LEWES DISTRICT AND SOUTH DOWNS NATIONAL PARK AUTHORITY LEWES DISTRICT JOINT CORE STRATEGY INDEPENDENT EXAMINATION

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1 1 LEWES DISTRICT AND SOUTH DOWNS NATIONAL PARK AUTHORITY LEWES DISTRICT JOINT CORE STRATEGY INDEPENDENT EXAMINATION STATEMENT BY CROUDACE STRATEGIC LIMITED ISSUES 7 AND 8 STRATEGIC SITES (POLICIES SP5/SP6) 1.0 Introduction: 1.1 (PPC) is instructed by Croudace Strategic Limited (part of the Croudace Group of Companies). Croudace is a family owned company with over 60 years of experience of delivering high quality residential development. 1.2 Croudace has an interest in land at Broyle Gate Farm, Lewes Road, Ringmer and has been promoting the land for a mixed use development of housing and open space/leisure/sports thereby delivering much of the original objectives of saved Local Plan Policy RG3. A planning application has recently been submitted to Lewes District Council for the proposed development. 2.0 Issues 7 & 8: (i). Are the policies and proposals for growth and changes in these areas appropriate and reasonable, including in relation to the NPPF and PPG, and in terms of environmental, economic and social impact? 2.1 The allocation of the strategic site in draft Policy SP5: Land North of Bishops Lane, Ringmer is objected to. This is because the site is not the most appropriate or sustainable location for a strategic site in Ringmer. Firstly: 2.2. The starting point is to note that Croudace supports the identification of one or more strategic sites in Ringmer. This is because after the main urban areas Ringmer is recognised as being the next largest settlement in the district and lies outside the SDNP. The capacity of the village to accommodate additional growth, beyond just meeting local village needs, well established. 2.3 The September 2011 Emerging Core Strategy consultation document (CD025) noted that Ringmer was classed as a Rural Service Centre, suitable for delivering a minimum of 100 dwellings, and concluded that Ringmer has significant development potential, as evidenced by the SHLAA, and that the potential for new development was significantly in excess of 100 dwellings, and that:

2 2 Therefore, a decision would have to be made as to whether Ringmer delivers a level of housing that meets a wider District housing need. 2.4 We consider that the district has greater capacity to absorb additional housing than is set out in the draft LP, in locations such as Ringmer, and that a housing target closer to the OAN is realistic and achievable. 2.5 Similarly, the Rural Settlement Study January 2013 Version 2 (CD091) states in paragraphs to 19.48: Ringmer scores highly in terms of the number of services and facilities and is one of only three villages in the district that has all the key services. In addition its close proximity to Lewes and the frequent bus service further enhances its role as a sustainable settlement Ringmer also appears exceptional in the volume of employment opportunities that it has to offer and those of nearby Broyleside The designation of the land west and south of the settlement within the National Park is likely to constrain development in these areas on landscape grounds; however there may be opportunities for development to the north and east of the settlement. 2.6 Further, the allocation in draft LP Policy SP2 of a minimum of 220 additional dwellings to Ringmer/Broyleside is objected to. It has been established through the Rural Settlements Study (CD091) that after the main urban areas, Ringmer is the next largest settlement in the District, provides a wide range of shops, service, local facilities and a particularly good employment offer and is sustainably located close to the County town of Lewes. The SHLAA (Table 6: CD097) identifies a capacity of almost 600 additional dwellings, on sites which are considered to be deliverable. 2.7 Given the findings of paragraphs 4.1, 4.4 and 6.3 of the Duty to Cooperate: Statement of Common Ground Cross-Boundary Working and Meeting Housing Needs (e.g. LDC version CD0029) which state: 4.1. Despite extensive work, the Council and SDNPA consider that, due to extensive and well documented environmental and infrastructure constraints, objectively assessed housing needs in Lewes cannot be met within the sustainable development requirements of the National Planning Policy Framework As to date, neighbouring authorities and those authorities making up the Sussex Coast HMA have been unable to identify any potential help to meet Lewes district s housing needs, broader strategic housing areas and routes to more innovative solutions for meeting the collective strategic housing need have been explored and implemented.

3 The study concludes that the Sussex Coast HMA is highly unlikely to be able to deliver the full level of required housing development in light of the significant environmental, landscape and infrastructure constraints to development which exist. there is plainly no logic or sound planning reason for not making maximum use of the identified deliverable SHLAA sites in the Ringmer Rural Service Centre and, indeed, the lack of alternative suitable, available and achievable sites in the district makes a compelling case for Ringmer making a greater contribution towards meeting the district s OAN (i.e. over and above just meeting local village needs). 2.8 The only evidence we find relating to why Ringmer could not satisfactorily accommodate the SHLAA capacity of around 600 dwellings on deliverable sites is found at paragraph of the Justification for the Housing Strategy May (CD045) which states: the main constraint to the outward expansion of Ringmer is the boundary of the National Park, which is drawn tightly around the southern and western edges of the built up area. Outside the National Park, the 2013 SHLAA identifies capacity in the village for a further 380 additional dwellings above the planned growth of 210 dwellings. However, this level of growth would result in substantial harm to the rural character and setting of Ringmer, in conflict with the vision and strategic objectives of the Core Strategy. However, no explanation is provided to describe or quantify the nature of the alleged harm to the rural character and setting of Ringmer or in what ways such development would offend the vision or the strategic objectives of the plan. 2.9 This view contrasts starkly with the findings of the Rural Settlement Study January 2013 Version 2 (CD091) Croudace therefore considers that there is a strong case for Ringmer contributing up to around 600 additional dwellings in the period and that the additional housing numbers (i.e = 380) be made up, in part, by one or more additional strategic sites An example of a suitable additional strategic site is the Land at Broyle Gate Farm, Ringmer (SHLAA site 01RG), which is suitable, (readily) available and deliverable (i.e.in the early part of the Plan period) and which could deliver both housing (including affordable housing), and significant benefits for the community in the form of additional open space, sports and recreational facilities. Further details about this site are set out in our Issue 15 Statement.

4 4 Secondly: 2.12 The allocation of Land to the North of Bishops Lane, Ringmer is contingent upon the Ringmer Neighbourhood Plan not being made before the adoption of the LP, or that it (i.e. the NP) does not allocate sufficient sites to deliver 100 additional units by Firstly, a contingent approach is objected to in principle. Either land is allocated in a LP or it is not. Secondly, a planning application in respect of this site was recently refused planning permission by Lewes District Council as being premature pending the Neighbourhood Plan: The proposed residential development would undermine the emerging Ringmer Neighbourhood Plan which plans for the community to get the right types of development and positively supports Ringmer s strategic development needs. It is assumed that this refusal will be progressed to Appeal, at which all matters will be at large before the Inspector. As such, at present, the deliverability of this site is in question In addition, the land north of Bishops Lane is not the most sustainable or appropriate site in the village. The site is accessed via a narrow country laneway, is distant from the public transport and can deliver none of the community advantages/benefits to the village that the Broyle Gate Farm can provide In contrast, Croudace s proposals for the Broyle Gate Farm site are for an integrated comprehensive mixed-use development comprising housing (including affordable housing), open space, leisure and sport facilities, as an extension to Ringmer village, adjacent to the Community College. The site is sustainably located and can deliver both new housing (including affordable housing) and much of the open space, leisure and sporting facilities the village needs. The siting of these facilities, in immediate juxtaposition to the Community College campus, is undoubtedly sound in planning and sustainability terms. The Broyle Gate Farm site is the only site in the village that can offer these planning/community advantages. A development of at least 75 dwellings is needed to make the provision of the new open space, leisure and sports facilities viable, and can be accommodated on the site without any adverse impact on the separate identities of Ringmer and Broyleside, or to the village-feel of the communities. The provision of the much-needed additional open space, leisure and sports facilities will positively contribute towards improving and reinforcing the sense of community, health and well-being of the village It is relevant to note that the Land North of Bishops Lane cannot deliver any of these community benefits.

5 Further, in considering the views of the community it is relevant to note that significant support has been voiced by the local community in support of the Croudace proposals, on more than one occasion. The Parish Council accepts this - see paragraph of Appendix A to the draft Neighbourhood Plan i.e. that the Croudace proposal was relatively strongly supported at consultation meeting 7. Indeed, it is relevant to note that Paragraph of Appendix A understates the support expressed by respondents at Consultation 7. The archive of the Neighbourhood Plan evidence-base records that in Consultation 7 a total of 104 people responded to Area 1 (i.e. Broyle Gate Farm). Of the 104, 78 people considered that the site was the best site or a possible site i.e. 75%. Only 25% said no to the site. Further, at a Community Involvement Exercise held by Croudace in July, 61% of respondents to the question Do you think the site is suitable for a Mixed-Use development of housing and open space/leisure supported the proposed development; 2.17 There is plainly strong support for the Croudace proposals amongst many local people Croudace considers that the site should be allocated either as an alternative to the Land North of Bishops Lane or in addition to that allocation, for the reasons set out above, in terms of both the role of Ringmer in meeting the district s OAN, and in relation to the obvious advantages of the site. Thirdly: 2.19 In relation to the environmental, economic and social impact of the policies and proposals for growth, as set out in the draft LP, there are clear implications for both Ringmer and the district as a whole of not meeting the district s OAN for housing Paragraph 7 of the NPPF explains that there are three dimensions to sustainable development an economic role; a social role and an environmental role. Paragraph 152 of the NPPF states that in plan-making, Local authorities should seek opportunities to achieve each of the economic, social and environmental dimensions of sustainable development, and net gains across all three Policies SP5 and SP6 of the draft LP fail in relation to all three dimensions of sustainable development This is because failing to meet the OAN for housing in the district with have negative economic effects i.e. in relation to the essential balance between jobs and homes and will result in making the district a less desirable location for businesses to relocate to and will result in a continuation of the levels of out-migration for work There is also a more local effect and example in the case of Ringmer. Paragraph of the Rural Settlement Study (CD091) notes that Ringmer appears exceptional in the volume of employment opportunities it has to offer and those of nearby Broyleside. To fail to provide housing close to where jobs can be created is not a sound approach in planning terms.

6 In relation to the social role, the draft LP and Policies SP5 and SP6 (because of the lack of allocation of sufficient strategic sites, fail to meet the Vision of the LP and LP Objective 3 (CD001). Not meeting the district OAN for additional housing will result in house prices increasing and the failure of the LP to provide adequate affordable housing. This in turn will make local housing unaffordable for young people from the local area Further, in the case of Ringmer, the non-allocation of the Land at Broyle Gate Farm denies the village the additional open space, sports and leisure facilities it needs (i.e. as recognised in paragraph 6.89 of the draft LP (CD001), and which could be delivered by the proposed Croudace development. As such the draft LP conflicts with advice on Promoting Healthy Communities in the NPPF, in particular paragraphs 69, 70 and In relation to environmental impacts, the allocation of additional strategic sites, whilst by necessity would result in releasing additional green field land, this would not necessarily have environmental impacts which were not capable of being minimised and/or satisfactorily mitigated in achieving an appropriate balance between the need to meet the housing needs of the area and protecting the most sensitive designated landscapes, such as the National Park, SSSIs etc. (ii). Are they clear and deliverable, including in respect of the associated infrastructure needed? 2.27 Croudace has no comment to make in relation to the Policy SP6 site at Harbour Heights, Newhaven save and except to observe that part of the site has been allocated in the Lewes Local Plan since 2003 (Policy NH8) and has failed to come forward for development, despite the current severe housing land supply shortage (i.e. just 1.66 years CD042a), this must give rise to questions why the site has not been developed. In addition, paragraph of the LP refers to the need for highway mitigation measures because the proposed development is acknowledged to have adverse impacts on the A259. Further information on the necessary measures and whether they would have any effect on scheme viability would be helpful in the draft LP In relation to the Land North of Bishops Lane, Ringmer (Policy SP6), notes that the site suffers from drainage problems and that a surface water strategy will need to be prepared and approved. It is considered that the main access to the site from a narrow country lane is far from ideal, and that improvements will be also required at the Earwig Corner junction between the B2192 and the A26. These issues should be resolved prior to the site being included as an allocation in the draft LP, as not to do so must bring the deliverability of the site into question. END 2,508 words

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