The Friends of the South Downs not only responds to planning applications within the National Park, we also look out for development proposals on or beyond the park boundary which might have a significant effect on the park’s special qualities. Below is our response to a current application alongside the A27 near Shoreham airport:
Pl app AWDM/0961/17: Demolition of existing buildings, erection of 600 new dwellings, non-food retail store, creation of country park, relocation of travellers’ site, new access to A27, community hub, primary school, landscaping: land west of New Monks Farm, Mash Barn Lane, Lancing
These are the comments of the South Downs Society, the national park society for the South Downs National Park:
- The application site is in open countryside not allocated for development in the adopted Adur Local Plan (1996). It comprises the western part of a “strategic gap” of open land between Lancing and Shoreham. A number of saved policies remain in force as part of the development plan for the area. These include the following:
- AC1- Protection of the countryside
- AC4- Protection of strategic gaps
- AP4 and AP5- Development and land drainage
- AH3- Housing to meet local need
- AP11- Listed buildings
- As the application proposals clearly conflict with policies AC1 and AC4, they would be a departure from the development plan, requiring reference to the Secretary of State for possible call in for his own determination following a public inquiry. In doing so, the Secretary of State will need to consider the impact of the proposals over a large area extending beyond Adur District in terms of loss of a significant part of one of the few gaps of open countryside on this part of the Sussex Coast; the impact of a large “out of town” retail development on nearby town centres; impact on the adjacent National Park landscape; and impact on the A27 trunk route.
- The 1996 Local Plan is being replaced by a new local plan. Adur District Council submitted a new local plan to the Secretary of State for examination in 2016. The examination was held in January- February 2017. The Inspector’s report is not yet available, although he indicated his preliminary findings in May. The new Local Plan has had to consider provision of additional land to meet the need for more housing and employment over the period to 2031.
- As part of its strategic development provision, the new local plan is proposing a major allocation of land at New Monks Farm, which largely coincides with the application site. The proposed allocation in Policy 5 of the new local plan comprises:
- Around 10,000 square metres of commercial floor space
- 600 new homes, of which 30% would be affordable
- A primary school
- A relocated and enlarged site for Gypsies and Travellers
- A community hub
- A country park
- Although preparation of the new local plan is well advanced, its “soundness” and overall planning strategy, including the major allocation at New Monks Farm, have not yet been endorsed by an independent inspector. Any decision to grant planning permission in advance of the Inspector’s report would be premature and prejudicial to the local plan process.
- Publication of the Inspector’s report is expected in the near future. Even when the inspector’s report is available, there are material differences between the proposed local plan allocation and the current planning application (for example, in the extent of the strategic gap taken by development and in the size of commercial floor space – both of which are larger in the application, the latter considerably so.) This means that detailed consideration of the planning merits of application proposals will be necessary, even if Policy 5 receives the Inspector’s broad endorsement.
(b) Strategic gap between Lancing and Shoreham
- The safeguarding of this strategic gap has been a longstanding feature of local planning policy in the area. Policy AC4 from the 1996 plan has been carried through into the new local plan, where Policy 14 seeks to maintain the gap between Lancing and Shoreham in order to prevent their coalescence and preserve their separate character and identity. Notwithstanding the new local plan work and the applicants’ declaration of a “landscape-led approach”, it is impossible to protect a strategic gap by building over a large part of it.
- To a limited extent, the strategic gap has been compromised by the Brighton & Hove Albion FC training complex immediately to the south of the application site. However, the training complex has a relatively small building footprint in comparison with the extensive open areas given over to playing pitches, albeit with some floodlighting and high netting fences (both urbanising features). As such, it does not set a precedent for the much more extensive and intensive form of development proposed in the current application, which has a far greater visual impact on the strategic gap.
- This impact is offset by the country park proposals on the eastern side of the application site, but nevertheless the strategic gap between Lancing and Shoreham is reduced by the current application by about one-third, leaving only the airport – with a narrow ribbon of development along the A259 frontage — as an intervening open area.
(c) Flood risk
- The application site is on the tidal flood plan of the Adur and falls predominantly within Flood Zone 3a in the national classification of flood risk (high probability). The site is at risk not only from tidal flooding, but also from surface water flooding and groundwater flooding. The whole site and surrounding areas have a greater than 75% risk of flooding from groundwater.
- The Society has seen, and supports, the comments submitted by CPRE Sussex on the flood risk issue on the 2016 pre-submission Local Plan. Surface water drainage and groundwater issues have not been adequately addressed in the current application and, accordingly, the scheme does not accord with national guidance on development and flood risk.
- The site adjoins the A27 trunk road which already carries around 60,000 vehicles per day in this area, about two-thirds of which is local traffic and one-third through traffic along the south coast. The standard of the A27 is very variable. To the east of the application site, the Brighton & Hove By-Pass is a high capacity dual carriageway road. However, to the west through Lancing and Worthing, the standard of the road varies between single and dual carriageway. In addition, there are many busy junctions at grade with roundabouts and traffic lights, together with residential and business properties with access directly onto the A27, all of which slow traffic. As a result, the road is very often congested and has a poor accident record. Highways England has recently published for consultation a package of improvements to the A27 between Worthing and Lancing. The proposals focus on improving the capacity, safety and free flow of traffic around key junctions.
- The addition of a set of large scale traffic generators on the application site – particularly the proposed retail store – will add considerably to traffic on the A27. The applicants have proposed a new signal-controlled roundabout to act as the main access to the site. There must be concern about the capacity of the local highway network to handle this extra traffic, particularly given the propensity of the proposed retail use to generate longer distance trips along the A27 or linked roads with inevitable negative impact on the national park to the east, west and north. We note that both Highways England and WSCC have concerns in relation to the Transportation Assessment accompanying the application.
- The application site immediately adjoins the South Downs National Park, which lies to the north of the A27. The impact of the proposed development on the purposes and setting of the national park are material planning considerations. The impact of the development on views out from the higher ground to the north within the national park and views into the national park from the application site and other undesignated areas to the south have to be taken into account. The applicants’ own analysis indicates a “moderate to major” visual impact from the commercial housing elements of the application proposals but fails to indicate how these impacts will be managed and mitigated to make them a harmonious neighbour to the national park. The bulk, colouring and branding of the retail building make no concession to fitting it into its surroundings, as a “landscape-led” approach would require. Moreover, from many public vantage points, the scheme sits in the foreground of one of the best-loved views of the South Downs, namely the iconic collection of Lancing College buildings (many of which are listed) on a downland ridge above the Adur Valley.
- The second national park purpose of promoting public understanding and enjoyment will be affected by the application proposals for changes to pedestrian and cyclist access to the national park from residential areas south of the A27. This has been the subject of many objections to the application proposals by local residents, equestrians and cyclists. The Society shares these concerns.
(f) Cumulative impact
- The Society is aware that a major application has recently been submitted by Albemarle (Shoreham Airport) Ltd. on a nearby site.
- Whilst Adur DC is obliged to consider New Monks Farm and the Albemarle application on their own merits, there are overlapping issues which will require their cumulative impact to be considered:
- Compatibility with Policy 5 and Policy 7 of the emerging Adur Local Plan (if that is endorsed by the Inspector)
- Impact on the integrity of the strategic gap of open countryside between Lancing and Shoreham
- Impact on flood risk and land drainage over the two application sites and adjacent areas on the tidal flood plain
- Traffic impact on the A27 and the local highway network
- Impact on local natural and historic heritage, particularly the national park and the setting of important listed buildings
Careful consideration must be afforded to these cumulative impact issues which, if both applications proceed, can only intensify concerns about the harmful impact of these major developments on the local area.
The Friends of the South Downs OBJECTS to the current application for the reasons set out above.