Campaign to Save Toad’s Hole Valley REP/29 APPENDICES ... · REP/29 APPENDICES Supporting Statements about EIP Matters INDEX Appendix 1 Case for Continued Downland Protection Pages

REP/29 Campaign to Save Toad’s Hole Valley - Appendices 1

Campaign to Save Toad’s Hole Valley

REP/29

APPENDICES

Supporting Statements about EIP Matters

INDEX Appendix 1 Case for Continued Downland Protection Pages 2 - 6 Appendix 2 Severance & Accessibility Pages 7 - 10 Appendix 3 Sustainable Construction Pages 11 - 13 Appendix 4 Photographs Pages 15 & 17 Hazel I. McKay 7 October 2013


Appendix 1 Toad’s Hole Valley - the Case for Continued Downland Protection 1. Principle Arguments

1.1. Above all Toad’s Hole Valley should be protected from development

because it is a much-valued part of the South Downs. The site is a highly valued landscape that should be safeguarded from development by designating it as a Local Green Space in accordance with paragraphs 76 and 77 of the National Planning Policy Framework NPPF.

1.2. Any development of the site would be unsound in that it would: damage part of the South Downs chalk ridge destroy a much valued landscape between the boundary of the built-up area

and the national park damage the interface between the city and the national park

2. Background

2.1. The site is a beautiful expansive sweep of downland scenery, which frames

views of the bypass and offers glimpses of the city and the sea.

2.2. The planning policies for the Toad’s Hole Valley were first set out in the 1958 Hove and Portslade Town Map, where it was designated as land of Great Landscape Value and within water gathering grounds.

2.3. In 1966 the South Downs Area of Outstanding Natural Beauty was designated. This strengthened downland protection policies, which were supported by successive East Sussex Structure Plans.

2.4. For many years the valley has been vulnerable to pressure from landowners and developers. Before the Second World War there was a proposal to erect film studios on the land. East Sussex County Council compulsorily purchased the lower part for school playing fields but it did not work out, as flints kept coming to the surface. In the end, it was returned to the former owners. Later, the Albion used that part as a training ground but it too failed.

2.5. In 1980 came proposals for the A27 Bypass. Strong opposition to this was based on the belief that its benefits were outweighed by the harm it would to the Sussex downland, including Toad’s Hole Valley. There was fear that the new bypass would encourage the development of more downland on the AONB land south of the proposed new road.

2.6. At the public inquiry in 1983, the Department of Transport’s main witness, Mr Collins, rejected this argument and told the inquiry the intention was not to encourage any further development.

2.7. His evidence was reinforced by the Department of Transport’s landscape witness, Mr Chitty. He explained that, in order to make the best integration of the road into the AONB, the road was designed as a rural route, set within strategically wide landscaping, that would leave the sweep of the Downs as natural as possible.


2.8. After lengthy considerations, the bypass was approved and, even before the road was built, pressure to develop land south of the proposed route began. Toad’s Hole Valley was part of a farm, owned by the wife of a partner in one Brighton’s leading architectural practices. He submitted a proposal for a hypermarket but planning consent was refused, partly on the direction of the Department of Transport, which was concerned about traffic generation.

2.9. Construction of the bypass began in 1989 and the extensive landscaping

promised by the Department of Transport was put in place. In particular, the embankments on the south had long easy, grassed gradients to preserve the downland appearance of Toad’s Hole Valley.

2.10. For a while, there were considerable improvements to the valley. Hove Borough Council and the landowners came together and, with the enthusiastic support of local activists and residents, scrub was pushed back, grass was mown, a dewpond was created, rubbish was cleared and a management plan was agreed.

2.11. But soon there was renewed pressure for development, in particular,

from the Brighton & Hove Albion Football Club, which was seeking to leave the Goldstone Ground. Wyncote Developments proposed a scheme that included a new football ground and commercial development to make the development viable. The club’s proposals were strongly discouraged by the political leaders of both Hove and Brighton councils and by the planning policies of Hove Borough Council. No planning application was submitted but the landowners responded by withdrawing from the management plan and stopping public access to the valley. (See D. Bangs, ‘A Freedom to Roam Guide to the Brighton Downs from Shoreham to Newhaven and Beeding to Lewes, 2008, p157)

2.12. The landowners then began a long campaign to have the land included for development in the first Hove Local Plan and its later versions. The Hove Borough Council maintained its stance and sustained its position at public inquiries, when the owners pressed their case.

2.13. By December 1994, the bypass had been constructed and, following the inquiry into the last Hove Local Plan, the inspector, Rosalind Whittaker, wrote:-

“4.25 Toad's Hole Valley is a roughly triangular-shaped area of about 43 ha; it is bounded by King George VI Avenue to the south-east, Downland Drive to the south-west and the Bypass to the north. On the opposite sides of both King George VI Avenue and Downland Drive is residential development. Typical of the landscape of the AONB, Toad’s Hole Valley is asymmetrical in shape with a steeply sloping south-western side and a more gentle slope to the north-east. Toad’s Hole Valley is free from development; with the exception of the wooded western slope, the Valley is in agricultural use. Toad’s Hole Valley is excluded from the Environmentally Sensitive Area, which covers the downland to the north of the Bypass; however, this is not a planning designation. The Valley includes some of the best and most versatile land which, in accordance with policy S12(d) of the Structure Plan, should be protected from development. “4.26 From King George VI Avenue, the broad horizons to the north and north-west of Toad's Hole Valley are not seriously interrupted by the Bypass


or traffic moving upon it. From the north-east beyond the Bypass, on the road leading to Devil’s Dyke, traffic moving upon the Bypass rather than the Bypass itself is visible; but these vehicle movements do not seriously affect the perception of Toad’s Hole Valley as part of Downland. At closer range, especially from the higher ground of Downland Drive, the Valley is of sufficient size for its downland character to be readily appreciated in its own right. In my view, therefore, the character of Toad’s Hole Valley itself and its relationship with the wider downland have not been significantly changed by the construction of the By-pass; it continues to make an important contribution to both the AONB and the exceptionally fine setting of the town of Hove.”

2.14. Miss Whittaker also rejected the objectors’ arguments that the Toad's Hole Valley should not be covered by downland protection policies, stating (in paragraph 5.42 of her report) that “I consider that the statement that Toad's Hole Valley is an intrinsic part of the Downland landscape is well justified”.

2.15. She also declined (in paragraphs 5.45-48) to include the valley in land to meet the future development needs of Hove

2.16. At the public inquiry concerning the Community Stadium between

2003 and 2006, the City Council robustly argued that Toad’s Hole Valley must be protected from any form of urban development.

2.17. A major change came with the decision not to include some of Hove’s

downland periphery, including Toad’s Hole Valley, in the South Downs National Park. The city council and the South Downs Conservation Board resisted any attempts to reallocate Toad’s Hole Valley or to withdraw its protected status. Following the initial inquiry, it was decided that the valley should be part of the national park. However, at a subsequent inquiry on the boundary details, that decision was overturned.

2.18. When the decision on the final extent of the national park was made in

2010, the AONB designations in the South Downs were revoked, leaving some lands around the city unprotected, including Toad’s Hole Valley. This has to be one of the unintended consequences of the campaign to create the South Downs National Park. Instead of having enhanced protection, Toad’s Hole Valley then had no significant protection, pending approval of the city’s next development, but it did not follow that the valley ought to be developed.

2.19. In recent years the condition of the land has deteriorated as a

consequence of the neglect by the owners and its illegal use by bikers has marred its charm. But basically it is good quality agricultural land that is not being used by its owners. It has been argued that it is scruffy, so its development would be no great loss, but the owners should not be allowed to profit from the dereliction.

2.20. It would take little effort to restore the valley to its former glory. As

David Bangs wrote in 2008, “The site is in a scandalous mess. The landowners should hang their heads in shame.” (See Bangs, ibid, p226) A previous survey of the valley identified thirty different species of birds, as well as deer, rabbits and foxes. (See J. Middleton ‘Encyclopaedia of Hove and Portslade, volume T to V, 2003, p28)


2.21. Allowing the degradation of land on the urban fringe is a well-established practice of developers seeking to convince the public that such land is worthless and ought to be developed. Were local planning authorities to succumb to such pressures, it would create a developer’s charter.

2.22. The valley is a deep downland coombe. Prior to its neglect, it was a

beautiful swathe of green that rippled in the south-west wind, with the sea shining in the distance. Even today, driving through the valley on the bypass, one feels engulfed by the downland on both sides and a surprising sense of remoteness. It is, in Miss Whittaker’s words, part of “the exceptionally fine setting of Hove”.

3. Reasons for continuing to protect Toad’s Hole Valley

3.1. The South Downs is one of the country’s most valuable landscapes that has

been frequently under threat from urbanisation since the railways made the south coast easily accessible from London. The pressures for urbanisation in the twentieth century consumed large tracts of downland, destroying in the process some of the very features that new residents came to enjoy. It was only the robust campaigning by some notable individuals and the Society of Sussex Downsmen (now the South Downs Society) that ensured the South Downs were not more severely damaged by urbanisation than actually happened. (See ‘The South Downs’ by Brandon and Reid, 2011)

3.2. The creation of the South Downs National Park in 2011 now protects most of the downland from development, but a few sites were excluded from the park, including Toad’s Hole Valley. The site wasn’t excluded because it wasn’t downland, but because remedial management was required to return it to the condition of the downland north of the bypass. Before the bypass was constructed, the land north and south of the bypass formed a continuous sweep, with no appreciable differences in its condition north and south of the route. There is only one reason now for the site’s poor condition, and that is neglect by the site’s landowners, who are now seeking to use the site’s badly managed state as a reason why it should be released for development.

3.3. Despite losing AONB status when the South Downs National Park was

designated, Toad’s Hole Valley continues to be part of the chalk ridge of the South Downs and it is the part of the South Downs that is most visible from North Hove. It is also located at the point where the South Downs are at their narrowest and most vulnerable. More than any other site around the city, this site performs the functions of a ‘Green Belt’, in that it is:

safeguarding the downland from further encroachment checking the sprawl of the built up area of the city into the downland preserving the setting of the distinguished town of Hove which is visually

bounded by the sea and the downs assisting the urban regeneration of the whole city, by encouraging the

recycling of derelict and underdeveloped urban land

3.4. As a downland site, Toad’s Hole Valley is characterised by (i) high landscape value, which remains despite the owner allowing its degradation, (ii) good quality agricultural land, which the owner declines to exploit, (iii) an aquifer collecting rainwater for the benefit of the city, and (iv) an area of biodiversity


which could be improved with better management. The draft city plan offers no reasons as to why those constraints should be set aside.

3.5. This special site in the South Downs can only be released once for development; once released, there would be no turning back. Previously, it has been argued by the city council that, even in exceptional circumstances, Toad’s Hole Valley should not be released. Most recently, at public inquiry, the council vigorously resisted using the site for a community stadium, even though that was argued to be a very special case, and nothing about Toad’s Hole Valley’s condition has changed since that inquiry. Unlike the case made for locating the stadium in the downs at Falmer in that it had very special access requirements, covering Toad’s Hole Valley with residential and employment buildings would be downland encroachment for no special reason; in fact, arguably the site would not even be well suited for the uses proposed.


Appendix 2 - Toad’s Hole Valley – Severance and Accessibility 1. Location – Key Features

1.1. Toad’s Hole Valley is located to the north of Hove close to the Dyke Road

junction on the A27 trunk road.

1.2. The site is characterised by excellent access to the strategic highway network, but is severed from its surroundings by physical barriers.

1.3. The potential for serving the valley by public transport is severely limited, as are the opportunities for providing footpath links between the valley and neighbouring suburbs.

1.4. It may be some time before the valley had sufficient residents or workers to justify the bus company offering a bus service, and there are no proposals for a subsidised service.

1.5. The isolated location of Toad’s Hole Valley makes it an unsuitable location for affordable housing. In contrast, the excellent access by road would encourage increased longer distance travel by car owning residents, businesses and workers.

2. Severance

2.1. Toad’s Hole Valley is triangular in shape and there are barriers on all three

sides separating the valley from its surroundings: To the north is the A27 trunk road severing the valley from the downland To the west is a steeply wooded bank with a gradient of about 1:4

separating the valley from the adjacent suburb of Hangleton To the south-east is King George VI Avenue, which separates the valley

from the residential area in the Goldstone Valley. This barrier is reinforced by a continuous beech hedge/wall that separates King George VI Avenue from King George VI Drive.

2.2. The Goldstone Valley is separated from the rest of Hove by the impenetrable

barrier of Woodland Drive. As a consequence, the residential development in the Goldstone Valley takes the form of a large cul-de-sac, which can only be accessed from the west via Goldstone Crescent.

3. Access by Road 3.1. By road Toad’s Hole Valley can only be accessed at two points: at the top

via the Dyke Road roundabout or at the bottom where Goldstone Crescent/ Nevill Road meet King George VI Avenue.

3.2. The valley offers excellent accessibility by road to South London, Gatwick and other Sussex towns, with travel times of 35 mins to the M25 or Gatwick Airport, and less than 20 mins to Worthing, Lewes or Newhaven.

3.3. It is this excellent access by road that the Employment Land Study Final

Report identified as the key feature making Toad’s Hole Valley suitable for a light industrial park. Specifically the study found ‘the site has limited access to local services, but offers excellent strategic and local access via the A27.’


4. Potential for Public Transport Services

4.1. In marked contrast the potential for serving Toad’s Hole Valley by public transport is very poor. The nearest rail station, Hove, is too distant to be used by most residents. There are limited options for serving the valley by bus, none of which would result in the valley being well served by public transport and none would offer public transport connectivity to the rest of Sussex and beyond.

4.2. Regardless of which route was chosen, bus services between Toad’s Hole

Valley and central Hove or Brighton would take in excess of half an hour, because it currently takes half an hour to reach either of the valley’s two access points: the Dyke Road roundabout or the junction of Goldstone Crescent with King George VI Avenue.

4.3. The roads leading to Toad’s Hole Valley are not themselves well served by

buses because of the socio economic profile along those routes and there is no demand for increased bus services. Specifically, Dyke Road Avenue is characterised by large detached houses with high car ownership, and the only bus route along that road is the leisure service no.77 to Devil’s Dyke running only on weekends and bank holidays. The approach via Goldstone Crescent is also through an area of mainly detached properties, but much smaller plots than Dyke Road Avenue. This area supports a regular service no. 81 into central Hove and Brighton that runs half hourly daytime weekdays and hourly at other times. The service is not very profitable and has been threatened by cuts.

4.4. Given that any new bus service would have to travel through those

unprofitable areas, it is unlikely Toad’s Hole Valley would be served by a new bus service. Thus the only realistic option appears to be to extend the Goldstone Valley service without increasing its frequency, giving rise to a very long journey between Toad’s Hole Valley and central Hove.

4.5. The bus company could also consider diverting some of the buses on the

more frequent 5B service that runs via Court Farm Road to Hangleton. It would be possible to reroute some of the buses into Toad’s Hole Valley instead of running them to Hangleton, but that option would be most unpopular with Hangleton residents and tend to undermine a profitable service. So in reality that option is unlikely to be pursued.

5. Securing an Initial Bus Service

5.1. When a new area is developed, there is a chicken and egg problem. If a bus service is not provided at the outset, all new residents become dependent on the private car, if they have access to one, and those without a car are reluctant to move into the area. On the other hand, only when a critical number of prospective residents, have moved into the area to live or work, is it profitable for a bus company to offer a new bus service.

5.2. Without the offer of subsidy or some other form of incentive, it may be some

years before a bus company would view serving the valley as a profitable venture. Meanwhile residents would have to rely on the service 81 in Goldstone Crescent or walk the longer distance to Court Farm Road, for the more frequent 5B. This could involve long unpleasant walks to and from the bus stops, particularly having regard to the gradients and heavy traffic on


King George VI Avenue. In such circumstances, residents would tend to become reliant on the private car, if at all possible, thereby reducing the demand for a bus service into the valley.

6. Access on Foot around the Locality

6.1. Given that Toad’s Hole Valley is close to established residential suburbs, it is surprising that walking links to those neighbouring areas pose difficult, if not insurmountable, problems.

6.2. First, walking routes between the valley and Downland Drive in Hangleton

would have to deal with the 1:4 gradient of the bank between the two areas. To address this problem the landowners are suggesting zigzag paths. Those paths would inevitably not have much footfall and would have to pass through the heavily wooded area on the bank, so would not be suitable for use by anyone walking alone, particularly after dark. This would undermine the aim of getting Toad’s Hole residents to use Hangelton’s services and vice versa. Whilst the proposed footpaths could be lit, they are unlikely to represent safe routes for vulnerable pedestrians.

6.3. Second, walking routes between Toad’s Hole valley and Goldstone Valley

would have to cross King George VI Avenue, which is perilous for pedestrians, and then pass through the barrier of the beech hedge/wall which has only one opening towards the top of the hill. To reach the opening in the beech hedge a pedestrian at the bottom of the valley would first have to walk all the way up the valley, which has a gradient of about 1:7, then having passed through the gap in the hedge, it would be necessary to walk back down the hill to reach the only point of interest in Goldstone Valley, the shopping parade in Queen Victoria Avenue. This walk would be a challenge for all but the physically fit; older people, disabled people, mother pushing buggies or carrying heavy bags would be unlikely to use walk that way.

6.4. If the through traffic is not removed from King George VI Avenue, then a

footbridge would be essential, which may or may not be aligned with the gap in the beech hedge and in any event the bridge would pose another obstacle for the pedestrian to navigate.

6.5. As there is now only one convenience shop in Queen Victoria Avenue and it

is most unlikely the residents of Goldstone Valley would wish to use the facilities in Toad’s Hole Valley, it is unlikely there would be much, if any, regular footfall between the two neighbourhoods, although there may be some recreational use of such a path.

6.6. Third, access on foot to the Grenadier shopping parade is an important

consideration because it is the main neighbourhood centre in the Hangleton & Knoll area with a wide range of shops and services including a library, chemists, post office, GP surgery, dentists etc. This would be the main local shopping centre for the future residents of Toad’s Hole Valley and walking to the Grenadier would be the only option for those reliant on public transport.

6.7. On the map, the route looks quite straightforward but apart from being a

fairly long walk, it would be seriously adversely affected by steep gradients and heavy traffic. In particular, the walking route would fall steeply to Goldstone Crescent junction at the bottom of the valley before rising sharply up to the junction with Court Farm Road, after which the route is relatively


level. This would not be a pleasant walk because the entire route would be alongside the heavy through traffic that uses King George VI Avenue and Hangleton Road. Anyone with access to a car would find it preferable to travel by car, so again it would be those without a car that would suffer.

7. Accessibility by Cycle

7.1. The remote location would be less of a problem for cyclists, who would be

able to use the highway network to access the Grenadier shopping parade, other local services, central Hove or Brighton. However, even some cyclists may find the steep gradients in and around the valley challenging.

8. Lifestyle Implications of the Valley’s Accessibility

8.1. Given the site’s excellent access to the A27, it would be a very attractive location for those commuting by car to employment in South London, Gatwick and other Sussex towns. Moreover, by using the A27, those with cars would be able to access a wide range of facilities. Thus car users living in the valley would tend to increase their propensity to travel to and from the city by car, thereby increasing, rather than reducing their carbon footprint.

8.2. In marked contrast, as explained above, those dependent on public transport

would rely on local bus services, and the connectivity and frequency of bus services would inevitably be very limited, particularly in the evenings and weekends. The routes would only connect the valley to the centres of Hove or Brighton (not other towns) and journeys to those centres would take as long as trips to Gatwick or South London by car. Public transport dependency would significantly curtail lifestyle choices and this disadvantage would extend to anyone who did not have regular access to a car, not just those living in affordable housing.

9. Correlation between Housing Density and Multiple Deprivation

9.1. It is notable that the Health and Equalities Impact Assessment at page 9

shows that the city’s high-density areas are generally concentrated in the corridors well served by frequent bus services and/or with good access to a railway station, and that is where the Strategic Policies indicate any new development areas should be located.

9.2. In contrast, it is apparent from comparing the maps on pages 9 and 19 that the wards exhibiting the highest levels of multiple deprivation – Hangleton & Knoll, East Brighton, Moulsecoomb & Bevendean – are the wards characterised by higher densities in the more remote locations, away from the main bus corridors.

9.3. This correlation serves to underscore that creating a new high-density

housing area, including 40% affordable, with poor accessibility to the rest of the city by public transport would not be an appropriate use of a greenfield site such as Toad’s Hole Valley.


Appendix 3 Toad’s Hole Valley – Sustainable Construction 1. Housing

1.1. A justification given for releasing Toad’s Hole Valley for development is that the resulting development would be an exemplar of sustainable development, achieving very high standards that are not being attained elsewhere.

1.2. In reality it is most unlikely the new dwellings would be built to Sustainable Homes Code Level 6 partly because of the onerous costs and partly because it is highly likely that local planning authorities will be prevented from requiring higher standards than the Building Regulations.

1.3. Policy DA7 states that not only would all the dwellings be constructed to

Sustainable Homes Code Level 6, but also at least 50% of the dwellings would have 3+ bedrooms (including the affordable dwellings), and policy CP20 states that 40% of the homes would be affordable. These are high expectations and it is most unlikely they would all be achieved.

1.4. In 2010, DCLG’s own review found Code Level 6 construction costs to be

40% to 50% more than the costs for comparable units constructed to the current building regulations (about £35,000 to £45,000 extra). Those costs were updated by DCLG in 2011 and showed additional costs for constructing to Code Level 6 on edge-of-town and greenfield sites to be close to 50%.

1.5. This year a review commissioned by a group of local authorities including the

City Council found that the costs of constructing to Code Level 6 had fallen since 2011, with the principal driver being a significant reduction in the capital costs of photovoltaics and a secondary component being the higher standards now required by Part L of the Building Regulations.

1.6. That report further noted that achieving Code Level 6 remained a challenge,

both in technical and in cost terms, with few examples of completed units. In respect of costs the study indicated at least a 25% cost premium (over base build costs).

1.7. It is not anticipated that those additional construction costs will fall

significantly more because the traditional methods used for house construction are very cheap and very flexible. The modern methods of construction used to make commercial developments more sustainable are much more expensive than traditional housing construction. (Miles and Whitehouse, ‘Offsite Housing Review’, Construction Industry Council 2013)

1.8. However, there is no evidence to suggest that dwellings sold on the open market would achieve substantially higher prices than those in neighbouring areas. In large part that is a reflection of how dwellings are valued. Location establishes the benchmark for house prices in an area thereby creating a price norm for each dwelling type; construction quality has very little impact on price. Also sales evidence indicates that purchasers are unwilling to pay significantly more for units constructed to higher specifications for sustainability. It is, therefore, most unlikely that the sales of market housing would be able to recoup the additional costs of Sustainable Homes Code Level 6.


1.9. Requiring 40% of the dwellings to be affordable and at least 50% of the affordable dwellings to have 3+ bedrooms would require cross subsidy from the market housing as the subsidies from the Homes and Communities Agency are being withdrawn. The burden of this cross subsidy would be additional to the costs of Sustainable Homes Code Level 6 and there no evidence is offered to show that the market housing could afford this level of cross subsidy.

1.10. It is now highly likely that the Code for Sustainable Homes (which is owned by DCLG) will be abolished, with some criteria from the code incorporated into the Building Regulations. Currently the Government is seeking views on the implementation of the Housing Standards Review.

1.11. This review recommends that all the standards concerning housing

construction should be integrated into the Building Regulations with the express aim of preventing local planning authorities imposing higher standards than the Building Regulations. This comes as no surprise, as this approach is strongly supported by all the construction umbrella groups.

1.12. If, following the consultation, the main thrust of the review is

implemented, which is highly likely, the city planning authority wouldn’t be able to require any housing development to attain Sustainable Homes Code Level 6, or any other construction standard more demanding than the building regulations.

1.13. Policy CP8 further undermines the requirement for standards of construction in excess of the building regulations; it says that those higher standards of construction would be required ‘unless it can be demonstrated that doing so … would make the scheme unviable’. So the plan itself is indicating that Sustainable Homes Code Level 6 is not an obligation.

1.14. In any event this site would be expensive to develop because the land is

very steep and the site has no services – no access roads, electricity, gas, water supply, sewerage or cable. Furthermore, the costs of installing all those services, together with the costs of constructing the proposed relief road (or road improvements) would have to be incurred at the beginning of the development period, significantly increasing total development costs.

1.15. The development, it is stated, would protect the aquifer, which would

necessitate measures to prevent surface water being lost via the sewers to the sea or by surface water run off. This would be expensive to achieve and would add further to total development cost.

1.16. All these essential costs would impact on the viability of the development,

reducing the margin for discretionary features. It would thus appear most unlikely that any dwellings constructed at Toad’s Hole Valley would achieve ‘Code Level 6’ or any code level in excess of the buildings regulations. Were that to be the case on any other site, it would not be a matter of great consequence, but in this case exemplary sustainable performance is being advanced as a primary reason for releasing Toad’s Hole Valley for development. In reality, what is likely to be delivered is an unsustainable edge-of-town suburb.


2. Business Development

2.1. There are equally good reasons to doubt that the development would achieve BREEAM Outstanding because the site is in an inherently unsustainable location, whilst accessibility by public transport is a significant component of the BREEAM assessment. As highlighted by the Employment Land Study Final Report, the key attraction of the location for light industry Is the excellent access to the road network, whilst the prospects for bus services to the site are pretty poor – see Appendix 2.

2.2. An outstanding building has to achieve a BREEAM score of 85% and

transport counts for 8% of the score. The proposed location for the B1 development is at the top of Dyke Road Avenue, which has unrivalled accessibility by private car. Currently the only bus service passing the Devil’s Dyke roundabout provides for leisure trips to Devil’s Dyke and any new services into Toad’s Hole Valley would gain access from the bottom of the valley, thereby doing little to improve the accessibility to and from the light industrial park. With such a poor score for transport, ‘BREEAM Outstanding’ would not be a realistic target, even if all other aspects of the development were exemplary.

2.3. Furthermore, as indicated above, policy CP8 states such a high standard

would not be required if “it could be demonstrated that doing so ... would make the scheme unviable”. So, as with housing, construction to BREEAM Outstanding is not an obligation.

2.4. It is the case that business properties constructed to higher standards of

sustainability can in some locations command higher rents. However, a location so far from the main railway stations, the central hub of the city and the universities would be unlikely to be attractive to businesses in the target group (modern knowledge-based companies), so the rents that could be achieved would be depressed. Meanwhile, fledgling and young companies usually look to keep their overheads low by seeking units with low rents and ‘easy-in easy-out’ terms, quite the opposite of the high quality, high rental space that is proposed.

2.5. This assessment is borne out by the Employment Land Study Final Report,

which indicates the site would be most suitable for a light industrial park. That review also highlights that this would be a very poor location for employees, as they would not have ready access to shops, cafés, medical facilities or other amenities. Good access to a wide range of facilities contributes significantly to the quality of an employee’s working life.

2.6. For these and other reasons, it is most unlikely that any floorspace

constructed at Toad’s Hole Valley would achieve BREEAM ‘Outstanding’ or any other standard in excess of the buildings regulations. In reality, what would probably be delivered would be a fairly standard edge-of-town light industrial park.


PAGE INTENTIONALLY BLANK TO AVOID PRINTING PHOTOS DOUBLE-SIDED


Appendix 4 Photographs of Toad’s Hole Valley

Taken from Downland Drive in February and July 2013, looking towards the national park and showing the sweep of the South Downs uninterrupted by the thin line of the A27 trunk road.


PAGE INTENTIONALLY BLANK TO AVOID PRINTING PHOTOS DOUBLE-SIDED


Both taken from King George VI Avenue in July 2013 with the Toad’s Hole Valley in the foreground. Above looking towards Shoreham, with the national park to the right of the A27, and below towards Truleigh Hill.

Documents

Campaign to Save Toad’s Hole Valley REP/29 APPENDICES ... · REP/29 APPENDICES Supporting Statements about EIP Matters INDEX Appendix 1 Case for Continued Downland Protection Pages