Mid Sussex District Council District Plan Pre-Submission Consultation 12th June – 24th July 2015 Consultation Responses – Summary Reports Pre-Submission District Plan: Consultation Responses Consultation on the Pre-Submission District Plan was held between 12th June and 24th July 2015. In total, 299 representations were received, generating around 1,200 separate comments from individuals and organisations. Summaries of the responses received during the consultation are published within this document, broken down into separate comments. In most cases, the full text of each representation has been included, but in some instances it has been necessary to summarise each response. Each comment has been categorised and logged using the following codes or policies: Code Comment 1a Support District Plan – General 1b Object to District Plan – General 1c Factual Corrections / Typos 1d Process / Compliance with Legislation 1e Compliance with other plans/policies (including DtCO) 1f New policy area should be included 1g Maps/Diagrams including general Policies Map comments 1h Evidence Base 1i Consultation 1j Saved policies 2a Context / General 2b Vision (para 2.10) – Specific Comments 2c Challenges (para 2.9) – Specific Comments 3a Support – overall (paras 3.1 - 3.38) 3b Object – overall (paras 3.1 - 3.38). 3c General principle of development at Burgess Hill 3d Location of development 3e Delivery of strategic sites 3f Alternative location suggested for development 3g Neighbourhood Plans – principle of approach, etc 3h Economic Growth 3i Infrastructure 3j Nature and Quality of Development 3k Monitoring 3l Gatwick Airport HRA – a Support HRA – overall HRA – b Object to HRA - overall HRA – c Methodology SA – a Support Sustainability Appraisal - overall SA – b Object to Sustainability Appraisal - overall Policy Title DP1 Sustainable Development in Mid Sussex DP2 Sustainable Economic Development DP3 Town Centre Development DP4 Village and Neighbourhood Centre Development DP5 Housing DP6 Settlement Hierarchy DP7 General Principles for Strategic Development at Burgess Hill DP8 Strategic Allocation to the east of Burgess Hill at Kings Way DP9 Strategic Allocation to the north and north-west of Burgess Hill DP10 Protection and Enhancement of Countryside DP11 Preventing Coalescence DP12 Sustainable Rural Development and the Rural Economy DP13 New Homes in the Countryside DP14 High Weald Area of Outstanding Natural Beauty DP15 Ashdown Forest Special Protection Area and Special Area of Conservation DP16 Setting of the South Downs National Park DP17 Sustainable Tourism DP18 Securing Infrastructure DP19 Transport DP20 Rights of Way and other Recreational Routes DP21 Communication Infrastructure DP22 Leisure and Cultural Facilities and Activities DP23 Community Facilities and Local Services DP24 Character and Design DP25 Dwelling Space Standards DP26 Accessibility DP27 Noise, Air and Light Pollution DP28 Housing Mix DP29 Affordable Housing DP30 Rural Exception Sites DP31 Gypsies, Travellers and Travelling Showpeople DP32 Listed Buildings and Other Buildings of Merit DP33 Conservation Areas DP34 Historic Parks and Gardens DP35 Archaeological Sites DP36 Trees, Woodland and Hedgerows DP37 Biodiversity DP38 Green Infrastructure DP39 Sustainable Design and Construction DP40 Renewable Energy Schemes DP41 Flood Risk and Drainage DP42 Water Infrastructure and the Water Environment A number of responses were received on ‘Standard Forms’ i.e. forms with identical content. These are coded separately as: Code Form Lindfield Lindfield Preservation Society letter1 PRC East Grinstead Post Referendum Campaign (PRC) Form Note: technical reports/appendices may not always be included within the summary reports due to their length. All responses, in full, are available to view at the District Council offices – Oaklands, Oaklands Road, Haywards Heath, RH16 1SS. 1 Whilst a number of separate letters were received from individuals, they have been coded as a ‘Standard Form’ as all made the same comment. These related to the misapprehension that the District Plan was allocating a number of sites in Lindfield (in fact, the comments were related to the SHLAA). Submission District Plan 2015 - Consultation Responses: Individuals Ref# Comment# Respondent: 5 1 Mr R Bates Code: 3l Policy: Sustainability Appraisal? I would like to question the statement that Gatwick Airport predict 45 million passengers by 2021 when the District Plan covers a period up to 2031 Passengers figures have been published that are higher than 45 million and the plan needs to be tested on figures up to 2031 There must be implications to Mid Sussex in respect to infrastructure, housing, transport and employment on higher Passenger figures by 2031 Ref# Comment# Respondent: 412 1 Mr C Phillips Code: Policy: DP5 Object Sustainability Appraisal? Disappointed that such a large number (1,515) of the housing allocation is left to local plans and that more have not been allocated to the other towns of Haywards Heath and East Grinstead. We appreciate that the desire is for neighbourhood plans to come up with a housing allocation for each area, but given the large percentage of land in the Mid Sussex District that is not appropriate for new building because of the constraints on it, we as a parish consider ourselves vulnerable to a disproportionate share of the remaining housing allocation due to us not having any areas subject to major constraints. Ref# Comment# Respondent: 412 2 Mr C Phillips Code: Policy: DP6 Object Sustainability Appraisal? The plan refers to expansion beyond existing boundaries. Our Parish has supported the development of a Rural Exception Site outside the existing village boundary on the understanding that this did not set a precedent for building outside the village boundary. We are concerned that the precedent has been set for the village boundary to creep into the neighbouring countryside. Ref# Comment# Respondent: 6948 1 Mr A Brooks Code: 1i Policy: Sustainability Appraisal? Is not in accordance with legal and procedural requirements including the need for informed front-loaded consultation at the earliest stage. o The District Council has not consulted on this plan according to the law or fairly, and o has largely ignored representations made to the East Grinstead Area Action Plan, Core Strategy, the withdrawn draft District Plan and the East Grinstead Neighbourhood Plan by residents of East Grinstead and the surrounding villages. o There has been: Consultation Responses - Individuals Page 1 of 54 Ref# Comment# Respondent: 6948 2 Mr A Brooks Code: 1b Policy: Sustainability Appraisal? Does not provide a spatial plan that sets out “where, when, how and why” development is planned Fails to take account of the major constraints at East Grinstead and prospective isolation of communities such as Crawley Down from employment sites due to traffic congestion. Is incomplete in that o It excludes South Downs National Park. o It references a Site Allocations Development Plan Document without defining associated strategy/philosophy to be adopted in the event that additional housing is required over and above that proposed in Neighbourhood Plans. Fails to Include relevant policies to take account of the major constraints on development allowed at East Grinstead, which also impact on the surrounding area. Fails to Address known loopholes and deficiencies in the current Local Plan and associated planning system. In support, as a minimum, the plan needs to define methodologies and philosophies for • Assessment of Sustainability • Assessment of Viability and non-Viability • Objectively Assessing Housing Needs • Producing a “housing allocations document for the District” • Producing a “Site Allocations Development Plan Document” • Assessing the viability of proposed drainage solutions. • Securing infrastructure. • Remedying infrastructure deficiencies. In Summary, the pre-submission plan • Has not been properly consulted upon • Is not based on robust evidence • Is not coherent, • Is not sustainable, • Is incomplete • Has not adequately considered alternatives • Is ambiguous, and, • Fails to address fundamental infrastructure deficits. Consultation Responses - Individuals Page 2 of 54 Ref# Comment# Respondent: 6948 3 Mr A Brooks Code: Policy: DP5 Object Sustainability Appraisal? Fails to set out the distribution of housing and employment development either for the District or for East Grinstead and the surrounding villages – it is not a coherent spatial plan, neither does it reference one. It does not set out “where, when, how and why” development will take place. Para 3.29 states that ”The Plan recognises that if insufficient development is being delivered through Neighbourhood Plans, then the District Council will be required to produce its own housing allocations document for the District.” However, the Plan conveniently ignores the process by which this policy would be produced. Without an accompanying policy, and spatial plan, this statement is unacceptable and the housing policy incomplete. Ref# Comment# Respondent: 6948 4 Mr A Brooks Code: 1c Policy: Sustainability Appraisal? Include definitions, methodologies and applicable philosophies throughout, to remove the current inherent ambiguities and ensure repeatability/integrity of assessments. Ref# Comment# Respondent: 6948 5 Mr A Brooks Code: 3i Policy: Sustainability Appraisal? Fails to set out clear development principles to provide essential infrastructure to support any further development in the North of the District in a timescale appropriate