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Representations Received at Proposed Submission Draft Stage

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Representations Received at Proposed Submission Draft Stage Response ID ANON-NRVC-BRUF-8 Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-01 22:40:05 Consultation Response Survey Part A - Personal Information A1 Personal Details Job title (where relevant): Organisation or affiliation (where relevant): A2 Client Details if applicable Title: First name: Last name: Job title (where relevant): Resident Other: Part B - Representation B1 Which part of the Soft Sand Review does this representation relate to? SSR Reference No.: SSR 1 (Chapter 7); SSR 30; SSR SSR34 and SSR35. SSR27 B2 Do you consider the Soft Sand Review to be: (tick as appropriate) Legally compliant or sound? - B2.1 Legally compliant?: Yes Legally compliant or sound? - B2.2 Sound?: No B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate) B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible. Reasons why plan is believed to be unsound and/or not legally compliant.: The town and surrounding villages are acknowledged one of the most as beautiful and historic areas within West Sussex, positioned at the foot of the South Downs National Park. In common with many market towns the local economy is fragile and sensitive to change. Currently our High Street and surrounding area is bucking the national trend, businesses are choosing to come to Steyning and open. The site just outside Steyning’s inclusion could stop or alter this trend. The proposed inclusion of the Ham Farm site as one of the identified areas for soft sand ignores the extent to which its inclusion would impact on visitor numbers and amenities for residents. It will also have an unacceptable effect on the surrounding landscape and should be withdrawn as a potential site. My representations I object to the inclusion of the Ham Farm as one of the three selected sites. This is referred to in policies: SSR 1 (Chapter 7); SSR 30; SSR SSR34 and SSR35. SSR27 (New Para 7.1.7) There are five six key guiding principles that have been used to guide the identification of the allocated sites: These are: • First principle: Places where there are opportunities to restore land beneficially, for example a net-gain in biodiversity. Ham Farm is recognised as Grade 3 agricultural land i.e. the best and the assessment notes that this seems likely to be lost in restoration. It fails this principle, no net-gain in biodiversity will be possible. SSR 27 (7.7.2.7) states the detailed technical assessment of the site has been undertaken that has not identified any overriding or fundamental constraints to the proposed forms of development on the allocated sites. I do not agree with several of these assessments, which also reflect the guiding principles The technical assessment on Soil quality is amber. I rate this using the Framework as Red • Second principle: Places without a sensitive natural or built environment and away from communities, in order to protect the amenity of businesses, residents and visitors to West Sussex. The Site Selection Report records that the site is visually sensitive in views from the top of the scarp and accepts that there will be negative impacts for users of Wiston Park. The fact that the SDNP boundary is to the south of the road indicates the value of the landscape in this area. It will be highly visible to all users of the South Downs Way and Chanctonbury Hill and its surrounding downland. These are well-known and accessible tourist destinations in the SDNP. Views at these locations are of the highest sensitivity owing to the location being within a National Park, on a National Trail and at a viewpoint destination. There are an estimated 39 million daily visits to the National Park. Extraction would include structures, movement, noise, lighting etc and cumulatively these will have a serious impact on those seeking tranquillity, peace and stunning views; the very reasons why visitors come to this area. In our opinion you have undervalued the impact at Amber. Within the immediate area of the site are Alderwood Pond, Wiston House with Wiston Park and the Cow Shed Studio, all are visitor attractions. Alderwood Pond has 45 fishing points including 4 for disabled use. This is the only fishing pond in the area with disabled access and provides facilities for several major charities. The Cow Shed Studio, immediately adjacent at Hammes Farm offer courses, exhibitions which attract visitors from a wide area. Wiston House has an international reputation as a Conference Centre. The current tranquil setting is used for Weddings, Dining, Social Events and the park hosts events such as the Steam Rally, Big Church, Concerts and other gatherings. The setting of all these popular attractions will be adversely affected. Steyning often features in articles as an attractive place to live, work and retire to and all of the local features, in particular the immediate landscape of the SDNP area are all extremely well used. The economic wellbeing of Steyning relies on attracting people to visit and initial impressions driving-by matter. The approach by road to the Steyning area from the south is already adversely impacted by the disused cement works. The proposed development of the quarry will adversely impact the approach from the west. For all the above reasons I disagree with the report’s technical assessment of Amenity as Red/ Amber and have rated this as Red. For the above considerations I am of the opinion that the assessment of Ham Farm for Landscape is should be scored Red/Amber and not Green as indicated • Third principle: The new sites should have good access to the Lorry Route Network (LRN). Access from the site to the LRN should be acceptable ‘in principle’, that is, there should not be any technical issues, with regard to highway capacity and road safety, that cannot be overcome. The Technical study for Transport and access is rated Green, indicating no highway concerns. This judgement appears to rely on the transport study arising from a planning application With approximately 96 vehicle movements – rated at 8, two way movements per hour, this seems a very crude assessment, when the rating has a strong effect as to a decision on the chosen site. In addition, the vehicle numbers are provided by the promoter. Assuming there is an even spread (which seems likely to be unrealistic) there will be a minimum of 4 vehicles turning across the traffic. This may appear minimal but with fast moving traffic it is bound to cause serious delays and increased risk of accident at busy times. This seems to ignore that removal of spoil and reinstatement in particular is likely to be in particular directions, also that this section of road has been identified as a dangerous stretch of road. The camber, flooding in the area and curves, which show straighter in any documents have not been taken into consideration. Taking these considerations into account implies that highway will need major improvements and lighting at the site entrance. (There seems some confusion in the technical assessment which refers to an addendum in October 2016 as opposed to the paper on Transport in 2019). These will impact on the visibility of the site from the SDNP and lead to a detraction in air quality which would be particularly disruptive when major events take place at Wiston Park. It will also be a departure from the current rural outlook at a point immediately before visitors enter Steyning. The technical assessment for Transport and access is Green. I refute this and for the above reasons the correct marking should be Red/Amber. • Fourth principle: The need to protect and enhance, where possible, protected landscapes in the plan area, particularly ensuring that any major minerals development will only be considered within designated landscapes in exceptional circumstances and in the public interest. The earlier comments highlight the impact on the highly sensitive views from the SDNP and national trail which are very popular as a tourist destination and residents alike. In addition, the site, as recognised in the report is only 125m from the ancient Great Alder Wood. The site is also adjacent to several listed buildings and historically important buildings: Horsebrook Cottage; the Old Rectory, buildings at Wappingthorne and importantly to the south of the Grade 1 Wiston House and a the 16th Century Barn at Hammes Farm. The development of this site, estimated to take 10 years, will have strong negative impact on all these buildings and amenities. The technical assessment of Historic environment designations is Red/Amber, which I agree with. Fifth principle: A preference for extensions to existing sites rather than new sites, subject to cumulative impact assessments. Development of this site conflicts with this principle. • Sixth principle: The need to avoid the needless sterilisation of minerals by other forms of development. There is no reason why this land would stay otherwise than Grade 3 agricultural land Conclusions Changes to the boundary of the Ham Farm site have not resulted in any amelioration of the adverse impacts on tourism. It will now have a greater frontage to the A283 and wider impact to the SDNP. The January 2020 Soft Sand Review contains several development principles relating to screening and transport, but these will not improve the impact of development from the escarpment and the National Trail. I remain of the view that the impacts on tourism have been undervalued and misunderstood.
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