Response to Sites Allocations Dpd Regulation 19 Representation Form
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RESPONSE TO SITES ALLOCATIONS DPD REGULATION 19 REPRESENTATION FORM Part A – Our Details Name Paul Tucker On behalf of Infrastructure First Address 2 Leybourne Place Felbridge East Grinstead West Sussex RH19 2PW Email Address [email protected] Part B – Our Comments Organisation Infrastructure First Our comments relate to: Site Sustainability Habitats Regulations Allocations DPD X Appraisal X Assessment Community Equalities Impact Draft Policies Map Involvement Plan X Assessment Infrastructure First Group Regulation19 Representation Site Allocations DPD We consider the Site Allocations DPD is … In accordance with legal and procedural Yes No requirements, including the duty to cooperate? X Sound? Yes No X We consider the Site Allocations DPD to be unsound in the following areas ... Sound Unsound Positively prepared X Justified X Effective X Consistent with national policy X No, I do not wish to participate Yes, I wish to participate at at the oral examination X the oral examination We are seeking a change to the Site Allocations DPD and would like to attend and give evidence at the oral part of the examination. The Infrastructure First Group takes a responsible attitude to development. It is advised by Wedderburn Transport Planning on highways issues, and, by Mr. Juan Lopez on legal issues. Given its remit and level of community support, the Infrastructure First Group considers it appropriate that it should be kept informed of the council’s response to the consultation and should be invited to participate in the public examination. Continued over … Page 2 of 26 28 September 2020 Infrastructure First Group Regulation19 Representation Site Allocations DPD The objection to the site Allocations DPD, Sustainability Appraisal and associated documents consists of the formal response form and the professional advice of Wedderburn Transport Planning which is contained in this report and which forms an integral part of the response. However, given that significant areas of uncertainty exist – particularly though not exclusively in relation to traffic data and their interpretation – as a result of the lack of provision of key information either in full or in part during and before the consultation, the Infrastructure First Group reserves the right to submit additional responses as and when additional information becomes available. About Infrastructure First Infrastructure First is a residents group concerned with ensuring that development in East Grinstead and the surrounding villages is sustainable and enhances the various settlements. We do not oppose sustainable development and support the East Grinstead Neighbourhood Plan. Infrastructure First has built on the experience and legacy of earlier local groups involved in planning notably the East Grinstead Post Referendum Campaign (PRC) which made representations on planning matters following the 2003 referendum against the District Council’s scheme to build 2,500 homes proposed on a mixed-use development on Imberhorne Farm. This was advanced by MSDC through an Area Action Plan and the PRC was able to assist the Council by exposing the unresolvable flaws in the proposal that led to the Council abandoning it in 2010. Many of the issues evaluated during that process remain valid when considering the latest proposal to develop land at East Grinstead and Felbridge. In the absence of an effective programme being run by MSDC to inform the local residents of the current consultation Infrastructure First has set up a website and distributed leaflets to households to enable them to make their views known. https://www.infrastructurefirst.co.uk Page 3 of 26 28 September 2020 Infrastructure First Group Regulation19 Representation Site Allocations DPD Firstly this response sets out why we consider that the Council has not met the Duty-to-Cooperate or its own Statement of Community Involvement. As such the DPD and associated documents are not considered legally compliant and should be withdrawn. This response focuses on objections to the site allocations proposed at East Grinstead and Felbridge that will add a further 722 homes to those already committed via the local development plan and through windfall developments. We consider that these proposed additional allocations at East Grinstead and Felbridge are not sustainable and should be replaced by other sites that are, located nearer to Crawley but which the Council has chosen not to evaluate. These sites nearer to Crawley are deliverable in the mid-term and would offer flexibility to the District Plan which is due to be reviewed in 2021, when it is likely to be required to accommodate more overspill housing from Crawley following the emerging reviews of the Horsham and Crawley Local Plans. We consider that the submitted draft DPD is not sound and should be withdrawn for further work to be completed. MSDC has attempted to develop the broad location between East Grinstead and Felbridge before and their failure to deliver resulted in the Council’s failure to deliver the District Plan which was originally due to be adopted in 2010. We also contend that the Council has not followed due process and so the draft DPD is not legal. We do not consider that the Council has followed due process in producing this DPD. We consider that it has failed to adequately engage with the public and that it has not adhered to the principle of front-loading consultation. There is no unmet need to make up in Mid Sussex in general and specifically none at East Grinstead. The allocations proposed at East Grinstead are to meet Crawley’s unmet need. Therefore, proposed allocations need to be shown to be i) sustainable in themselves and ii) the best solution to meet the unmet need at Crawley, some 13 km distance from East Grinstead, along the congested A264 corridor. We argue that neither criteria is met by the proposals in the draft Site Allocations DPD. The sites at East Grinstead are not sustainable and should be removed from the DPD and the Council needs to revisit sites abutting Crawley, that are sustainable, that could be delivered and would better meet the requirement to provide homes to meet Crawley’s unmet need. Page 4 of 26 28 September 2020 Infrastructure First Group Regulation19 Representation Site Allocations DPD We also consider the Sustainability Appraisal is superficial, inaccurate in places and fails to consider all reasonable potential sites. We set out our arguments for this in Appendix C. 1. Background The Site Allocations DPD is necessary because the District Plan, adopted in 2018, was built up from the various Neighbourhood Plans produced across the District, and so did not identify sufficient sites to deliver the share of unmet housing need for Crawley post 2023/24, identified, for Mid Sussex to accommodate, by the Inspector at the District Plan Examination.1 This DPD is an interim measure being produced ahead of the review of the District Plan in 2021.2 It is clear from the reviews being undertaken by Horsham and Crawley into their Local plans that it is likely that Mid Sussex, like Horsham, will need to accommodate more housing to meet Crawley’s expansion. The DPD does not address this point since none of the site allocations proposed offer any possibility of further expansion. There is no built-in flexibility. Since the main objective of this DPD is to meet unmet need at Crawley, it is perplexing that MSDC has chosen to either ignore completely, or dismiss without evaluation, sites that are closer to Crawley which could offer a substantial quantum of development and that would neither require increased car journeys nor overload the existing infrastructure as would sites at East Grinstead and Felbridge, or pose a risk to Ashdown Forest, that needs mitigation. 1.1 High risk strategy On the evidence available, the quantum of development proposed in the draft Site Allocation DPD between East Grinstead and Felbridge cannot be delivered sustainability and the strategy being put forward is high risk. Furthermore, these locations are, at best, sub-optimal in addressing the requirement that Mid Sussex must deliver 1,500 additional houses to meet the expected unmet need of Crawley Borough from 2023/24. Mid Sussex have introduced an unnecessary and unwelcome lack of flexibility to the Mid Sussex spatial plan, that runs contrary to national planning policy by discarding potential sites closer to Crawley without evaluation. 1 The submitted draft District Plan had underestimated the OAN for Mid Sussex and also failed to recognise or accommodate that unmet need for Crawley. During the Examination the housing requirement was significantly increased. 2 Local Development Scheme June 2019, “The Mid Sussex District Plan 2014 – 2031 also includes a commitment (Development Policy 5: Planning to Meet Future Housing Need) to undertake a review of the District Plan commencing in 2021” Page 5 of 26 28 September 2020 Infrastructure First Group Regulation19 Representation Site Allocations DPD Under the current draft Site Allocations DPD the ability to meet the Mid Sussex housing requirement would rely on delivering sites at East Grinstead and Felbridge in the same (or very similar) locations to those that the Council previously failed to deliver under the East Grinstead Area Action Plan DPD [EGAAP] scheme. The failure to find a way of developing that mixed-use strategic location at “Imberhorne” through the EGAAP process, despite the expenditure of considerable resources and the inclusion of an expensive multi-modal transport study [MMTS], led directly to the recently adopted local plan (District Plan) arriving ten years late and the failure of the Council to operate a plan-led planning system from 2008 to 2018 (as is required by national planning policy). MSDC had argued that to deliver the 2,500 mixed-use strategic development under the East Grinstead AAP, £120m at 2006 prices (£175m today) was needed to fund the necessary infrastructure. For the SA19 and SA20 the Infrastructure Delivery Plan lists infrastructure spending of less than £21m.