East Grinstead Society

Letter to Mid Sussex District Council regarding the Mid Sussex District Plan 2014-2031

Dear Sirs,

Further Comments on the Mid Sussex District Plan 2014-2031

We would like to make our comments on the Pre-submission Draft issued in June 2015. Some of these are a repetition of those made in 2012, 2013 and 2014 to earlier drafts of this document but they still apply and are worth repeating. In addition there are some new points to raise in respect of the latest draft.

We wholeheartedly agree that Mid Sussex is an attractive place to live, work and visit but this very attractiveness introduces some local development constraints which are peculiar to the area in general and East Grinstead in particular.

The uncertainty concerning housing numbers and potential sites in this Draft means that we cannot make detailed comments on those aspects of the plan as they affect East Grinstead but there is one fundamental point to be made. Future infrastructural improvements are dependent on Community Infrastructure Levies and section 106 and section 278 contributions from new developments. This ignores the infrastructure deficit which has arisen, particularly in East Grinstead, from housing developments which have outstripped the local infrastructure improvements required to sustain them. This has worsened the situation for existing inhabitants of the town. As the road network is already incapable of dealing with the current traffic flows there will be even greater problems as further developments are approved by MSDC before the District and Neighbourhood Plans  are finalised  and officially approved. Evidence for this is provided by the recently completed Jubb Report on the road network in and around East Grinstead which confirms how bad congestion has become. It also demonstrates that the position has worsened further since the Atkins and MTRU reports in 2012.

There is a brief acknowledgement in the draft plan of the problems along the A264/A22 and the reference to the infrastructure deficits in sewerage and water supply, transport and open space and sports/play provision but no indication how this shortfall will be made up. It is unrealistic  to expect that provision for eliminating this deficit will be made by future developments. The shortfall is also acknowledged in the evidence base for DP6, the Settlement Sustainability Review, which makes reference to the severe traffic problems at East Grinstead.

In view of East Grinstead’s particular road congestion problems we suggest this should be addressed in ‘The Challenge Facing the District’. The fourth bullet point, second sentence of paragraph 2.9, should be extended to read ‘’East Grinstead in particular has acknowledged congestion problems along the A22/A264 to the extent that future development will be limited to town centre renewal and brown field development unless and until A22/A264 junction improvements have been made’’. Similarly, Policy DP5:Housing should include this housing limitation in East Grinstead’s development proposal. This would then be in conformity with Strategic Objective 6 ‘To ensure that development is accompanied by the necessary infrastructure in the right place at the right time that supports development and sustainable communities. This includes the provision of efficient and sustainable transport networks’’.

In view of these ongoing traffic problems without any suggestion within the District Plan as to how the historic infrastructure deficit is to be addressed it seems inappropriate to place East Grinstead in the same Settlement Hierarchy category as Burgess Hill and Haywards Heath as the likely recipient  of futher housing demands should the District’s offering prove insufficient to central government.

Currently there appears to be an open season on housing developments in East Grinstead yet the planners are not even insisting on proper contributions from developers towards the congestion that will result nor on proper proportions of affordable housing. We cite the development at the Old Convent as an example of this. It is all very well detailing Priority Themes and Strategic Objectives but problems brought forward must be addressed.

We note that the draft plan makes no assumptions about the possible expansion  of Gatwick Airport other than assuming the current position of no changes until 2019 is maintained. If there were to be changes after that date then obviously the whole plan would have to be reappraised fundamentally.

With regard to the specific policies in the document we support the principles of DP10 and DP11. There should be a presumption against development outside existing town built-up boundaries to prevent coalescence with neighbouring settlements. In East Grinstead there is currently a threat of creeping development towards both Turners Hill and Crawley Down. The  strategic gaps must be maintained so we suggest that DP11 should be amended to comfirm that development will only be permitted if it does not contribute to or result in coalescence.

Similarly, policies DP14 and DP15 are of importance to East Grinstead provided the SANGS and SAMM are administered robustly and developers are not allowed to water-down their obligations as have occurred with some section 106 agreements in East Grinstead.

Securing Infrastructure, DP18, should be extended to deal with the  existing infrastructure deficit. The constraints on development in East Grinstead because of the closeness to Ashdown Forest and the High Weald Area of Outstanding Natural Beauty mean that likely CIL payments  and section 106 agreements will be insufficient to pay for both future infrastructure needs and the deficit brought forward. The same comment applies to DP19 regarding Transport. Should Gatwick expansion go ahead, of course, the whole transport network would have to be re-examined as there is no way that the vastly increased east/west traffic flows to the enlarged airport and the implications of tens of thousands of incomers moving into the area could be catered for by the existing road system.

DP22 relates Facilities and Activities including, inter alia, informal leisure space. This seems very sensible but when one turns to Appendix C one of the previously saved local policies ,EG18, has now been omitted. This was saved in the 2004 Mid Sussex Local Plan and included the green space at the junction of Blackwell Farm Road and Holtye Road. This site, owned by MSDC, was the subject of a planning application. We had the ludicrous situation whereby the Solicitor to the Council proposed to appropriate the land, which was acknowledged to be an open space, to planning purposes so that MSDC, the planning authority, could give MSDC, the developer, permission to put houses on the site.. It should have remained an informal open space and calls into question the purpose of saved local policies.

We support the Council’s inclusion of Local Green Spaces (paragraph 3.18) in the allocation of land in the District Plan. We think this initiative could go further to indentify in the District Plan green spaces valued by local communities for protection from development. See Policy DP38 suggestion below.

We welcome policy DP23 but regret this did not  include protection of the Wallis Centre as there is no duplicate facility in the locality. There is insufficient  alternative accommodation within East Grinstead to house all the groups and youth project work that used the Wallis Centre.

In general we support DP24 to DP30 but regret that on some recent planning applications the 30% minimum for affordable housing provision has not been met. We support the 30% affordable housing threshold. Regarding DP31 we approve the policy but would ask why the proposed scheme at Imberhorne Lane Nurseries is still under discussion when it does not seem to comply with current Government guidelines nor with those which are proposed for the draft plan going forward?

DP33 comfirms the protection of Conservation Areas. This is of particular importance to the inhabitants of East Grinstead with its historic High Street and associated portlands. We are surprised that EG2 which specifically referred to the Portlands has now been omitted from the local saved policies listed in Appendix C. The saved policy should be reinstated as protection of these areas is of fundamental importance to the Town.

We fully support policy DP38 ‘’to create and maintain easily accessible green infrastructure, green corridors and spaces within towns to act as………recreational routes’’ but we think that the strategic objective should include, specifically, protection from development green spaces valued by the commmunity. These should be specified in the District Plan in order to protect them from future development for the future of residents. This Society is currently carrying out a review of green spaces in and around the town which we would be pleased to provide for inclusion in the Plan. This review included the green space at the junction of Blackwell Farm Road and Holtye Road referred to above.

While not  a green space as such we would welcome the continuation of the saved policy EG2 brought forward from the 2004 Local Plan. The  Portlands form an important part of the Conservation Area  of our historic town centre and should remain protected from any form of development in perpetuity. This is currently under threat and is so fundamental to the origins of the town that we think it should be carried forward specifically.

Finally, we emphasise the importance of DP42, Water Infrastructure and Water Environment. Obviously, until housing numbers are known there cannot be any definitive comments but the Council must be certain that sufficient resources are available before proposing any specific housing numbers. The same applies to all the other infrastructure requirements for a 21st century district.

Yours faithfully,

 

N J Beale

Chairman