included in all options for development of the strategic site at Stone Cross, and was considered acceptable due to its sustainable location and proximity to the facilities in the centre of Stone Cross and its potential to support existing facilities. The initial stages of the PSSSLP allocated the site for around 90 dwellings and the site was also chosen to provide new community facilities for Stone Cross due to its proximity to the centre of the settlement. This requirement to provide the community facilities has now been superseded by the decision to allow the appeal on Site SCE to the east, which has incorporated land for a village hall.

8.36 Development of Site SCB is constrained by the sloping topography, the location of ancient woodland on the western boundary, and the potential for traffic noise from the A27 to the north and Dittons Road to the south. Notwithstanding the fact that the community facilities are no longer proposed on this site, it is considered that an allocation of around 90 dwellings is appropriate to achieve a good design of development, taking into account the above constraints. The community facility originally proposed could have been provided on land not appropriate for residential development and which would be more likely to have been adversely impacted upon by road noise. The restriction to around 90 dwellings was specifically set to allow appropriate physical acoustic mitigation of road noise adjacent to the A27 and Dittons Road as part of the layout of development, in addition to any mitigation within the building design of dwellings. These numbers would also ensure a buffer of at least 15m could be maintained to the ancient woodland on the western edge of the site and that appropriate and sensitive green infrastructure can be incorporated into the layout of development to ensure a net gain in biodiversity on site can be achieved. In addition, the restricted numbers of new dwellings as proposed would ensure that appropriate landscaping can be provided to the A27 on the northern boundary to prevent the perception of proximity to this main vehicular route for both future residents of the dwellings and road users. This stretch of the A27 is currently characterised by either hedged boundaries with open fields beyond, or by steep embankment sides, with few available views of the urban area to the south. It is considered important to retain this character.

8.37 One further constraint to development at Site SCB is the UHPG main which runs through part of the site. The Health and Safety Executive (HSE) are the appropriate body that set standards to ensure the safety of these facilities; setting standards to limit development within close proximity to the facility. There are two key zones of influence for the pipeline in this case for housing development, the inner zone extending to 9 metres from the centre of the pipeline where no development would be allowed and a middle consultation zone at 75 meters where development is normally allowed within certain parameters. In this case up to 10% of the development is allowed to fall within this middle 52 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

zone, or up to but not exceeding 9 dwellings. This middle zone covers around 0.86ha of the site.

Site SCC (not in the I&O consultation)

8.38 The land forming Site SCC extends to 4.2 ha and is located immediately to the north of the former site C as identified in the I&O Paper. This land is a natural extension to site C and has been deemed suitable, available and achievable through the SHLAA process. The land slopes up to the north, away from a stream on the boundary with Sites SCD and SCG to the south. It has existing strong field boundaries and links with Peelings Lane to the north, which is part of a footpath route link through to the centre of Stone Cross. In addition, an existing footpath runs along the western boundary and links with the existing housing estate to the west of the site. Development of this site would not be overly visually prominent in the wider area due to the existing green infrastructure and the existing housing estate immediately to the west. Altogether 97 dwellings are proposed on this site and this would provide opportunities to enhance green infrastructure to ensure a net gain in biodiversity. The site would be dependent on the delivery of Site SCD to 8 Land at Stone Cross the south for appropriate vehicular access and a cohesive scheme of development of Sites SCD, SCC and SCG would be preferable.

8.39 Site SCC, along with Site SCD (formerly site C in the I&O Paper) and Site SCG to the east, could together form a natural and cohesive extension to this part of Stone Cross and would link to the existing isolated sporadic development on the northern side of Rattle Road.

Site SCD (formerly site C in the I&O Paper)

8.40 This site forms a natural extension to existing residential development at the eastern side of Stone Cross and appropriate vehicular access can be achieved from Rattle Road. The topography of the site slopes down from Rattle Road towards a stream on the boundary of Site SCC and the number of units proposed reflects the requirement to address the sloping nature of the site within the design of the development. The site also has links with the existing housing estate to the west via the public footpath on the western boundary, which also links to Peelings Lane in the north, a commonly used pedestrian/cycle route to access the centre of Stone Cross. The site has good green infrastructure on the field boundaries which could be enhanced by additional planting throughout the development to ensure a net gain in biodiversity.

8.41 This site, identified as SCD, along with Site SCC to the north and Site SCG to the east, could together form a natural and cohesive extension to this part of Stone Cross and could link to the existing isolated sporadic development on the northern side of Rattle Road. Access to Sites SCC and SCG would be required via Site SCD and therefore a cohesive scheme of development across all three sites would be preferable.

53 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross Site SCE (formerly the northern part of site B in the I&O Paper)

8.42 The officer draft of the PSSSLP which was considered by the LDF Sub-Committee in February 2013 proposed around 87 dwellings at land south of Rattle Road, identified as Site SCE in the PSSSLP, and represented by the northern part of site B as identified in the I&O Paper.

8.43 However, an outline planning application with all matters reserved except for access was submitted in 2012 for Site SCE proposing 120 dwellings. Outline planning permission was refused however the decision was appealed and heard at a Public Local Inquiry in 2013, subsequent to the first consideration of the officer draft of the PSSSLP at the LDF Sub-Committee in February 2013. The outcome of the appeal was that the development of 120 homes on Site SCE was allowed.

8.44 Therefore, outline planning permission with access now exists for 120 dwellings on Site SCE; around 33 net dwellings increase on that earlier proposed in Policy SSC1. In addition, the proposals now permitted include provision of a multi-functional indoor facility however this was proposed to be provided within Site SCB within earlier drafts of the PSSSLP.

8.45 Taking into account the indicative layout submitted within the outline application, only 0.55ha of usable public open space is shown to be provided, thereby resulting in a high density of dwellings per hectare of 39.5. The quantity of on-site public open space proposed falls short of the standards used by the Council by around 0.33ha, and at detailed matters stage around 0.88ha of on site public open space would be required under those standards. Applying these standards would therefore result in a density of development of around 45dph. Accordingly, the resultant reserved matters application(s) relating to the outline planning permission are likely either to fail to provide sufficient on site amenity space to serve the needs of the development, or would create a development out of character with all other development in Stone Cross, including that allocated within the other six areas of the strategic site due to the highly dense nature of the resulting layout. It is acknowledged that a large part of Site SCE is closer to the centre of Stone Cross than Sites SCC, SCD, SCG and SCF, however, this does not mitigate the negative impact of the high density of dwellings and the resultant inappropriate character of development on this site.

8.46 The constraints to the layout of the development on this site include the retention of substantial tree lined boundaries on the south eastern and south western sides and the need to respect the setting of the Grade II* Listed Stone Cross Windmill to the east. It is also important that development of this site does not impede the amount of wind that can access the windmill to ensure that its functioning is not affected in the future.

8.47 The southern part of Site B, as identified in the I&O Paper, to the south of the sunken lane is particularly landscape sensitive in views from the south and east across the Mountney Levels. Due to the fact that other land to the east of Stone Cross has been submitted that is less landscape sensitive and is appropriate for development, it is not considered appropriate to allocate this land originally identified as the southern part of 54 site B in the I&O Paper as part of the strategic site. Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Site SCF (not in the I&O consultation)

8.48 Site SCF forms part of the western element of land submitted through the SHLAA process and relates well to Sites SCC, SCD, SCE and SCG. The site would be reliant on the delivery of Site SCE to the west for connectivity of the built form with the existing urban edge of the settlement. A larger area of land was earlier proposed for allocation, but with the granting of outline planning permission via appeal on Site SCE for a larger number of units than earlier proposed through the PSSSLP process, it was deemed appropriate to reconsider the numbers proposed at Site SCF. This should allow development to be restricted to the northern part of the site to ensure that new residential development is appropriately located, adjacent to Rattle Road and existing built form, and to achieve cohesiveness with development of Sites SCC, SCE, SCD and SCG. This should also ensure that an isolated area of development is not located within the more visually sensitive southern part of the site which is more prominent in views across the Mountney Levels. The boundary of the proposed site has now also been drawn to omit the existing storage use at Uplands Farm to ensure that no loss of commercial or

employment related use in this area is required to facilitate new residential development. 8 Land at Stone Cross

8.49 Linking this site with Site SCE to the west would provide opportunities to incorporate new links to existing Public Rights of Way in the layout of new development and also to increase accessibility and connectivity to the wider footpath / cycle way network.

8.50 There is a substantial network of existing hedgerows and mature trees worthy of retention along field boundaries, and along the boundary with the railway to the south which are of biodiversity and ecological interest. As much as possible of this existing green network would need to be retained and enhanced. This should help to maximize the biodiversity potential on site and to retain and enhance green wildlife corridors, as well as providing potential for additional planting to create a soft edge to development within the northern part of the site. The provision of SUDS and buffers to the flood risk area in the south eastern corner of the site would be required to enhance biodiversity on the site. Acoustic mitigation may be required to protect the amenities of new residents from noise generated at the railway line on the southern boundary of the land. This could take the form of additional planting as part of the wider green infrastructure of the site.

8.51 Provision of a strong landscape structure, together with landscape buffers between the roads and residential areas and the creation of multi-functional green infrastructure networks which link with existing networks, could enhance the existing landscape and would help to soften the impact of development on this part of Stone Cross, and within the more sensitive landscape views across the Mountney Levels to the south. The proposed number of residential units and the proposed density should enable a high quality design of development, both built form and hard and soft landscaping, to reduce the impact of future development on the surrounding landscape and the existing built environment.

55 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross Site SCG (not in the I&O consultation)

8.52 Site SCG is located to the east of Sites SCC and SCD and was not part of the original I&O consultation. This land has been submitted relatively recently under the SHLAA process and is considered to be suitable, available and achievable in combination with Sites SCC and SCD. The sites together could form a cohesive extension to the existing urban edge of Stone Cross, whilst ensuring an appropriate countryside gap can be retained to Westham further east. The site could also link with the existing isolated sporadic development on the northern side of Rattle Road.

8.53 The north-eastern part of the site is constrained by the requirement to provide a buffer to the flood risk area to the east and therefore, is not developable and the numbers proposed reflect this constraint. The site boundaries are formed of strong existing green infrastructure which could help to soften the development in views from the east and which could be reinforced and enhanced to ensure a net gain in biodiversity can be achieved on this site.

8.54 Delivery of this site would be dependent on development coming forward on Site SCD in order to provide appropriate vehicular access and therefore the preference is for comprehensive scheme for development across all three sites (SCC, SCD and SCG) to be brought forward.

Land at Friday Street

8.55 The proposed site allocation boundaries for development at Stone Cross do not include any additional land at Friday Street over and above the 38 units already permitted on the western triangle of land immediately adjacent to the existing urban edge of Stone Cross, with access from Penrith Way. This small triangle of land formed a natural extension and infill adjacent to the existing residential development to the immediate west and south, and respected the existing eastern urban edge of development in this area, without encroaching on to the open countryside to the east.

8.56 The remainder of the land within the original site A in the I&O Paper has significant constraints to further development for housing.

8.57 The land to the north of Oak Tree Lane is visually prominent in views from the east and the Landscape Character Assessment and Development Option Evaluation Study, Volumes 1-3, identify this area as a landscape buffer.

8.58 The undeveloped land to the south of Oak Tree Lane and the farm buildings to the north of Pennine Way comprises two further field areas. The southern part of the two fields to the immediate north of Pennine Way contain a significant area at Flood Risk which is not developable, extending on average 20m into the site along the entire southern boundary. The topography of the two fields has a significant slope which ascends to the north, with a high point to the immediate west of the farm buildings in the western field. Any residential development on this high point would be particularly prominent in views throughout the surrounding area. 56 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

8.59 The Landscape Character Assessment and Development Option Evaluation Study, Volumes 1-3, identify the two fields as having a low potential preference for development. In addition, the Study constrains the developable area by requiring a significant tree belt to be planted in the northern part of the two fields to provide visual mitigation of new development within the wider landscape and to buffer new development to the farm buildings.

8.60 In addition, the farm buildings at Friday Street are currently in use for commercial purposes, with a mix of established B1 and B2 uses. There is concern that the presence of B2 uses would be incompatible with residential development to the immediate south and south west of the farm buildings. The economic objectives of the sustainability framework are to ensure that employment floor space is safeguarded. Residential development on the fields to the south of the farm buildings could create amenity issues due to the noise generated by the B2 uses; thereby potentially leading to future pressure for existing businesses to relocate from established locations and customer bases, bringing risk to their long term survival in the area. The use of Oak Tree Lane as the sole access

into the business site at Friday Street Farm could also lead to noise and disturbance for 8 Land at Stone Cross future residential properties if these are located adjacent to the northern boundary of the western field.The substantial buffer, shown in the Landscape Character Assessment and Development Option Evaluation Study, Volumes 1-3, would assist in reducing conflict between residential and business uses and vehicular traffic using Oak Tree Lane.

8.61 With the constraints to the northern and southern parts of the two fields, and the removal of any land to the north of Oak Tree Lane, the remaining land area at Friday Street is reduced significantly from an indicative area of around 12.15ha (not including the land already developed for the 38 units) to around only 3ha in size.

8.62 Access to the remaining 3ha would be required from Pennine Way and this would have to be via an acceptable solution over the adjacent undevelopable flood risk area. Due to the topography and the linear shape of the restricted area of land available for development, the main access route and subsidiary estate roads would be likely to create a convoluted road network which would represent a significant challenge to achieve an appropriately designed layout of development. In addition, public open space would also be required to be provided to serve the residential development, along with appropriate SUDS which would be required to consider the hydrological impacts of development upon the Mountney Levels and associated sensitive river, stream and wetland habitats. These constraints would reduce the developable area further still.

8.63 In summary, due to the identified constraints, development within the significantly reduced land area from that considered at I&O stage is likely to lead to a visually isolated development which would not be cohesive with other development in the area. In addition, any new development on the northern side of Pennine Way is likely to lead to a perception of visual coalescence of built development between Stone Cross and Eastbourne to the south. Development to the north of Oak Tree Lane would be inappropriate due to the visual sensitivity of the land within the wider landscape. Other land to the east of Stone Cross has been submitted through the SHLAA process that is more appropriate in terms of visual sensitivity. Moreover, these sites could create a more cohesive development on 57 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross the eastern edge of the settlement, whilst retaining a visual gap to the village of Westham and would enable the delivery of the 612 dwellings required within this strategic site. Therefore, it is not necessary to allocate land at Friday Street.

Density and Housing Numbers

8.64 The housing numbers across the strategic site are restricted to 650 due to the capacity of the WWTW. Thirty eight dwellings are now approaching completion on part of Friday Street Farm, leaving a balance of 612 dwellings to be allocated across the seven identified sites – SCA, SCB, SCC, SCD, SCE, SCF and SCG. An average density of 30 dph, or around 133 habitable rooms per hectare, as proposed in Policy SSC1, would ensure that despite the constraints of individual sites outlined above, the sites can accommodate the individual site numbers proposed, and also provide appropriate green infrastructure and public open space requirements.

Pre-submission modifications to the PSSSLP

8.65 The representations received as part of the Regulation 19 consultation in June and July 2013 relate to a number of matters. Although there were various site specific issues raised, a significant amount of representations received related to the principle of the quantity of development, the process and omission sites.

8.66 In terms of site specific issues, the policies have been reviewed to provide some flexibility to the exact location of the nursery on site SCA, and to provide some flexibility in terms of biodiversity and open space provision.

8.67 A number of representations promoting omission sites detail flaws in the allocated sites compared to those omission sites being promoted. The omission sites within the broad areas of search identified within the adopted CSLP have already been considered as alternatives in the Sustainability Appraisal. It is not considered necessary to change any of the allocated sites or to replace them with those omission sites.

8.68 The final viability assessment of the Strategic Sites was completed by the Council's appointed consultants in November 2013. The study shows that minor modifications were required to policies in the PSSSLP and supporting text to enhance viability and the changes have been derived to ensure compliance with the NPPF whilst ensuring viability. At Stone Cross, no changes were required to the policy wording or text and the sites are deemed viable to deliver the 638 dwellings with 40% affordable housing.

8.69 At the time of producing this Background Paper, with the pre-submission modifications information, outline planning permission for development as required by the policies in the PSSSLP has been granted on Sites SCB; SCE (via appeal); Sites SCC, SCD and SCG as a comprehensive proposal; and resolution to grant outline planning permission, subject to a S106 Legal Agreement, at Site SCF. Only Site SCA now remains to come forward.

58 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Summary for Land at Stone Cross

Total available land area across the sites: 30.12 hectares

Site SCA

Land area available: 5.47 hectares

Land requirements across the site

Housing land at 30 dph: 1.46 hectares

Relocated Garden Centre 0.6 hectares(14)

Public open space: 0.32 hectares

Total land requirement: 2.38 hectares

Land remaining: 3.09 hectares 8 Land at Stone Cross

Constraints commentary

8.70 There is ancient woodland on or adjacent to this site which would require a buffer of at least 15m to development, requiring an area of around 0.4ha in total. In addition, the sloping topography of parts of the site, the requirement for noise mitigation in relation to both Dittons Road and the A27 and the requirement to incorporate the existing footpath within the layout of development are constraints to development of this site.

8.71 The remaining site area also provides flexibility to provide a larger garden centre on the western part of the strategic site, subject to material planning considerations, whilst still allowing sufficient land area to accommodate 44 dwellings. The remaining land area should provide flexibility for the layout of the residential development, taking into account the constraints and the requirement for green infrastructure, including protecting, retaining and where appropriate, buffering, enhancing, restoring and strengthening existing wildlife corridors and habitats of biodiversity value, to ensure a net gain in biodiversity can be achieved on the site.

14 Based on the size of the existing garden centre site. 59 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross Site SCB

Land area available: 4.91ha

Land requirements across the site

Housing land at 30dph: 3 hectares

Public Open Space: 0.67 hectares

Total land requirement: 3.67 hectares

Land remaining: 1.24 hectares

Constraints Commentary

8.72 This site has three main constraints. There is an area of ancient woodland on the western boundary that requires a buffer of 15m to any development and this will affect an area of around 0.35ha. The UHPG main runs across the north eastern corner of the site and development within the first 9m of the pipeline is not permitted. Within the first 75m from the pipeline, only 10% of the overall development can be constructed, thereby limiting 9 units to an area of around 0.16ha in size. Finally, the site is affected by noise from both the A27 to the north and Dittons Road to the south and appropriate acoustic mitigation would be required which may be in physical form, such as landscaping. Therefore the remaining 1.24ha would allow for a flexible layout and design of the development, taking into account the constraints and the requirement for green infrastructure, including the protection, retention and where appropriate, buffering, enhancement, restoration and the strengthening of existing wildlife corridors and habitats of biodiversity value, to ensure a net gain in biodiversity can be achieved on the site.

Site SCC

Land area available: 4.29 hectares

Land requirements across the site

Housing land at 30dph: 3.23 hectares

Public Open Space: 0.72 hectares

Total land requirement: 3.95 hectares

Land remaining: 0.34 hectares

Constraints Commentary

8.73 The site has a sloping topography and the proposed density of development reflects this constraint. There is an existing Public Right of Way on the eastern boundary of the site which would need to be protected and incorporated into the design of 60 development, together with the creation of a new pedestrian and cycle access to Peelings Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Lane to the north. In addition, measures for noise mitigation in relation to the A27 to the north of the site would be required and this could take the form of physical works on site, such as additional landscaping. Development would also be required to consider hydrological impacts upon the stream between Sites SCC, SCD and SCG, which feeds into the Pevensey Levels, and a comprehensive approach between the sites to mitigate any potential adverse effects would be required.

8.74 The remaining 0.34ha would provide flexibility for the design of development to incorporate these constraints and the requirement for green infrastructure, including the protection, retention and where appropriate, buffering, enhancement, restoration and the strengthening of existing wildlife corridors and habitats of biodiversity value, to ensure a net gain in biodiversity can be achieved on the site.

Site SCD

Land area available: 3.35 hectares

Land requirements across the site 8 Land at Stone Cross

Housing land at 30dph: 2.7 hectares

Public Open Space: 0.6 hectares

Total land requirement: 3.3 hectares

Land remaining: 0.5 hectares

Constraints commentary

8.75 The site has a sloping topography and the proposed density of development reflects this constraint. There is an existing right of way on the eastern boundary of the site which would need to be protected and incorporated into the design of development, together with the creation of new vehicular, pedestrian and cycle access from Rattle Road to the south. An area of commercial land lies between the southern elements of Sites SCD and SCG and acoustic mitigation in the form of landscaping may be required to mitigate any impacts of commercial use of this land on the residential amenities of future occupiers of Site SCD. Development would also be required to consider hydrological impacts upon the stream between Sites SCD, SCC and SCG, which feeds into the Pevensey Levels, and a comprehensive approach between the sites to mitigate any potential adverse effects will be required.

8.76 The remaining 0.5ha would provide flexibility for the design of development to incorporate these constraints and the requirement for green infrastructure, including the protection, retention and where appropriate, buffering, enhancement, restoration and the strengthening of existing wildlife corridors and habitats of biodiversity value, to ensure a net gain in biodiversity can be achieved on the site.

61 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross Site SCE

Land area available: 3.59 hectares

Land requirements across the site

Housing land at 40dph: 3 hectares (based on outline planning permission granted at appeal)

Public Open Space: 0.88 hectares

Community Centre: 0.5 hectares

Total Land requirement: 4.38 hectares

Constraints commentary

8.77 The outline planning permission granted at appeal will require the majority of the required public open space to be provided off site, in order to allow sufficient remaining land to provide 120 dwellings and the community centre on site at a density similar to the other sites proposed for development in eastern Stone Cross.

8.78 There are also several further constraints to development of this site, including the consideration of the setting of the Grade II* listed Stone Cross Windmill and its future access to wind from the east. The retention of the sunken and tree lined track between Sites SCE and SCF for its landscape and historic value, the retention of existing green infrastructure where present within the site and on the site boundaries and provision of appropriate SUDS will also be required.

Site SCF

Land area available: 4.15 hectares

Land requirements across the site

Housing land at 30dph: 2.73 hectares

Public Open Space: 0.6 hectares

Total land requirement: 3.33 hectares

Land remaining: 0.82 hectares

62 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Constraints Commentary

8.79 Development of the site is required not to prejudice future access to the remainder of Uplands Farm, including to the commercial activities undertaken on land adjacent to Site SCF. Due to the visual sensitivity of the southern part of the site, development would be required to be located within the northern part of the site, closest to Rattle Road, to allow open space, landscape and acoustic mitigation in the southern part of the site. Reinforcement of the planting on the eastern boundary of the site would also be necessary to reduce visual impact of development on the surrounding landscape. Retention of the sunken and tree lined track between Sites SCE and SCF for its landscape and historic value would also be required.

8.80 The remaining 0.82ha would provide flexibility for the design of development to incorporate these constraints and the requirement for green infrastructure, including the protection, retention and where appropriate, buffering, enhancement, restoration and the strengthening of existing wildlife corridors and habitats of biodiversity value, to ensure a net gain in biodiversity can be achieved on the site. 8 Land at Stone Cross

Site SCG

Land area available: 4.36 hectares

Land requirements across the site

Housing land at 30dph: 3.06 hectares

Public Open Space: 0.6 hectares

Total land requirement: 3.66 hectares

Land remaining: 0.7 hectares

Constraints Commentary

8.81 An area of commercial land lies between the southern elements of Sites SCD and SCG and acoustic mitigation in the form of landscaping may be required to mitigate any impacts of the commercial use of this land on the residential amenities of future residents of Site SCG. A Flood Risk Assessment (FRA), taking into account climate change, would be required in relation to Site SCG and this would identify any areas of the site in Flood Zones 2 and 3, where only water compatible uses, essential infrastructure and recreational access will be permitted. Development would also be required to consider hydrological impacts upon the stream between Sites SCD, SCC and SCG, which feeds into the Pevensey Levels, and a comprehensive approach between the sites to mitigate any potential adverse effects would be required.

8.82 The remaining 0.82ha should provide flexibility for the design of development to incorporate these constraints and the requirement for green infrastructure, including the protection, retention and where appropriate, buffering, enhancement, restoration and the 63 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 8 Land at Stone Cross strengthening of existing wildlife corridors and habitats of biodiversity value, to ensure a net gain in biodiversity can be achieved on the site.

64 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

9 Land at Pine Grove, Crowborough

9.1 The comprehensive SHLAA undertaken by the Council in 2008-2009 identified that land was suitable, available and achievable in the Pine Grove area of Crowborough. This land subsequently formed part of the broad area of search for new strategic development to serve Crowborough as identified in the adopted CSLP.

9.2 At I & O stage, the opportunities and constraints of developing the land at Pine Grove were identified and are summarised below:

Opportunities

Enhance the biodiversity value of the site – retention of at least a small number of significant and prominent established trees, trees along the boundaries of the site, within the site and within the existing woodland area to the south, whilst not impeding development. In addition, the ecological assessment recommended that any development on site should include particular habitat creation measures to enhance biodiversity and wildlife corridors, such as:-

Habitat piles of dead wood should be created within the woodland to support saprophytic invertebrates, including stag beetle larvae. Bird and bat boxes should be erected in appropriate locations. Species rich native hedgerows should be planted. Green roofs should be considered. Species of known wildlife value should be used in landscape schemes, including a large proportion of native trees and shrubs.

Design - there is an opportunity for creative building design with good landscaping Crowborough 9 Land at Pine Grove, and some limited public open space, which would also serve to enhance the setting of the community centre and Pine Grove offices. The site is suitable for a range of housing, and may need to include high density development, which may also increase the height of the buildings on site. This aspect, alongside creative design and innovative features, can be used to provide modern buildings of character within Crowborough town centre on this site which is visible from the north and north west of the town. Links to the town centre - the opportunity should be taken to incorporate and improve pedestrian and cycle links through to other town centre facilities. Development on previously developed land - the provision of residential development on this site would help to minimise greenfield land take around the edge of Crowborough.

65 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 9 Land at Pine Grove, Crowborough Constraints

Car Parking - the demand for parking spaces for the Community Centre and other town centre uses within the development could be an issue and this should be considered as part of the detailed design and management of the site. Biodiversity - retention of existing habitats, particularly prominent trees within the centre of the site and woodland area, will require sensitive building layout and landscape design, and may impact upon the land availability in certain parts of the site.

9.3 The consideration of the opportunities and constraints informed the guiding principles for development of the SDA at Pine Grove and these were comprehensively consulted upon within the I & O exercise.

PSSSLP Policy and Site Area for Land at Pine Grove

9.4 The proposed site allocation boundary at Pine Grove, as identified in the PSSSLP, and the accompanying policies have been informed by the consultation process and the constraints and opportunities identified.

Alternative additional sites to provide the 140 dwellings across Pine Grove and Jarvis Brook

9.5 Subsequent to the I&O consultation, one of the sites at Jarvis Brook was withdrawn. Additionally, a second site was subsequently deemed unsuitable for development, leaving only one site at the former depot as available for allocation to achieve the 140 dwellings required across Pine Grove and Jarvis Brook. Therefore, a search was made for alternative sites to address the additional site area required to deliver the 140 homes and this is documented in the Sustainability Appraisal Report. In summary, three additional sites were found to help achieve delivery of 140 dwellings and the opportunities and constraints of development of these sites are outlined below:

Land to the rear of Tall Trees, Nevin, Tree View and Orchard View, Crowborough Hill – Opportunities and Constraints

9.6 This site lies close to Crowborough town centre in a sustainable location for accessibility to the facilities and services offered. The site could provide around 10 small dwelling units to partly address the deficit caused by the deletion of the Millbrook Garden Centre site and the land west of Palesgate Lane in Jarvis Brook from potential options for development in the town.

9.7 The site lies in close proximity to existing public open space and leisure facilities in Crowborough, is close to frequent bus routes and is within easy walking distance to the High Street. Its development would lead to the loss of some existing green space, formed predominantly of rear garden areas, and potentially some mature trees, but appropriate planting and a buffer to the stream to enhance remaining green infrastructure would help to conserve the biodiversity of the site. 66 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

9.8 Mitigation will be required to address the requirements of the HRA in relation to the designated European Sites on the Ashdown Forest through provision of SANGS and SAMMS.

Land to the rear of Mayvern Court, Eridge Road – Opportunities and Constraints

9.9 This site lies on the edge of Crowborough town centre in a sustainable location for accessibility to the facilities and services offered. The site could provide around 6 small dwelling units to partly address the deficit caused by the deletion of the Millbrook Garden Centre site and the land west of Palesgate Lane in Jarvis Brook from potential options for development in the town.

9.10 The site lies in close proximity to the public open space and leisure facilities at Goldsmiths Leisure Centre, is on a bus route with frequent services and is within easy walking distance to the High Street. Sufficient space would remain to provide appropriate parking and communal open space on site to serve the new and existing development. There would be some loss of existing green space, comprising communal open space, and potentially some mature trees, but appropriate planting to enhance remaining green infrastructure would help to conserve the biodiversity of the site.

9.11 Mitigation would be required to address the requirements of the HRA in relation to the designated European Sites on the Ashdown Forest through provision of SANGS and SAMMS.

Land at Roughetts and adjacent properties to the south, Ellison Close – Opportunities and Constraints

9.12 This site lies close to Crowborough town centre in a sustainable location for Crowborough 9 Land at Pine Grove, accessibility to the facilities and services offered. The site could provide around 6 small dwelling units to partly address the deficit caused by the deletion of the Millbrook Garden Centre site and the land west of Palesgate Lane in Jarvis Brook from potential options for development in the town.

9.13 The site lies in close proximity to the public open space and leisure facilities at Goldsmiths Leisure Centre, is close to bus routes with frequent services and is within easy walking distance to the High Street. There would be some loss of existing garden space and potentially some mature trees, but appropriate planting to enhance remaining green infrastructure would help to conserve the biodiversity of the site.

9.14 Mitigation would be required to address the requirements of the HRA in relation to the designated European Sites on the Ashdown Forest through provision of SANGS and SAMMS.

Site Area

9.15 The proposed strategic site for Pine Grove is formed of four separate site areas identified as Sites CRA, CRB, CRC and CRD. It is proposed in Policy SCR1 that the four sites will deliver 113 dwellings (see map at Appendix 7). 67 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 9 Land at Pine Grove, Crowborough Site CRA – Land at Pine Grove

9.16 Site CRA is 1.13ha in size and is sustainably located within the centre of Crowborough. The site is therefore considered suitable to deliver around 91 dwellings.

9.17 The site is currently formed of a temporary car park, a wooded area to the south and east, and the Beaconwood office building. The boundaries of the site follow the adjacent roads on three sides and the boundary to the Crowborough Community Centre with its car park on the fourth, northern side. There are a variety of designs, characters and densities of development in the local area and it is considered that a sensitive design on this site could provide the 91 proposed units, whilst retaining some elements of the existing green infrastructure to ensure that wildlife corridors in the area can be preserved. It is acknowledged that it will be challenging to retain trees on all but the areas on the boundaries of the site.

9.18 It is acknowledged that the development would lead to a loss of office space through the development of the Pine Grove site. However, the Beaconwood offices at Pine Grove are not of the high quality type sought by small and medium enterprise companies in this area and the recent report by GVA Grimley considers that there is probably sufficient office supply in Crowborough to cater for SME companies, therefore not requiring the retention or relocation of this existing office use. Options are also being explored in relation to provision of a Community Hub use at the adjacent empty former Council Offices at Pine Grove, which could provide alternative space for existing uses at Beaconwood.

9.19 There would also be the loss of a temporary public long stay car park on the Pine Grove site, and research into existing parking provision in the town centre has shown that an adjustment of some of the remaining parking bays would be required within the town centre car parks to ensure sufficient car parking remains with Crowborough Town Centre. Policy SCR1 requires this provision to have been made at the same time as development of Site CRA to ensure adequate car park provision is maintained in the town centre.

Site CRB – Land to the Rear of Tall Trees, Nevin, Tree View and Orchard View

9.20 Site CRB measures 0.73ha and is proposed to accommodate around 10 single storey dwellings. The site is constrained by its linear nature, existing substantial green infrastructure on boundaries and within the site and the wooded ghyll area on the eastern boundary. In addition, due to the proximity of existing residential development to site boundaries and the need to ensure that residential amenities of existing occupiers of dwellings are protected, it is considered that single storey dwellings would be the most appropriate on this site.

9.21 The developer with an option on the site, who is already developing land immediately to the southwest, has indicated that a development of the type proposed in Policy SCR1 could be delivered. Site CRB would be accessed via this adjacent site to the southwest and the layout of development has already factored in this future requirement. 68 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Site CRC – Land to the rear of Mayvern Court, Eridge Road

9.22 Site CRC measures 0.12ha and is located to the rear of existing flatted development which fronts onto Eridge Road. Development of this rear part of the site for around 6 additional dwellings would be a natural extension to the existing residential development at the front of the site and it is envisaged that new development would be of a similar form and style. Sufficient land is available to provide appropriate additional parking to serve six new units within this sustainable location in close proximity to the town centre and public transport provision.

Site CRD – Land at Roughets and adjacent properties to the south, Ellison Close

9.23 Site CRD measures 0.39ha and is located to the north of St John’s Road off Ellison Close. It comprises a dwelling called ‘Roughets’ with associated garden, and the rear parts of three gardens of dwellings fronting on to St John’s Road.

9.24 The site had previously been put forward for 7 detached dwellings and planning permission was refused on four counts including: proximity to the Ashdown Forest Special Protection Area (SPA), overdevelopment of the site, impact on residential amenity and ecology. The proposed allocation of the site as part of the PSSSLP would address the HRA issues in relation to the Ashdown Forest under Policy SCR2 and Policy SHR1. Six units are identified in the PSSSLP and these would be smaller than those previously proposed in the application which should prevent overdevelopment of the site and ensure that green infrastructure can be retained and enhanced. The requirement for smaller units would also allow for a more appropriate site layout to be achieved that would not impact on the residential amenity of existing or proposed dwellings. The issues relating to ecology could be resolved through conducting appropriate surveys and proposing mitigation as necessary. Crowborough 9 Land at Pine Grove,

9.25 It was also noted that works to the access/egress of Ellison Close on to St John’s Road may be required and this is incorporated into Policy SCR4.

Density, Housing Numbers and Constraints

9.26 The density of the individual sites reflects their proximity to the town centre and individual site constraints and characteristics.There is an overall provision of 2.37 hectares of land across the four sites forming the proposed Land at Pine Grove strategic site.

Pre-submission modifications

9.27 The representations received as part of the Regulation 19 consultation in June and July 2013 relate to a number of specific matters. A significant proportion of representations received related to Site CRA at Pine Grove. In the main, these related to the future loss of car parking within the town centre as a result of the development of the site, and the loss of the temporary car park. A number of criticisms were made of the car parking study commissioned by the Council and ESCC and the policy that seeks to address the loss of the temporary car park at Pine Grove. The comments made regarding the loss of car parking have already been addressed by the Council (15) following the specific 15 March 2013 Cabinet report entitled Pine Grove Disposal Update, available on the Council's website 69 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 9 Land at Pine Grove, Crowborough evidence from the car parking surveys carried out and it is not necessary to change the allocation at Site CRA.

9.28 Representations were also received regarding the effectiveness of a SANGS in South East Crowborough. These issues have been addressed through updates to the HRA, which explains how SANGS and SAMMS work in this area in complementary fashion to effectively mitigate development. Proposals to modify the SANGS policy in respect of Pine Grove are therefore proposed to be incorporated in order to be consistent with the overall SANGS policy.

9.29 Detailed arguments were provided as to why the Pine Grove Sites were not considered to be deliverable. Two alternative sites were put forward to the Pine Grove site. The sites suggested are not in the vicinity of Pine Grove or the town centre with one site lying within the High Weald Area of Outstanding Natural Beauty (AONB) and the other outside the AONB in South East Crowborough. The sites promoted as alternatives have been considered through the Sustainability Appraisal process for the PSSSLP. It is considered that the Pine Grove sites remain the most appropriate.

9.30 The final viability assessment of the Strategic Sites was completed by the Council's appointed consultants in November 2013. The study shows that minor modifications were required to policies in the PSSSLP and supporting text to enhance viability and the changes have been derived to ensure compliance with the NPPF whilst ensuring viability. At Land at Pine Grove, there is a proposed change to housing mix to take into account a change in housing mix at the South East Crowborough allocation (SD10).

Summary for Land at Pine Grove

Site CRA – Pine Grove

Land area available: 1.13 hectares

Land requirements across the site

To provide 91 net dwellings (81dph) : 1.1232ha

Children’s Equipped Play Space: 0.0068ha

Total land requirements: 1.13 hectares

Constraints Commentary

9.31 Development at Site CRA is proposed at 81dph to reflect the central sustainable location of the site and the character of development in the area, which includes flats, a large community hall and a two storey office building. The layout of development should allow for the retention of some of the existing green infrastructure on site to retain wildlife corridors.

70 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Site CRB - Land to the rear of Tall Trees

Land area available: 0.73 hectares

Land requirements across the site

10 net dwellings (13.6 dph): 0.73

Total land requirements: 0.73 hectares

Constraints Commentary

9.32 Development proposed at Site CRB equates to around 13.6dph and this reflects the requirement to retain existing green infrastructure; to provide an appropriate access route into the linear site; to ensure an appropriate layout of development which provides for residential amenities of existing adjacent properties and the amenities of future occupiers; to allow for the floor space required by single storey dwelling types; and to ensure an appropriate buffer between development and the ghyll area.

Site CRC - Land at Mayvern Court, Eridge Road

Land area available: 0.12 hectares

Land requirements across the site

6 net dwellings (80dph): 0.12 hectares

Total land requirements: 0.12 hectares Land at Pine Grove, Crowborough 9 Land at Pine Grove, Constraints Commentary

9.33 Development proposed at Site CRC equates to around 80dph and this reflects the density of existing development at this site within a central location in the town and will allow for the provision of appropriate car parking and communal amenity space for future residents.

Site CRD - Land at Roughets, St. Johns Road

Land area available: 0.39 hectares

Land requirements across the site

6 net dwellings (15.3 dph): 0.39 hectares

Total land requirements: 0.39 hectares

Constraints Commentary

9.34 Development at Site CRD equates to around 15.3dph and reflects the existing constraints on site including protected trees; the need to protect the amenities of existing 71 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 9 Land at Pine Grove, Crowborough residential properties, and the requirement to retain and enhance green infrastructure. Although the site is relatively close to the town centre, the lower density reflects the general existing character of development in the area and also respects the proximity to the European protected sites on the Ashdown Forest.

72 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

10 Land at Jarvis Brook, Crowborough

10.1 The comprehensive SHLAA undertaken by the Council in 2008-2009 identified that land was suitable, available and achievable at Jarvis Brook, Crowborough. This land subsequently formed part of the broad area of search for new strategic development to serve this part of Crowborough as identified in the adopted Core Strategy.

10.2 At I & O stage, the opportunities and constraints of developing the land at Jarvis Brook were identified and are summarised below. Since publication of the I&O Paper, the Millbrook Garden Centre site, which was an option for development, has been withdrawn by the landowners and is therefore no longer available for development. This site is not included for further consideration within this Background Paper.

10.3 Jarvis Brook Depot

Opportunities

Brownfield site - this site provides the opportunity to develop a brownfield site and therefore to minimise the use of greenfield land around the edge of town. Provision of more appropriate use in established residential area - development of the site for residential use would remove an incompatible use within this residential area and would result in an attendant reduction in heavy vehicle movements in the area. Design - there are opportunities to improve the overall appearance of the area by means of designing a high quality residential scheme to replace the existing commercial use on the site. Ecology - there would be opportunities to enhance the ecological and biodiversity value of the area, through retention and enhancement of 'wildlife' corridors and creation of a buffer zone adjacent to Crowborough Ghyll. 10 Land at Jarvis Brook, Crowborough

Constraints

Access - the proposed development site is accessed by reasonably narrow estate roads which have a high level of on-street parking. It is not, however, anticipated that redevelopment of this site for residential use would create an overall deterioration in current highway conditions as the redevelopment would lead to a reduction in the numbers of heavy vehicles using the access roads. Contamination - there is likely to be contamination from former uses as a depot with diesel pumps present on the site and any pumps would need to be removed and any contamination appropriately dealt with, prior to development (subject to contamination survey). Noise - noise attenuation measures may be necessary adjacent to the railway line (subject to the results of a noise survey).

73 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) Land at Jarvis Brook, Crowborough10 Land at Jarvis 10.4 Palesgate Lane

Opportunities

Opportunities to improve accessibility and connectivity - the development of the site would require improvements to general accessibility and connectivity to the local area, through the provision of suitable vehicular and pedestrian/cycle routes to ensure that local residents are not isolated.This would have the added benefits of increasing accessibility throughout the area including to local green infrastructure provision. An opportunity for green infrastructure provision - development of the site would provide opportunities for children's play space, leisure and recreation facilities to address future needs and some of the deficiencies in the local area.

Constraints

Site Gradient - the site is sloping towards the south-east and is more steeply sloping at its southern end where the land falls towards the ghyll. Ancient Woodland – there are areas of Ancient Woodland at the southern and western parts of the site trees on the western boundary which are subject to Tree Preservation Orders (TPOs). Archaeology - towards the southern part of the site there is also an area of Archaeological Interest although it is not known what impact this may have on any potential development. This would need to be investigated further before any development takes place. Flood Risk – an element of the southern part of the site lies within Flood Zones 2 and 3. A 50m restriction on building adjacent to the Flood Zone area places restrictions on the land available for development. High Pressure Gas Mains - an underground High Pressure Gas main crosses the centre of the site. The layout of development on the site would need to take into account the High Pressure Gas main, the recommended Protection Zone and any additional safety requirements of Southern Gas Networks and the Health and Safety Executive. This would impact on the layout and possible the land available for development. Access through the Industrial Estate - a further significant constraint relates to access to the site. As Palesgate Lane is considered an unsuitable means of access due to the narrowness of the road, a new access to the site would need to be achieved through the Millbrook Business Park/Industrial Estate. The only possible point of access to the site is from the access road to the Servomex building, and would need to be in accordance with the requirements of the Highway Authority. In addition, the only possible means of access between the areas of Ancient Woodland to the west and south of the site is narrow and would be impacted by the need to provide a 15m buffer zone to the areas of Ancient Woodland. Accessing a residential site through the Millbrook Business Park/Industrial Estate is also a particular concern in relation to people with children, pushchairs and wheelchairs. and also for cyclists due to the clear conflict with the numbers of heavy vehicles which would need to access the Business Park/Industrial Estate. 74 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Biodiversity and Ecology/Trees - the presence of two areas of Ancient Woodland on site and a number of significant oak trees, presents a constraint to development, due to the requisite 15 m buffer to the areas of Ancient Woodland. This is a particular constraint in providing adequate access to the site. Significant trees and designated TPO's identified on site, must be retained and incorporated into a suitable landscape scheme, which would impact upon the layout and design of the development and possibly on the land available for development. Ecological constraints - The ecological assessment found that woodland /dense scrub occupies 60% of the site. Although due to its limited size the site supports only a moderate range of habitat types, some of the habitats are of high biodiversity value. Overall, the site was considered to be of ecological value at a District level due to the presence of ancient ghyll woodland and its potential significance for reptiles. It was considered that it may qualify as a Key Reptile Site at the County level. The site is considered to have biodiversity interest and good connectivity to a range of habitats in the wider countryside, including woodland, hedges, streams, ponds and grassland, indicating that the site is an area of high biodiversity value.The ecologist’s conclusion was that the site supports an Ancient Woodland habitat, which is an irreplaceable habitat that must not be lost to development. The assessors also concluded that it is difficult to envisage any development proposal for the site that would not have an unacceptably high adverse impact.The ecologists recommendation therefore, is that this site should not be developed due to its ecological importance. Potential isolation of the new community - the development of the site for housing, in an area that is physically isolated from other residential developments may lead to community severance and leave residents feeling isolated and remote from other communities and facilities.

10.5 The consideration of the opportunities and constraints informed the guiding principles for development of the SDA at Jarvis Brook and these were comprehensively

consulted upon within the Issues and Options exercise. 10 Land at Jarvis Brook, Crowborough

PSSSLP Policy and Site Area for land at Jarvis Brook, Crowborough

10.6 The site area identified in the PSSSLP for the strategic site at Jarvis Brook and the accompanying policies have been informed by the consultation process and the constraints and opportunities identified.

Site Area

10.7 Subsequent to the I&O process, the site at Palesgate Lane was considered inappropriate for further consideration for inclusion within the strategic site. The full consideration of the issues in relation to this particular site is within the SAR accompanying the PSSSLP. In summary however, land at Palesgate Lane was rejected in order to protect the biodiversity interests on site and also due to the only access available to the site being through the adjacent industrial estate. Natural England also raised significant concerns in relation to the ecological impacts of allocating the Palesgate Lane site for development during the I&O consultation process. 75 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) Land at Jarvis Brook, Crowborough10 Land at Jarvis 10.8 The chosen site at Jarvis Brook, identified as site CRE (see map at Appendix 8) is currently in use as a heavy vehicle depot. The site area is constrained by the existing boundaries formed by residential development off Forest Dene to the north west and north east, the railway line on the south eastern boundary and the Crowborough Ghyll on the south western boundary. Access is via the existing vehicular access to Forest Dene.

10.9 Within Crowborough Ghyll is an area of ancient woodland, but the 15m buffer to this area does not fall within the proposed site boundary for Site CRE. However, considerations for development of this site would include acoustic mitigation for noise generated at the railway line; the retention of trees on site; and the retention and enhancement of site boundaries with residential dwellings on Forest Dene.

10.10 The land within the proposed strategic site is brownfield land and is currently used as a heavy vehicle depot and therefore development for housing purposes would lead to the loss of the employment use at this site. In order to mitigate this loss, Policy SCR5 proposes that development of the strategic site only be permitted if provision of suitable replacement employment floor space within the Jarvis Brook area, commensurate with the loss of the depot, can be secured. This would ensure that there is no net loss of employment use in the area and would support the continued presence of an appropriately skilled workforce in the local area to support long term competitiveness.

Density and Housing Numbers

10.11 The average density of development is proposed to be 30dph, or 137 habitable rooms per hectare, which reflects the existing density of residential development in the area.

Pre-submission modifications

10.12 The representations received as part of the Regulation 19 consultation in June and July 2013 relate to a number of specific matters. The representations received regarding development of the Land at Jarvis Brook appear to be generally supportive, however with queries raised about the ability to increase employment provision elsewhere and the viability of the site.

10.13 Due to the restrictions on additional traffic movements in the Crowborough area, it is considered that as there are a number of businesses seeking to expand/ relocate to this area alternative employment provision can be secured. This is in addition to capacity at Farningham Road.

10.14 The final viability assessment of the Strategic Sites was completed by the Council's appointed consultants in November 2013. The study shows that minor modifications were required to policies in the PSSSLP and supporting text to enhance viability and the changes have been derived to ensure compliance with the NPPF whilst ensuring viability. On a viability basis the development of this site has already been considered, taking into account the potential contaminated land issues, and it is reported that the site is viable at the proposed 27 units at 30dph. 76 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

10.15 A small number of changes have been proposed to the policy for the purposes of clarification arising from the comments made.

Summary for Land at Jarvis Brook

Land area available: 0.9 hectares

Land requirements across the site

Housing land at 30dph: 0.9 hectares

Total land requirements: 0.9 hectares

Constraints Commentary

10.16 Development of the proposed site would need to ensure that there is no negative impact on the Ancient Woodland to the south west; that appropriate acoustic mitigation is provided to the railway line, which could be partly in the form of planting on the boundary; that the oak trees and other green infrastructure on site are retained; and the requirement to provide appropriate boundary treatments to existing residential properties to the north and northeast. 10 Land at Jarvis Brook, Crowborough

77 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) Land at Jarvis Brook, Crowborough10 Land at Jarvis

78 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

11 Land at South East Crowborough

11.1 The comprehensive SHLAA undertaken by the Council in 2008-2009 identified that land was suitable, available and achievable in south east Crowborough. This land subsequently formed part of the broad area of search for new strategic development to serve Crowborough as identified in the adopted CSLP.

11.2 At I & O stage, the opportunities and constraints of developing the land south east of Crowborough were identified. Twelve areas of land were identified and formed options for development (see map at Appendix 9) however, only site Di was subsequently chosen in its entirety, along with part of site E adjacent. This allocated site is closest to Option 3 for development at south east Crowborough as set out in the I&O Paper.

11.3 Full consideration of the other ten parcels of land forming alternative options for development is contained within the Background Paper for Crowborough, and the reasons for selecting the preferred option and rejecting of alternatives is fully outlined in the SAR. The main issues for rejection of the other ten parcels of land included vehicular and pedestrian access constraints and adverse impact on ecology and landscape including some that is designated or affects an AONB.The consideration of reasonable alternatives for development was also informed by the evidence base, including the Landscape Character Assessment and Development Option Evaluation Study February 2009, Volumes 1-3, and comments on the I&O paper from Natural England.

11.4 The opportunities and constraints outlined below refer to the two chosen sites:

11.5 Site D – Land south of Walshes Road (comprising sites Di and Dii).

Opportunities 11 Land at South East Crowborough

SANGS - Opportunity to provide a SANGS on land to south (within the same land ownership) to enhance biodiversity and meet the requirements of the Habitats Regulations in respect of Ashdown Forest. Landscape character - development of Site Di would provide the opportunity for an attractive landscape scheme on the edge of the urban area of south-east Crowborough which could be accommodated within the local landscape character. Any development to the west of the access road to Walsh Manor Farm from Walshes Road would be unobtrusive and seen as a 'natural' extension of the urban edge. Recreation facilities - development of Site Di would provide the opportunity to benefit from the existing recreational facility currently provided by Site Dii with a direct pedestrian link possible between the two sites. If Site Dii was to be developed then this would require the provision of a new recreational facility as part of the development of Site Di (or any land adjacent to Site Di on its eastern side). Traffic management on Western Road - the development of Site D would provide opportunities to implement or contribute towards the implementation of a traffic management scheme in Western Road to improve traffic flow and reduce congestion.

79 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 11 Land at South East Crowborough Constraints

Trees and woodland - retention of noteworthy trees and groups of trees around the periphery of Site Di in particular in the north east and northwest corners and south-east corner, may be a constraint on development. The woodland at the southern end of Site Dii adjacent to the ghyll should be retained, which may impact on development. Public open space - whilst relocation of the children play facility would be more accessible than the current facility to those residents living to the north of Walshes Road, it would not be as convenient for residents who live in Adam Close and housing development around Alderbrook Road and have access to the current facility. Western Road – highway and transport improvements.

11.6 Site E – Land south of Walshes Road

Opportunities

SANGS - there is an opportunity to provide a SANGS on land to south to enhance biodiversity and meet the requirements of the Habitats Regulations in respect of Ashdown Forest. This would be provided on land within the ownership of the Site E land owner. Removal of buildings - There is an opportunity to remove unattractive farm buildings at Walsh Manor Farm which are located to the east of the site adjacent to the access road from Walshes Road. Landscape character - there is an opportunity to improve/retain existing hedgerows and landscape features within the development and on the boundary of the site. Traffic management on Western Road - there is an opportunity to implement or contribute towards the implementation of a traffic management scheme in Western Road to improve traffic flow and reduce congestion.

Constraints

Trees and hedgerows - the retention of trees and boundary hedges may impact upon any proposed development on site. Landscape visual impact - this part of the SDA is the most exposed and sensitive in relation to views from/to the AONB and surrounding areas.The potential visual impact that any development of Site E would have on the AONB therefore is greatest on this particular site. Western Road – the need for localised highway and transport improvements.

11.7 The consideration of the opportunities and constraints informed the guiding principles for development of the SDA at land at south east Crowborough and these were comprehensively consulted upon within the I & O exercise.

80 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

11.8 Alternative land submitted for consideration but rejected

Alderbrook, South East Crowborough (SHLAA Ref: 200/1110)

11.9 The site lies adjacent to the broad area of search for growth in South East Crowborough identified in the Core Strategy, and in combination with development of other identified locations for growth in the town, it cannot be considered that the development would not have an adverse impact on the designated European sites on the Ashdown Forest through nitrogen deposition. The site lies outside of the High Weald AONB, but in an area identified as a landscape buffer between the edge of the town and the designated AONB landscape, therefore, development on the site could be visually harmful to this area of countryside.

11.10 The site has poor linkages with existing development in the south of Crowborough. The most direct vehicular access would be via a narrow road without pedestrian footways. There are no direct existing footpaths connecting this site with the town to the north or the wider countryside to the east, south and west. There are potential road safety issues with the increase of vehicles using the junction of Stone Cross Road with Alice Bright Lane to the south of the site due to poor visibility to the north which cannot be improved.

Land at Steel Cross, Crowborough: SHLAA Ref: 250/110

11.11 The site lies outside the broad area of search for growth identified in the CSLP, and in combination with development of other identified locations for growth in the town, it cannot be considered that the development would not have an adverse impact on the designated European sites on the Ashdown Forest through nitrogen deposition.

11.12 This land lies entirely within the High Weald AONB. It can be demonstrated 11 Land at South East Crowborough through the evidence based process, including the SHLAA exercise, that there are other suitable, available and achievable sites which lie outside of the AONB which could achieve the development requirements within this part of the District, as identified within the adopted CSLP, including the provision of SANGS. The Planning Inspector examining the CSLP made it clear that major development within the AONB should be allowed only on an exceptional basis where it is in the public interest, and subsequently the submission Plan was modified to delete major development sites proposed within the AONB. The NPPF requires a detailed assessment of need, the impact of any decision on the local economy, the cost of and scope for meeting the need, either outside of the designated area or in some other way, and also of any detrimental effect on the environment, the landscape and recreational opportunities and the extent to which that could be moderated. Other sites put forward for development, which ,lie outside of the AONB, are considered to be suitable, available and achievable and therefore this site is rejected.

PSSSLP Policy and Site Area for Land at South East Crowborough

11.13 The site allocation boundary for the proposed strategic site at Crowborough, and the accompanying policies, have been informed by the consultation process and the constraints and opportunities identified. 81 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 11 Land at South East Crowborough Site Area

11.14 The proposed strategic site, identified as CRF in the PSSSLP (see map at Appendix 9), measures 7.14ha in total and is located to the south of Walshes Road. The proposed site allocation boundary is similar to Option 3 for development at south east Crowborough, as shown in the I&O Paper, and comprises the entirety of the site identified as Di (to the west of the track bisecting the strategic site), and a small part of the site identified as E (to the east of the track bisecting the strategic site), within Option 3. In addition to the land shown within Option 3 within the I&O Paper, an area of land to the east is also incorporated within the proposed strategic site. This additional area would provide greater flexibility in terms of layout and design to accommodate the 160 new dwellings proposed, but would also enable the use and reinforcement of an existing field boundary to minimise visual impact of development in views from the east. This measure should create a more natural boundary to the spread of development to the east and could soften the visual impact and reinforce the wildlife corridor already existing in this location. The land to the west of the track, formerly identified as site Di, is bounded by the existing hedged and tree lined boundaries of the existing field area.

11.15 The Landscape Character Assessment and Development Option Evaluation Study February 2009, Volumes 1-3, identified the land shown as CRF in the PSSSLP as having a degraded and weak character within the surrounding landscape. In addition, the Ecological Assessment identified the land as having the lowest ecological value in relation to other options for development within south east Crowborough. Therefore, there are opportunities through development to increase and improve green infrastructure on the proposed strategic site area, as well as to ensure that a net gain in biodiversity can be achieved.

11.16 The buildings at Walshes Manor Farm were originally included in land identified as site E in the I&O Paper, but it has become apparent that these buildings are in commercial use. Therefore, to avoid the loss of employment land, the buildings are omitted from the proposed site allocation boundary. The inclusion of the additional land adjacent to the former site E, as shown in the I & O Paper, could also help to mitigate loss of land area within the strategic site.

11.17 Land to the south of the proposed Site CRF, beyond the immediate field, is proposed for allocation to provide a SANGS. A proposed policy requirement for the development of Site CRF is the provision of a suitably located car park for SANGS users. A pedestrian access to the SANGS could be achieved via the existing public footpath running south form Walshes Road, which could be incorporated appropriately into the design of residential development on the strategic site. There may also be potential for access to the SANGS via the existing public open space to the south of Adam Close.

Density and Housing Numbers

11.18 Although the proposed strategic site is located on the rural edge of Crowborough, the average density of development proposed is 30dph. This would reflect the density of existing residential development in the area and would ensure efficient and effective 82 use of the allocated site area. The proposed density does however provide scope to Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

ensure that green infrastructure and biodiversity can be enhanced, as well as ensuring that access can be provided to the SANGS further south.

Pre-submission modifications

11.19 The representations received as part of the Regulation 19 consultation in June and July 2013 relate to a number of specific matters.

11.20 A number of representations were received regarding Western Road and the surrounding roads, in terms of the impact of development upon the roads and the modelling/ surveying work undertaken. These issues have been addressed by ESCC in surveys and modelling work undertaken and which confirms that the principle of development is acceptable from a highway perspective and that mitigation measures will enable the development to proceed.

11.21 A number of representations also related to the possible relocation of a church, community hall, health facility and a café on the site. This is not part of the policy and as such these facilities have not been included in the land requirements or the HRA. It is understood that some discussions have taken place between the potential developers of the site and these community interests and that some accommodation between the two parties may be able to be achieved. Whilst the potential provision of community infrastructure by developers is to be welcomed, as it is not considered necessary to require such facilities on the basis of the scale of development proposed it is not included in the policy.

11.22 Omission sites, with SANGS, outside the AONB were submitted (see Alderbrook and Steel Cross Crowborough in this section above). It was submitted that the sites would

not have an impact on Western Road. These sites have been further appraised as part 11 Land at South East Crowborough of the Sustainability Appraisal Process, but are not considered to be suitable to replace the site already identified.

11.23 The developer has submitted an alternative housing mix for the development. The final viability assessment of the Strategic Sites was completed by the Council's appointed consultants in November 2013. The study shows that minor modifications were required to policies in the PSSSLP and supporting text to enhance viability and the changes have been derived to ensure compliance with the NPPF whilst ensuring viability. The viability appraisal undertaken by the Council has meant a proposed change in the original policy, which moves towards the housing mix suggested by the developer.

11.24 A small number of changes to the policy have also been made to reflect concerns raised, to rationalise the density (already incorporated into the policy at 30dph) and to ensure consistency throughout the document, particularly in relation to SANGS provision.

83 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 11 Land at South East Crowborough Summary for Land at South East Crowborough

Land area available: 7.14 hectares

Land requirements across the site

Housing land at 30dph: 5.51 hectares

Public Open Space: 1.2 hectares

Car Park for SANGS: 0.25 hectares

Total land requirement: 6.96 hectares

Land remaining: 0.18 hectares

Constraints Commentary

11.25 A new or upgraded access for vehicles, cycles and pedestrians would be required onto Walshes Road. The existing Public Right of Way which passes through the site would need to be incorporated into the layout of the development. The location of the car park for the SANGS to the south of the site would be a constraint to development in relation to potential noise and disturbance to residential properties from its use. Existing mature trees and hedgerows on site boundaries would need to be preserved and enhanced and areas of grassland habitat would also require protection. In addition, the hedgerow on the eastern boundary of the site would need to reinforced to ensure that the visual impact of development on the wider landscape can be mitigated, and planting on the boundary with the commercial premises at Walshes Farm, would be necessary to screen the activity from new residential development. Resolution of localised transport issues in the Western Road area would be required to the satisfaction of the Highways Authority.

11.26 The surplus land area of 0.18ha should provide some flexibility for the design of the development to respond to these constraints and the also to address the requirement for green infrastructure, including the protection, retention and where appropriate, buffering, enhancement, restoration and the strengthening of existing wildlife corridors and habitats of biodiversity value, to ensure a net gain in biodiversity can be achieved on the site.

84 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

12 Land adjacent to Tunbridge Wells

12.1 The comprehensive SHLAA undertaken by the Council in 2008-2009 identified that land was suitable, available and achievable adjacent to Tunbridge Wells within the Parish of Frant. This land subsequently formed part of the broad area of search for new strategic development in this area as identified in the adopted CSLP.

12.2 At I & O stage, the opportunities and constraints of developing the land adjacent to Tunbridge Wells were identified and are summarised below. The individual site references are those used in the I & O Paper and may differ to those in the PSSSLP (see map at Appendix 10).

Opportunities

Road access - there is an opportunity to assess the traffic impact of new development with the possibility of upgrading the Benhall Mill Road/Forest Road junction. Footpath/cycle routes - there is the opportunity to retain and upgrade the existing footpath link between Benhall Mill Road and Forest Road and to incorporate this into the development with links to the new development.There may also be an opportunity to improve pedestrian footways and crossing facilities in Benhall Mill Road and Forest Road and this will help to increase accessibility, connectivity and the provision of Green Infrastructure in the local area. Reduce flood risk and surface water run off, enhance biodiversity, enhance green infrastructure network - the site presents the opportunity to incorporate a range of sustainable drainage systems, which together with creative and sustainable design layout could increase and enhance biodiversity and green infrastructure networks. Enhance the biodiversity value of the site - there is the opportunity to enhance and provide funds towards the management of the retained part of the Hawkenbury Wells Tunbridge 12 Land adjacent to Meadows Site of Nature Conservation Importance (SNCI) as an integral part of the development. This will help to improve the biodiversity and ecological value of the site. Opportunities to improve the rate and quality of discharge to water courses in line with Water Framework Directive objectives - the use of sustainable drainage systems could assist in meeting climate change objectives through reducing surface water flow and absorption, and reducing the level of run off to local streams and rivers. Opportunities to address climate change issues - the site presents good opportunities through the design and layout of the development by utilising the south facing slopes within Site A to maximise passive solar gain. The protection and enhancement of existing trees and hedge planting would assist urban cooling and carbon reduction through creating local carbon 'sinks' whilst also supporting biodiversity and the provision of green infrastructure. Development of the strategic site would be subject to Building Regulation requirements for new homes and in terms of zero carbon development by 2016 and water efficiency measures for new homes.

85 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 12 Land adjacent to Tunbridge Wells Constraints

Access to main roads - Benhall Mill Road is quite narrow to the south of Site C. In addition, there is no pedestrian footway on its eastern side from this point. Significant on-street parking on Benhall Mill Road north of this point may cause constraints to road users. It is however noted that improvements may be possible as part of the development of the site. Footpaths - the opportunity to retain and upgrade the Public Right of Way may constrain the options for the development of the site and, in particular, options for access to the site. Biodiversity - sites A and B consist of land which lies within the Hawkenbury Meadows SNCI. Since the designation of this area as an SNCI in 1991, there has been no effective management of the land. As a result, some of the features of the site which formed part of the original reason for its designation have now diminished. It is considered that part of the land within sites A and B may be retained and enhanced for biodiversity purposes and that funding may also be secured through the development for the future management of the SNCI. This could mean that the biodiversity value of this area of land may be significantly enhanced over time.. The loss of agricultural land - the development of the site would involve the loss of Grade 4 agricultural land which is currently used for horse grazing along with the small scale market gardening within site E. Open Space - the provision of open space, recreation and green infrastructure within the site to serve the needs of the future residents of the area, would impact upon the potential layout and development of the site.

12.3 The consideration of the opportunities and constraints informed the guiding principles for development of the SDA adjacent to Tunbridge Wells and these were comprehensively consulted upon within the Issues and Options exercise.

PSSSLP Policy and Site Area for Land adjacent to Tunbridge Wells

12.4 The site area identified in the PSSSLP for the strategic site at Tunbridge Wells, and the accompanying policies, have been informed by the consultation process and the constraints and opportunities identified.

Site Area

12.5 The proposed strategic site, identified as FRA in the PSSSLP, (see map at Appendix 10) measures 11.14ha and incorporates around 3.29ha of the Hawkenbury Meadow SNCI, and approximately 3.4ha of land affected by a former municipal landfill.

12.6 Although there were four options for development consulted upon in the I&O paper, the preferred option for development to deliver 120 new homes incorporates the majority of the land consulted upon, with the exception of the site identified as B in the I&O Paper. The decision to include the majority of the land was taken as there remains some uncertainty as to the extent of the usable site area of the former landfill site and the future requirement to mange the SNCI to prevent further deterioration to its ecological interest. 86 The reasons for the rejection of site B are clearly set out within the SAR for the PSSSLP. Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

12.7 Further work on the constraints to development of the site identified as site D in the I&O Paper have highlighted that there may be potential to develop on some, or all, of the area affected by former landfill, but that further investigation would be required in relation to costs to make the site safe for the occupants of any new residential development. This is particularly in relation to potential gas migration and contaminants within the soil. The costs of any requisite mitigation measures could impact on the viability of development of this part of the strategic site, due to the requirement that any land developed must not be capable of being considered as contaminated land under Part IIA of the Environmental Protection Act 1990.

12.8 The SNCI, identified as site A in the I&O Paper, is a local designation and it demonstrates that the habitat on the site, at the time of designation, was considered to be special in relation to the County of East Sussex. The habitat has degraded since designation through lack of management however this decline could be slowed and reversed. Although the retention of as much as possible of the SNCI as undeveloped land would be preferable, due to its importance to biodiversity in the area, some development in this part of the strategic site, sufficient only to allow management of the remaining SNCI, may be acceptable. The use of this land for development could be minimised by using unconstrained areas of land to the south within the strategic site in the first instance. Should any development take place on the SNCI, Policy SFR2 sets out the requirements to ensure a net gain in biodiversity can be achieved.

12.9 Other constraints to development at Site FRA include the proposed policy requirement to retain the important wooded track way linking Benhall Mill Road and Forest Road. This track separates the northern part of the site (formed of the SNCI) from the land to the south, including the former landfill site. In addition, retention of as much as possible of the existing green infrastructure within and on site boundaries would be required. This would include the retention and reinforcement of the tree lined and hedged Wells Tunbridge 12 Land adjacent to boundary with Benhall Mill Road, as well as the boundary with the railway line. Appropriate landscaping of the eastern boundary with the railway line would help to mitigate any noise impact, as well as to reinforce the important wildlife corridor existing along the embankment.

Density and Housing Numbers

12.10 An average density of around 28dph, or 119 habitable rooms per hectare, is proposed on this site. This density reflects the character of residential development in the immediate area and would also allow for the inclusion of public open space and appropriate green infrastructure throughout the site, as well as the retention of as much as possible of the SNCI land area.

Pre-submission modifications

12.11 The representations received as part of the Regulation 19 consultation in June and July 2013 relate to a number of specific matters.

12.12 A number of representations have been received from the affected landowners, which provide differing views on the land that makes up the allocation. On reflection of these comments, it is considered that the allocation should remain as per the PSSSLP. 87 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 12 Land adjacent to Tunbridge Wells 12.13 To take into account these and other comments received, the policy wording has been amended to reflect the cooperation required between Tunbridge Wells Borough Council, Kent County Council, Wealden District Council and East Sussex County Council when considering infrastructure requirements on the site. Additional changes have also been proposed to reflect Natural England’s concerns regarding the impact of the proposed development upon the setting of the AONB.

12.14 The final viability assessment of the Strategic Sites was completed by the Council's appointed consultants in November 2013. The study shows that minor modifications were required to policies in the PSSSLP and supporting text to enhance viability and the changes have been derived to ensure compliance with the NPPF whilst ensuring viability. The viability appraisal undertaken by the Council has meant a proposed change to the housing mix.

12.15 An increase in density of development from 28dph to 30dph is also proposed, and this will help to minimise the amount of land take from the SNCI required for the development of the strategic site, whilst also preserving the character of the rural edge of Tunbridge Wells in this location.

Summary for Land adjacent to Tunbridge Wells (Frant Parish)

Land area available: 11.14 hectares

Land requirements across the site

Housing land at 30dph: 4 hectares

Public Open Space: 0.9 hectares

Total Land requirements: 4.9 hectares

Land remaining: 6.24 hectares

Summary

The increase in density from 28dph to 30dph reduces the land take required to accommodate the housing from 4.28 ha to 4ha. Therefore, the total land requirement has reduced from 5.18ha to 4.9ha, leaving a remaining land area of 6.24ha (an increase of 0.28ha).

Constraints Commentary

12.16 The main constraints to development relate to the SNCI and the former landfill site. Proposed policies would require the maximisation of use of land outside of the SNCI for residential and ancillary purposes, in order to minimise the land take required of this ecologically sensitive area. However, the amount of land take from the SNCI would be dependent on further investigative works in relation to the viability and other impacts of developing the former landfill site. Around 3.82ha of the site falls outside the boundaries 88 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

of the SNCI and former landfill site, thereby requiring around 1.08ha of land take from or between either or both the SNCI and former landfill site.

12.17 Other constraints to development include the retention of existing wildlife corridors; the linear belt of mature woodland along Benhall Mill Road; the wooded track way between Benhall Mill Road and Forest Road; and retention, reinforcement and management of hedgerows on site, along with the vegetated railway corridor and trees that provide screening to the adjacent business centre.

12.18 The large amount of remaining land area (some 6.24ha) would allow for considerable flexibility in accommodating the 120 units across Site FRA. The level of remaining land should provide scope for the protection of as much as possible of the SNCI area and also to address the other identified constraints and the requirement for green infrastructure to ensure a net gain in biodiversity on the site can be achieved. Land adjacent to Tunbridge Wells Tunbridge 12 Land adjacent to

89 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) 12 Land adjacent to Tunbridge Wells

90 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013)

Appendices Appendices

91 Wealden District Local Plan Pre Submission Modifications to the Strategic Sites Local Plan Development of the Strategic Sites Local Plan (December 2013) Appendices

92 Appendix 1

Maps for each Strategic Development Area showing:

 Issues and Options site areas; and  Proposed Submission Strategic Sites Local Plan strategic site areas.

1.1 Land west of Uckfield

1.2 Land at East Hailsham

1.3 Land at North Hailsham

1.4 Land at South Polegate and East Willingdon

1.5 Land at Dittons Road

1.6 Land at Stone Cross

1.7 Land at Pine Grove

1.8 Land at Jarvis Brook

1.9 Land at South East Crowborough

1.10 Land adjacent to Tunbridge Wells (Frant Parish)

Appendix 1.1

Land west of Uckfield

Issues and Options Consultation Paper, 2012

Land available at west of Uckfield

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land West of Uckfield: Site UCA

Appendix 1.2

Land at East Hailsham

Issues and Options Consultation Paper 2012

Land available at East Hailsham

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land at East Hailsham: Sites HHA, HHB and HHC

Appendix 1.3

Land at North Hailsham

Issues and Options Consultation Paper 2012

Land available at North Hailsham

Site B Site D Site A

Danecroft Site C

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land at North Hailsham: Sites HHA, HHB and HHC

Appendix 1.4

Land at South Polegate and East Willingdon

Issues and Options Consultation Paper 2012

Land available at South Polegate and East Willingdon

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land at South Polegate and East Willingdon: Site PWA

Appendix 1.5

Land at Dittons Road

Issues and Options Consultation Paper 2012

Land available at Dittons Road

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land at Dittons Road: Sites PWB and PWC

Appendix 1.6

Land at Stone Cross

Issues and Options Consultation Paper 2012

Land available at North Stone Cross

Issues and Options Consultation Paper 2012

Land available at East Stone Cross

Issues and Options Consultation Paper 2012

Identification of Sub Areas at Stone Cross

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land at Stone Cross: Sites SCA and SCB

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land at North Hailsham: Sites SCC, SCD, SCE, SCF and SCG

Appendix 1.7

Land at Pine Grove

Issues and Options Consultation Paper 2012

Land available at Pine Grove

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land at Pine Grove: Sites CRA, CRB, CRC and CRD

Appendix 1.8

Land at Jarvis Brook

Issues and Options Consultation Paper 2012

Land available at Jarvis Brook

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land at Jarvis Brook: Site CRE

Appendix 1.9

Land at South East Crowborough

Issues and Options Consultation Paper 2012

Land available at South East Crowborough

Issues and Options Consultation Paper 2012

Idenfication of Sub Areas at South East Crowborough

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land at South East Crowborough: Site CRF

Appendix 1.10

Land adjacent to Tunbridge Wells (Frant Parish)

Issues and Options Consultation Paper 2012

Land available adjacent to Tunbridge Wells (Frant Parish)

Issues and Options Consultation Paper 2012

Identification of Sub Areas at land adjacent to Tunbridge Wells

Land allocated in the Proposed Submissions Strategic Site Local Plan

Land adjacent to Tunbridge Wells (Frant Parish): Site FRA

Published by Wealden District Council Council Offices Vicarage Lane Hailsham East Sussex BN27 2AX Tel: 01323 443322 Fax: 01323 443333 e-mail: [email protected] Website: www.wealden.gov.uk