MSDC Developments
MSDC DEVELOPMENTS NEIGHBOURING FELBRIDGE
DM/23/2699 LAND SOUTH AND WEST OF IMBERHORNE UPPER SCHOOL
Felbridge Parish Council's response to this initial planning application has been uploaded below
LATEST ON PROPOSED BARRATT HOMES 200 HOUSE DEVELOPMENT ON CRAWLEY DOWN ROAD - DM/23/0810
!! LATEST - Felbridge Parish Council's latest response dated 2nd February is uploaded below !!
The key paragraphs are:
Felbridge Parish Council strongly believe that both SA19 and SA20 allocations should be considered together by the Local Planning Authorities. In its current form, SA19 could be approved with no mitigation of its impact upon the Star junction; this would then prevent the SA20 site from being approved due to the lack of capacity at this critical junction as a result of the un-mitigated SA19. This would be despite the fact that the larger SA20 site includes improvements to the Imberhorne Lane junction and the northbound approach to the Star junction which would provide some mitigation.
In all, this proposed development has not met the DPD Inspector’s requirement to mitigate its highway impact. This is the conclusion of the Surrey County Council Highway Authority and therefore provides a sound justification for refusal of this proposal by the Local Planning Authority as this fails to meet the DPD Inspector’s requirements for transport mitigation to be to the ‘satisfaction of both Surrey and West Sussex County Council Highway Authorities’.
EVIDENCE OF FLOODING ON PROPOSED SITE:
FPC have again written to the Environment Agency copied to MSDC with further evidence of flooding overnight on 2nd November which resulted in flooding within the site and on the Gullege Bridleway running between the two fields. It was noted that while there was heavy rain through the early hours of 2nd November, Felbridge was not badly affected by Storm Ciaran. There was standing water in the usual places on roads but no flooding, no trees down, no issues with power or utilities and all schools and businesses remained open. THE FULL DOCUMENT INCLUDING DRAWINGS AND PHOTOGRAPHS CAN BE DOWNLOADED BELOW
EA Ref: HA/2022/124189/04-L01 Further to our letter dated 16th October 2023. A local resident has sent us an additional set of flood images showing an even higher flood level than previously photographed. Again, it is unlikely that the photographs were taken at the peak extents of the flooding. Appendix 1 includes the photographs of the event and the same view taken at 2pm on the same day, the significant drop in water level in a period of only a few hours indicates how transient the flooding at this location is and thus this reduces the likelihood that any photographs are taken at the actual peak of the flooding. The later photographs were used to identify the actual level the water extended to and measure this back to the telegraph pole on the north side of the bridge as a geofixed location. This showed that the photographed flood extent on the bridleway was 11.7m north of the telegraph pole and 16.4m to the south. These positions marked onto the applicant’s drainage plan is shown below as figure 1.
The 1 in 100-year flood zone extent shown on the above plan is 38m along the bridleway (ignoring the drainage gullies along its eastern side). As previously stated, the 20-year modelled flood extent is about 10m. Thus, the flooding extent photographed on 2nd November 2023 at 28m is far closer to the 100-year event than it is a 20-year event. We also draw your attention to the photograph below taken at the same time on 2nd November 2023 showing the flood water extending far beyond the treeline into the proposed development site.
The MSDC Drainage Engineer (Flood Risk) has provided us with feedback about the definition of a 20-year event as being one which has a 5% likelihood of occurring. Considering the probability, we still believe that to have so many recent observed flood events far in excess of the 20-year event, and actually approaching much closer to the 100-year extent makes it unlikely that the model is accurately predicting the likelihood of flooding in the 20 and 100-year events. We therefore continue to recommend that RPS are asked whether their hydraulic model is adequately predicting the frequency and extent of the flooding when compared to the photographic evidence. As they are the hydraulic modelling experts, we believe it is reasonable that RPS provide a response regarding this matter, rather than a third-party consultant interpreting the output of their model.
FPC's comments on Barratt Homes traffic calming proposals. It has been noted that only a small number of residents were invited to comment. MSDC agreed to upload FPC's comments to their Planning Portal.
Felbridge Parish Council (FPC) are concerned that the proposed footpath to the bus stop on the North side of Crawley Down Road opposite no 71/73 would remove an excessive amount of Green Belt. It would be better for a new path to be created to the changed bus stop from the existing path.
FPC agreed a ‘Copenhagen’ style crossing created at McIver Close, in line with the existing footpath, would be an improved safety feature.
The suggested location of the new ‘table’ crossing outside no 71 Crawley Down road would place the crossing adjacent to the drive of No 71 and cause inconvenience to the occupant.
Any improvements to the existing footpath on the North side of Crawley Down road are to be welcomed.
FPC agrees with the suggestions made by Surrey County Council during a site meeting. These are that width restrictions for both East and West bound traffic in Crawley Down Road are preferred to raised road level through the creation of a ‘table’. This form of traffic calming is only suitable for maintaining low speed of traffic.
REPEATED REQUESTS FOR RESIDENTS TO COMMENT
FPC understand residents' frustration at the repeated need to comment on this application. Residents have said that it is time consuming and leaves them feeling that the exercise is pointless. However, it is strongly recommended that residents who have already submitted responses send a further email if they wish to ensure that their comments are not overlooked. It is possible that Barratt Homes may take the view that any reduction in active comments will suggest that previous concerns have now been overcome. The FPC Planning Chairman has gone through all the new submitted documents and found only minor amendments which do not address the main issues of concern expressed by residents to FPC. Those residents are being advised to email steven.king@midsussex.gov.uk if they consider that the minor alterations between the previous documents and the latest plans have not changed their opinions relating to DM/23/0810 and stating that their previous response dated XXXX still apply.
FPC'S RESPONSE DATED 18 AUGUST 2023 TO THE LATEST BARRATT HOMES APPLICATION FOR 200 DWELLINGS OFF CRAWLEY DOWN ROAD WITH ACCESS AT NO. 71 AND NO. 123 IS BELOW.
To comment, please email planninginfo@midsussex.gov.uk and quote reference DM/23/0810
DM/23/0810 Land South of Crawley Down Road, Felbridge
Felbridge Parish Council (FPC) strongly objects to this application. Whilst it is accepted that development of this site has been agreed in principle by the adoption of DPD Policy SA19 following the examination in public, Felbridge Parish Council does not believe that the development proposal as submitted meets the criteria necessary for the application to be considered viable.
HIGHWAYS AND TRANSPORT Felbridge Parish Council does not recognise the latest modelling of the Star Junction presented in that it has only provided revised traffic counts. There are no published turning counts or observed queue length studies. As such, it is impossible to validate if the model correctly predicts the queues and average delay times experienced by residents. Only once the model has been shown to be capable of replicating the current observed conditions at this junction is it reasonable to use the model to predict the future state. This is fundamental as Surrey Highways have already declared this junction “severe”.
FPC believe a thorough current state traffic study is necessary to support this development, particularly as the latest Transport Statement from the application shows the junction to be at 101% utilisation. The Tandridge traffic study, used as the basis for their emerging District Plan which showed this junction already operating at 106% in 2018 with a MMQ (mean maximum queue length) of 48 cars, indicates a worse situation.
The junction severity was also evidenced by the Inspector for APP/M3645/W/18/3198090 who included in his decision (Para 34) data that demonstrates that the queue length of eastbound traffic on the A264 increases by 168 vehicles in the 2-hour period 4:15pm to 6:15pm. The throughput of the junction in the PM peak averages 719 vehicles per hour, thus the Inspector is recording that the junction was already operating at 112% of its capacity based upon 2018 traffic data. Since then, 120 additional dwellings have been approved within 500m of this junction.
This latest Transport Assessment also fails to model the Crawley Down Road (CDR)/A264 junction against a current traffic survey, instead it states that it has replicated the ‘15 Crawley Down Road’ [TA/2017/1290] modelling which was based upon 2018 surveys and is therefore five years out of date. Whilst it has reportedly been updated to reflect 2023 observed traffic flows, there is no queue length study and we do not recognise the modelling presented as the baseline for the CDR/A264 junction which states that there is effectively no queue with it ‘unloading every cycle’. During the peak hours (and well outside them) the queue on the eastbound A264 reaches back to Crawley Down Road (and regularly back to Rowplatt Lane), as such the opportunity to turn east out of CDR is about having a gap in the westbound lane at exactly the same time as the queue is not moving in the eastbound lane as the hatched box at this junction only clears when the eastbound traffic stops moving and the next queuing vehicle has complied with the hatching. Contrary to the Transport Assessment, there is always a queue at the end of CDR and the current delays at this junction are the only thing that prevents Rowplatt Lane & CDR being a rat run to avoid the queue on the A264. The model is therefore inappropriate.
Felbridge Parish Council is still concerned about the poor Eastern sightline at 123 Crawley Down Road. The requirement for speed calming put forward by Surrey Highways would have to demonstrate significant compliance with the 30mph limit for the sightline to be satisfactory.
Felbridge Parish Council fully supports the East Grinstead Town Council amendment to the East Grinstead Neighbourhood plan that requires Mid Sussex District Council to issue a Grampian precedent condition for SA19 & 20. Should any future planning consent be granted for either or both of these allocated sites, then Mid Sussex District Council guarantee that Section 106/278 legal agreements will be executed prior to consent. This includes an upgrading of the A22/A264 ‘Star’ road junction to provide full mitigation for the existing over capacity of this junction; mitigation to negate the increased capacity caused by the proposed extra 775 dwellings; plus the additional accommodation for 120+ residents of the Retirement Community on the SA20 site. The relocation of Imberhorne Lower School from Windmill Lane in East Grinstead to the site, along with the addition of a two-form entry primary school will also increase vehicle movements for the site. This work is to be completed prior to the first housing occupations of either site mentioned above.
The Transport Assessment for this proposal has incorporated the Atkins proposal of 2-lanes turning south at the Felbridge junction within their baseline model ‘as this is a committed improvement project’. Surrey Highways has now determined that this improvement ‘will not and cannot be implemented’. This failed improvement scheme had been cited as the mitigation for the Hill Place Farm (200 units) and was relied upon for the future state transport modelling for 17 Copthorne Rd (26 units), 11a Crawley Down Rd (32 units), 15-39 Crawley Down Rd (63 units), 61 Crawley Down Rd (20 units) - a total of 339 units. Thus, these committed and mainly completed developments now have no highways mitigation to counter their impact upon this severe junction. Until mitigation of the impact of these 339 units upon an already severe junction has been delivered, it is impossible to see how an additional 200 units can be considered and the cumulative impact of the resulting 539 units without any mitigation would be ‘severe’ contrary to the NPPF.
The baseline used for the Transport Assessment does not use the same approach that SCC required for the initial 63 unit scheme at 15 Crawley Down Road (TA/2017/1290). For that scheme, the Transport Assessment was based on a June 2019 traffic survey. The 2019 baseline measured traffic level was then revised to include all subsequent local approved developments and completed developments to properly reflect baseline traffic levels. The revised baseline must then be adjusted using TEMPRO to uplift the revised baseline at the development completion date and the current development traffic added to properly assess the cumulative impact of all relevant developments. This data should then be used to model the future state scenarios with and without development. The latest TA has identified the large local schemes but has failed to include the cumulative smaller local commitments or the very significant SA20 site of 550 dwellings plus the Retirement Community that is part of that proposal.
Inspector’s Minor Amendment to SA19 & SA20 Felbridge Parish Council draws attention to Surrey County Council’s agreement to undertake a study with West Sussex County Council to determine what junction mitigation can be implemented to alleviate the A22/A264 corridor issues both now (in light of cumulative development locally), and in the future state with the additional DPD sites and normal traffic growth. The agreement quotes “Working collaboratively with and to the satisfaction of both Surrey and West Sussex County Council Highway Authorities, mitigate development impacts by maximising sustainable transport enhancements; where additional impacts remain, highway mitigation measures will be considered”. The new study (which SCC and WSCC commissioned) has not started yet, let alone been concluded and as such SCC will not be able to say whether (or how) the Star junction could be mitigated to below its current ‘severe’ state. Felbridge Parish Council contends that until the joint WSCC and SCC transport study has been concluded and suitable and deliverable mitigation of the current severe junctions has been agreed, it is inappropriate to approve this application as the Highways elements of the adopted DPD policy SA19 cannot be delivered.
DESIGN We find a number of failings in relation to compliance with the MSDC Design Guide regarding the following principles. Principle DG9 (Page 51): Reduce Reliance on the Private Car: There is an inadequate bus service in Felbridge with few services at evenings and weekends. There is a lack of local facilities, for example no doctor or dentist; supermarket; leisure centre; restaurants; rail service or safe footpath option. The village is served by one single intake primary school that is already oversubscribed before all the 121 dwellings already approved on MSDC land off or near Crawley Down Road have been constructed or occupied. There is reference in the application to a safe cycle route using the Gullege Bridleway and Worth Way to reach East Grinstead. However, the bridleway surface is unsuitable for cycles (or wheelchairs/pushchairs), it regularly floods and has no lighting.Principle DG11 (Page 52): Respond to the Existing Townscape. “New development should generally reflect the scale of adjacent areas and the settlement context within which it is located to deliver a coherent and consistent urban fabric”.
Felbridge Parish Council strongly object to the Planning Statement
4.2 The proposed development seeks to deliver a sympathetic extension to Felbridge.
This proposal does not provide a sympathetic extension to Felbridge. The housing density of the west parcel at 40dph greatly exceeds the existing density immediately north of the site, which is 16dph. It is also greater than the 30dph of the eastern parcel despite being nearer the development edge and the rural edge. This does not conform to the MSDC design guide principles DG11, DG16 & DG34.
This principle (DG11) requires this site to have a comparable density and style of housing to the neighbouring areas, whereas this application is for a considerably higher density with properties that are totally different in scale or design. The proposed western parcel comprises 2-storey, 2.5-storey and 3-storey dwellings whereas the abutting dwellings in Felbridge on the north boundary of the site are a mixture of single storey and 2-storey houses, with nearly one third being single storey. Therefore the solely 2-storey and higher development immediately south of them is inappropriate. We are also concerned about the visual impact as there is very little drop in height between the existing single storey dwellings on Crawley Down Road and the site of the proposed 3-storey dwellings, thus there are likely to be visible above the existing street scene.
Principle DG16 (Page 63): Create a Positive Development Edge. “Development should nevertheless be sensitively designed so that it avoids imposing upon the rural edge and existing roads that are characterised by their hedgerows and tree belt. This may require additional boundary planting. At the rural edge lower density development will also normally be necessary.” This requirement has not been met in the site plan as presented, which has a significantly higher density at the rural edge, than the surrounding area.
Principle DG34 (Page 87): Managing Increased Density in Urban Extensions. “A range of densities, building types and forms will normally be required with higher density development in the more accessible locations and lower density development in the peripheral areas.” This proposal has its highest density in the parcel furthest from the urban centre of East Grinstead and on the periphery of the built-up area boundary adjacent to the rural area beyond.
BIODIVERSITY/SUSTAINABILITY The developer has failed to address biodiversity net gain and to effectively plan for the future. The Sustainability statement gives little comfort or commitment on any methods that will be included onsite. Given the phasing out of gas boilers in new homes from 2025 and the stated completion date for this development being 2026, there needs to be an alternative heating approach proposed for these dwellings. An air source heat pump solution (or other sustainable energy solution) for all properties would be preferable and is becoming common on other housing schemes of a similar size. There is no mention of commitment to photo-voltaic or solar hot water and this should be clarified. There is no commitment in terms of a payment or length of the Biodiversity Action Plan and we would ask for a period of a minimum of 10 years to be added as a condition should the Council be minded to approve the application. Given the rural nature of the site, consideration should be given to sustainable green features including green screens and rainwater gardens.
PLAY Felbridge Parish Council suggests a different consideration for teenagers and urges the developer and the Council to look at initiatives such as ‘Make Space for Girls’ especially given the proximity to Imberhorne School.
AFFORABLE HOMES It is noted that the application shows 30% of dwellings would be affordable homes. However, in the consultation feedback for the pre-application, East Grinstead Town Council suggested that the percentage of affordable homes delivered on greenfield sites in Mid Sussex should be 40%.
FLOOD RISK Felbridge Parish Council challenges the suggestion that there is virtually no flood risk zone within the site. Residents who walk these fields, and the adjoining bridleway, know there is regular flooding in this area extending to both sides of the Gullege Bridleway. Photographs of recent flood events on the bridleway and the bridleway being closed as it was swept away during recent flooding have been submitted as part of this consultation. The authors of the Hydraulic Modelling clearly state that their model has not been calibrated as they had no known flood events to use as references. The public photos collated into the flood review submission for the last application would provide calibration points. The MSDC Drainage and Flood Engineer has responded to our concerns stating that the modelling was reviewed by the Environment Agency (EA) who support it.
We continue to see this as a risk, the EA were told by the applicant that there was no local flooding and the repeated flood photographic evidence all post-dates the EA’s review of the modelling. Felbridge Parish Council continue to demand that RPS are requested to calibrate their Hydraulic model using the photographic flood evidence to satisfy the public and businesses who are very concerned about the flood risk upstream and downstream from this site. The revised model would be the most accurate prediction of the future flood risk zones, and would ensure that this development does not generate a negative impact upon the flood risks.
REMOVAL OF CATEGORY B TREE Felbridge Parish Council agree with the concerns of local residents that there is no sustainable justification for the removal of the mature oak tree T19 which is a category B tree protected by a TPO. The applicant is stating that it needs to be removed to make way for the access road. Surely for such a significant development an alternative highway access can be sought (albeit by purchase of additional highways frontage) such that a mature protected tree can be retained. We do not see compensatory planting as a suitable substitution for such a dominant tree.
ENDS
Previous responses are below:
Felbridge Parish Council strongly objects to this application. Whilst it is accepted that development of this site has been agreed in principle by the adoption of DPD Policy SA19 following the examination in public, Felbridge Parish Council does not believe that the development proposal as submitted meets the criteria necessary for the application to be considered viable.
HIGHWAYS AND TRANSPORT Felbridge Parish Council does not recognise the modelling of the Star junction presented in that it is more than 3 years old and shows a junction operating within capacity, when more recent studies show that it is exceeding capacity and is declared as a severe junction by Surrey Highways. We believe a current traffic study is necessary to support this development. The Tandridge traffic study, used as the basis for their emerging District Plan, which showed this junction already operating at 106% in 2018 with a MMQ (mean max queue length) of 48 cars, draws a very different conclusion. The junction severity was also evidenced by the Inspector for APP/M3645/W/18/3198090 who included in his decision (Para 34) data that demonstrates that the queue length of eastbound traffic on the A264 increases by 168 vehicles in the 2 hour period 4:15pm to 6:15pm. The throughput of the junction in the PM peak averages 719 vehicles per hour, thus the inspector is recording that the junction was already operating at 112% of its capacity based upon 2018 traffic data. Since then 120 additional dwellings have been approved within 500m of this junction. This latest Transport Assessment also fails to model the Crawley Down Road/A264 junction against a current traffic survey, instead it states that it has replicated the ‘15 Crawley Down Road’ [TA/2017/1290] modelling which was based upon 2018 surveys and is therefore 5 years out of date. We do not recognise the modelling presented as the baseline for the Crawley Down Road (CDR)/A264 junction which states that there is effectively no queue with it ‘unloading every cycle’. During the peak hours (and well outside them) the queue on the eastbound A264 reaches back to Crawley Down Road, as such the opportunity to turn east out of CDR is about having a gap in the westbound lane at exactly the same time as the queue is not moving in the eastbound lane as the hatched box at this junction only clears when the eastbound traffic stops moving and the next queuing vehicle has complied with the hatching. Contrary to the TA, there is always a queue at the end of CDR, the current delays at this junction are the only thing that prevents Rowplatt Lane & CDR being a rat run to avoid the queue on the A264.The model is therefore inappropriate. The provision of a separate entrance for the western part of the site, such that vehicles do not cross the bridleway is welcomed, The original plan for vehicles to cross this widely used Public Right of Way was likely to raise many safety issues. However, the proposed additional entrance appears to be an afterthought in the submitted documents as there is no safety assessment for this location, nor is there any modelling for this new junction. Felbridge Parish Council are very concerned that this junction for ~140 houses immediately west of the junction of Crawley Down Road and Rowplatt Lane will have a negative impact upon the safety of that junction. The visibility splay for the exiting vehicles at 123 CDR is very poor. Even the applicants own speed data [out of date as it is 2016] shows 85%tile speeds of 37/40mph so using the known speeds the relevant visibility table should be ~100m to the nearside kerb approximately three times that provided. 2 Felbridge Parish Council fully supports the East Grinstead Town Council amendment to the East Grinstead Neighbourhood plan that requires Mid Sussex District Council to issue a Grampian precedent condition for SA19 & 20. Should any future planning consent be granted for either or both of these allocated sites, then Mid Sussex District Council guarantee that Section 106/278 legal agreements will be executed prior to consent. This includes an upgrading of the A22/A264 ‘Star‘ road junction to provide full mitigation for the existing over capacity of this junction; mitigation to negate the increased capacity caused by the proposed extra 775 dwellings; plus the additional accommodation for 120+ residents of the Retirement Community on the SA20 site. The relocation of Imberhorne Lower School from Windmill Lane in East Grinstead to the site, along with the addition of a two form entry primary school will also increase vehicle movements for the site. This work is to be completed prior to the first housing occupations of either site mentioned above. The Transport Assessment for this proposal has incorporated the Atkins proposal of 2-lanes turning south at the Felbridge junction within their baseline model ‘as this is a committed improvement project’. This future improvement scheme has now been cited as the mitigation for the Hill Place Farm (200 units), 17 Copthorne Rd (26 units), 11a Crawley Down Rd (32 units), 15-39 Crawley Down Rd (63 units), 61 Crawley Down Rd (20 units) as well as SA19 (200 units) - a total of 539 units. All of these schemes have quantified the additional impact they will have individually upon the junction. The 2-lanes turning south was previously implemented and withdrawn when it had a significant detrimental impact upon junction performance and we believe there are significant doubts as to whether this proposal would actually deliver any junction capacity. There is also the Surrey County Council agreed need to improve pedestrian crossing facilities at this junction. In response to the initial phase1 application for this site, SCC Highways requested a number of items to be revised in the Transport Assessment (TA), none of those items have been included in this latest TA. The greatest flaw is that SCC stated; It should not be assumed that a solution will be in place for the A22/A264 junction that can mitigate the adverse impact of the development. The TA should therefore consider the current junction without mitigation. The TA provided with the new application continues to include the junction mitigation, it is therefore fundamentally flawed as it is solely based upon that scheme being in place and delivering a quantified benefit by 2026 when the viability of that scheme is being questioned by SCC. The baseline used for the transport assessment does not use the same approach that SCC required for the initial 63 unit scheme at 15 Crawley Down Road (TA/2017/1290). For that scheme, the Transport Assessment was based on a June 2019 traffic survey. The 2019 baseline measured traffic level was then revised to include all subsequent local approved developments and completed developments to properly reflect baseline traffic levels. The revised baseline must then be adjusted using TEMPRO to uplift the revised baseline at the development completion date and the current development traffic added to properly assess the cumulative impact of all relevant developments. This data should then be used to model the +10 year scenarios with and without development. The Surrey Highways determination of the Star junction as Severe and the requirement to mitigate it will be challenged by the Examination Inspector for the Tandridge District Plan. The emerging Tandridge District Plan included mitigation of this junction by the proposal to create two lanes turning south from the A264 into the A22. This proposal has already been identified for implementation as mitigation for the 200 houses approved at Hill Place Farm [APP/D3830/W/16/3142487] and the 121 dwellings approved along Crawley Down Road and Copthorne Road [APP/M3645/W/18/3205537, APP/M3645/W/18/3198090 & TA2019/1453]. Thus the proposed mitigation approach has already been put forward as the mitigation for numerous other sites that have been approved, and in some cases completed, despite the agreed mitigation not being implemented. Inspector’s Minor Amendment to SA19 & SA20 Felbridge Parish Council draws attention to Surrey County Council’s agreement to undertake a study with West Sussex County Council to determine what junction mitigation can be implemented to alleviate the A22/A264 corridor issues both now (in light of cumulative development locally), and in the future state with the additional DPD sites and normal traffic growth. The agreement quotes “Working collaboratively with and to the satisfaction of both Surrey and West Sussex County Council Highway Authorities, mitigate development impacts by maximising sustainable transport enhancements; where additional impacts remain, highway mitigation measures will be considered”. The Atkins study (which SCC and WSCC commissioned) has not been concluded and as such SCC will not be able to say whether (or how) the Star junction could be mitigated to below its current ‘severe’ state. Felbridge Parish Council contends that until the joint 3 WSCC and SCC transport study has been concluded and suitable and deliverable mitigation of the current severe junctions has been agreed, it is inappropriate to approve this application as the Highways elements of the adopted DPD policy SA19 cannot be delivered. DESIGN We find a number of failings in relation to compliance with the MSDC Design Guide regarding the following principles. Principle DG9 (Page 51): Reduce Reliance on the Private Car: There is an inadequate bus service in Felbridge with few services at evenings and weekends. There is a lack of local facilities, for example no doctor or dentist; supermarket; leisure centre; restaurants; rail service or safe footpath option. The village is served by one single intake primary school that is already oversubscribed before all the 121 dwellings already approved on MSDC land off or near Crawley Down Road have been constructed or occupied. There is reference in the application to a safe cycle route using the Gullege Bridleway and Worth Way to reach East Grinstead . However, the bridleway surface is unsuitable for cycles (or wheelchairs/pushchairs), it regularly floods and the Worth Way has no lighting. Principle DG11 (Page 52): Respond to the Existing Townscape. “New development should generally reflect the scale of adjacent areas and the settlement context within which it is located to deliver a coherent and consistent urban fabric”. Felbridge Parish Council strongly object to the Planning Statement 4.2 The proposed development seeks to deliver a sympathetic extension to Felbridge. This proposal does not provide a sympathetic extension to Felbridge. As the housing density of the west parcel at 40dph is in stark contrast to the existing density immediately north of the site which is 16dph. It is also greater than the 30dph of the eastern parcel despite being nearer the development edge and the rural edge. This does not conform to the MSDC design guide principles DG11, DG16 & DG34. This principle requires this site to have a comparable density and style of housing to the neighbouring areas whereas this application is for a considerably higher density with properties that are totally different in scale or design. The proposed western parcel comprises 2-storey, 2.5-storey and 3-storey dwellings, the abutting dwellings in Felbridge on the north boundary of the site are a mixture of single storey and 2-storey houses with nearly one third being single storey and therefore the solely 2-storey and higher development immediately south of them is inappropriate. We are also concerned about the visual impact as there is very little drop in height between the existing single storey dwellings on Crawley Down Road and the site of the proposed 3-storey dwellings, thus there are likely to be visible above the existing street scene. Principle DG16 (Page 63): Create a Positive Development Edge. “Development should nevertheless be sensitively designed so that it avoids imposing upon the rural edge and existing roads that are characterised by their hedgerows and tree belt. This may require additional boundary planting. At the rural edge lower density development will also normally be necessary.” This requirement has not been met in the site plan as presented which has a higher density at the rural edge, than the surrounding area. Principle DG34 (Page 87): Managing Increased Density in Urban Extensions. “A range of densities, building types and forms will normally be required with higher density development in the more accessible locations and lower density development in the peripheral areas.” This proposal has its highest density in the parcel furthest from the urban centre of East Grinstead and on the periphery of the built up area boundary bounding onto the rural area beyond.
BIODIVERSITY/SUSTAINABILITY The developer has failed to address biodiversity net gain and to effectively plan for the future. The Sustainability statement gives little comfort or commitment on any methods that will be included onsite. Given the phasing out of gas boilers in new homes from 2025 and the stated completion date for this development being 2026, there needs to be an alternative heating approach proposed for these dwellings. An air source heat pump solution (or other sustainable energy solution) for all properties would be preferable and is becoming common on other housing schemes of a similar size. There is no mention of commitment to photo-voltaic or solar hot water and this should be clarified. There is no commitment in terms of a payment or length of the Biodiversity Action Plan and we would ask for a period of a minimum of 10 years to be added as a condition should the Council be minded to 4 approve the application. Given the rural nature of the site, consideration should be given to sustainable green features including green screens and rainwater gardens. Play Area Felbridge Parish Council suggests a different consideration for teenagers and urges the developer and the Council to look at initiatives such as Make Space for Girls especially given the proximity to Imberhorne School . Affordable Homes: It is noted that the application shows 30% of dwellings would be affordable homes. However, in the consultation feedback for the pre-application, East Grinstead Town Council suggested that the percentage of affordable homes delivered on greenfield sites in Mid Sussex should be 40%. Flood Risk Assessment (P8): The EA flood map shows Zone 2 extending into the site and the RPS model shows virtually no flood risk zone within the site. If the RPS flood model is shown to be overly optimistic this creates a concern relating to the SUDS infiltration basin. This is proposed within the EA Flood Zone 2 area of the site, thus when there is heavy rainfall the SUDS basin [which is intended to retain surface water from the site and release it slowly to reduce the risk of flooding] will already be inundated with Felbridge Water and thus serve no practical purpose. Felbridge Parish Council challenges the suggestion that there is virtually no flood risk zone within the site. Residents who walk these fields, and the adjoining bridleway, know there is regular flooding in this area extending to both sides of the Gullege Bridleway. Photographs of recent flood events on the bridleway and the bridleway being closed as it was swept away during recent flooding have been provided as part of the consultation for the previous application. The authors of the Hydraulic Modelling clearly state that their model has not been calibrated as they had no known flood events to use as references. The public photos collated into the flood review submission for the last application would provide calibration points. Felbridge Parish Council demand that RPS are requested to calibrate their Hydraulic model to satisfy the Public and Businesses who are very concerned about the flood risk upstream and downstream from this site as the revised model would be the most accurate prediction of the future flood risk zones, and would ensure that this development does not generate a negative impact upon the flood risks.
FPC COMMENTS ON SPECIFIC TRAVEL ISSUES - including the failure of MSDC to enforce earlier Travel Plans
Whilst Felbridge Parish Council support Sustainable Active Travel as a means of reducing the impact of development, we have serious concerns about the effective delivery of these schemes in East Grinstead. The local resident’s group, Infrastructure First, submitted FOI's relating to three large developments in East Grinstead;
Land West of Imberhorne Lane for 100 dwellings [12/03843/REM]
Land South of the Old Convent for 74 dwellings [14/00294/FUL]
Land Adjacent to Ashplats House for 117 dwellings [12/00716/REM]
The details of the FOI responses are in the attached travel plans information which was submitted by Infrastructure First as part of their consultation response to the previous SA19 application.
It is clear that even with planning conditions requiring a travel plan to be in place, MSDC developments have completed and been occupied without any travel plan. Even when there is a plan, there is no monitoring to show whether any significant modal change has taken place. Thus, we take the view that having a sustainable travel planning condition on the SA19 site does not guarantee local residents that a plan will be in place, or that it will be effective.
The MSDC latest Infrastructure Delivery Plan (IDP), dated 21 December 2020, lists only a single costed measure for SA19: ‘Real Time Passenger Information’ at local bus stops. There is no evidence to show that this would be effective in reducing car journeys, and no guarantee that it would be implemented. A similar upgrade to local bus stops was used as mitigation for development traffic from the 100 dwelling scheme West of Imberhorne Lane [Ref 10/02071/OUT] committing to;
Bus stop improvements on Imberhorne Lane and Heathcote Drive (four existing stops to be upgraded with shelters, real time information, hardstanding areas etc)
Funding was secured by s106, dated 24 May 2011, but the bus stop improvements have never been implemented. Other SA19 highways mitigation measures listed in the IDP include ’Bus priority improvements’. The same 100 dwelling scheme above also committed to local bus priority measures;
The introduction of bus priority measures at the A22 London Road/Imberhorne Lane signalised junction
Again, these have also not been implemented despite the site being fully occupied for over a decade.
The following MSDC sites have all made S106 contributions for highways mitigation, none of which have been implemented.
Land West of Imberhorne Lane for 100 dwellings – 10 years after completion, traffic light coordination is not in place
Land South of the Old Convent for 74 dwellings – 6 years after completion, Moat Road/A22 junction improvements not implemented despite assessment of ‘severe impact’ of this development by WSCC
Land Adjacent to Ashplats House for 117 dwellings - 9 years after completion, highways improvements not implemented despite assessment of ‘significant impact’ of this development by WSCC
Land at Hill Place Farm for 200 dwellings – 4 years after approval (occupation now started), Lingfield Rd and Star junction highways improvements not implemented
17 Copthorne Road & 15 Crawley Down Road totalling 89 dwellings - now occupied, Star junction highways improvements not implemented
Thus, it is clear that even when S106 agreements are in place, WSCC has not implemented the highway mitigations that were specified in the planning process. Therefore, S106 conditions on MSDC sites are no guarantee that the agreed highway mitigation plans will be implemented.
For the land at Hill Place Farm, the appeal inspector drafted a Grampian condition for the Secretary of State to prevent occupation before the highway improvements were implemented, but decided it was not necessary as there was sufficient certainty that the improvement works would be completed before occupation took place. Clearly that ‘sufficient certainty’ was ill-placed.
We therefore contend that there is sufficient evidence to demonstrate that for MSDC developments around East Grinstead;
Sustainable travel planning conditions do not provide a guarantee that significant mitigation will be delivered
S106 agreements do not guarantee mitigating highway improvements will be implemented
Even if the agreed highways mitigations are implemented and effective, these mitigations only deal with the incremental impact of these individual developments and not the cumulative impact of over 2,000 other approvals for East Grinstead in the last decade.
Even without this development, residents are already suffering the cumulative impact from the several hundred dwellings already occupied and for which the required highways mitigation at the Felbridge junction has NOT been delivered. Therefore, as residents are all experiencing unacceptable delays along the A22 corridor into East Grinstead, Felbridge Parish Council ask that you consider the failure to deliver committed improvements to the Felbridge junction as weighing negatively in the planning balance.
Felbridge Parish Council wishes to know what TDC, as the Local Planning Authority for the eastern entrance into this development, will do to guarantee (if this development goes ahead) that effective mitigation measures will be in place and how they will be monitored BEFORE the dwellings are occupied. You must deliver long term mitigation for the severe traffic impacts that these developments have upon our residents.
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FURTHER PROPOSED MSDC DEVELOPMENT off Felbridge roads.
MSDC Councillors Approve Sites on and near the Felbridge Border For Further Development
MSDC Councillors voted 24/18 in favour of approving the two sites on the Felbridge border which were included in the MSDC Development Planning Document as suitable for future development. None of the MSDC councillors local to the East Grinstead/Felbridge area voted against the plan. Included is SA19 (land off Crawley Down Road in Felbridge) for 200 houses. The pre-application by Barratt Homes for this site included a proposal to create a road across the Gullege Bridleway. Felbridge Parish Council strongly opposed that application. A full planning application has now been submitted DM/22/3214 for phase 1 of the development. MSDC have already approved three developments for 121 houses off Felbridge roads. The second application for 550 dwellings, plus accommodation for 120+ Retirement Community residents, is expected from Welbeck Homes.
This proposal for 200 houses is in addition to the 120+ already built or under construction. The website is set up by Barratt Homes for this site is www.landsouthofcrawleydownroad.com A map showing the proposed development can be found at the bottom of this page under Uploaded Documents. The developer's presentation can be viewed on this link https://www.youtube.com/watch?v=W52qEnxo4PQ Felbridge Parish Council strongly opposes further major development on the Felbridge border without infrastructure delivery. There are no plans to address the fundamental issues with the Star Junction in particular which already operates over capacity even before the impact from the 120+ new houses has been assessed.
MSDC have also included a further site near Imberhorne School for an additional 550 houses in their Site Allocations DPDs. This site is known as SA20. This will also have a major impact on the Star Junction and again there have been no proposals put forward to address the impact on the Star Junction.
Felbridge Parish Council note that despite formal requests for support, MSDC allocated no infrastructure investment for play, sport, leisure, community buildings, etc from the funding they received from the developers of the sites at at 17 Copthorne Road, 15-39 Crawley Down Road or 11a Crawley Down Road. In addition, there was no investment in road improvements in Felbridge.