East Grinstead Society

Strategic Housing Land Availability Assessment

The Society’s letter to MSDC commenting on the Strategic Housing Land Availability Assessment (SHLAA) is shown below. In brief we think that the SHLAA should be extended to enable comparison of sites across a range of key indicators including public transport, rail accessibility, road infrastructure, site locations’ effect on commuting and traffic congestion, future employment, protected areas, A & E accessibility and listed building proximity. Recording those indicators in a consistent way to facilitate comparison.

The cumulative effects on road capacity and infrastructure generally of developing a number of sites in the town area to be quantified.

The East Grinstead Society
Registered Charity No. 257870

COMMENTS ON THE INTERIM SHLAA – April 2009

Introduction

The EG Society welcomes the opportunity to comment on the interim Strategic Housing Land Availability Assessment (SHLAA) issued by MSDC in March. We understand that the SHLAA is intended to lead to a revised Core Strategy and a future site allocations document to balance the relative merits of sites.

If that understanding is correct then we feel that the SHLAA needs to be more than a listing of potential development sites in the area. It needs to be capable ofcomparing sites objectively; and be able to bring out the cumulative effects on infrastructure of multi-site development. At present the SHLAA does neither. Unless these elements are available we do not see how a Core Strategy and future sites allocation document can be sustainable and credible.

Small to medium sites in East Grinstead

At East Grinstead most sites, (some 70 or so in the “Schedule of identified sites considered through the Assessment”), are in the built-up area of the town and therefore no doubt classed as ‘brownfield’ and potentially suitable for development. However, we doubt that the town could absorb anything like that number, notably because its road infrastructure is already inadequate. Consideration of SHLAA sites within the town should therefore take into account the effects of ‘site accumulation’. Measures to reduce existing congestion (by junction improvements and the like) and also to cope with further development building should be in place before decisions are taken as to sites for development.

Greenfield and strategic sites in the north area

Greenfield sites are identified in the interim SHLAA at the south-eastern side of East Grinstead. Both No. 17 (Land adjacent Great Harwood Farm House) and the smaller No 255 (Boyles Farm) are in the High Weald Area of Outstanding Natural Beauty. We are aware that for planning purposes AONB development may be considered in special circumstances but these are not mentioned and both sites should therefore be excluded.

In addition to potentially bad cumulative effects consideration of larger sites should take into account their comparability if a fair and economically sound result is to be reached. The larger greenfield sites in the Countryside Area of Development Restraint to the west of East Grinstead (No 50 Land to the west and south-west of EG, No 248 Land at Imberhorne Farm and Hill Place Farm, No 249 Land west and south-west of EG and adjacent smaller sites) are not, with the present SHLAA methodology, capable of being compared with other large greenfield sites elsewhere in the north of Mid Sussex.

Comparability of information

Large site consideration should be based on the recording of key indicators in a consistent way to enable site comparisons to be made objectively. We think that the present recording method, to be used in due course for the preparation of a Core Strategy and future site allocations document, will fall short of Government intentions in PPS3:Housing. This we assume will require reliable data for assessing the developability and deliverability of large sites.

Thus the interim SHLAA should we believe be enhanced so that information about large sites in particular can be recorded consistently and comparable as between one site and another. The following are some of the key indicators to be presented to facilitate comparison:

Public transport – sustainability, constraints and realistic expectations of take-up;

Rail accessibility – north, south and to major centres

Road infrastructure – requirements and constraints on provision

Site locations – impact on commuting and traffic congestion

Future employment availability, constraints and accessibility

Protected areas – closeness to and effect upon the Ashdown Forest ancient woodland, SNCI etc

A&E/trauma units – accessibility, drive time in rush hour

Listed building proximity

Examples where comparative data needed

In north Mid Sussex, data recorded on the proposed site at Crabbet Park is difficult to compare with other large sites. None of the data presented can be directly compared with the same factors of other sites of similar size. It may be that the disadvantages of other sites are less than those for Crabbet Park, or vice versa, but the present methodology makes it impossible to tell.

Assessments of several sites mention the presence of listed buildings as a significant constraint on development. However, the listed building status of Gullege is not recorded as a possible disadvantage of the site in question. Instead it is mentioned as offering a useful natural boundary to development.

As to infrastructure the practicality, costs and potential damage to protected areas as a result of road building and other road changes in different areas need to be presented as capable of comparison. Also car mileage comparisons should be available in comparing future site allocations.

Equally demanding of comparison is rail accessibility. In this respect the East Grinstead position has not been compared with other major sites. We have said before that the London to East Grinstead line stops there with no link westwards to Crawley, whereas other settlements in the area have direct access south to the coast, to London and to the regional employment hub at Crawley. We think that rail accessibility and destinations are key indicators when comparing the economics of large sites.

The interim report indicates that sites may be excluded from consideration but exclusion criteria are not made clear or consistently applied. For instance the report excludes some but not all sites if they are in the AONB.

Summary of main points

The SHLAA should be extended to enable the objective comparison of sites across a range of key indicators. As part of this process identify and record these indicators in a consistent way

The cumulative effects on road capacity and infrastructure of developing a number of sites in the town area should be quantified. The potential for improvements to reduce traffic congestion to be measured.

John Bridle, Vice-chairman
The East Grinstead Society 28th April 2009