Ansty and Staplefield Parish Council

Responses to the Ansty and Staplefield Neighbourhood Development Plan Consultation (Regulation 14) which ran from 14/7/15 to 8/9/15.

Responses from Ansty Residents/ Developers:

Lynne and Nigel Pink Page 1Suzanne and Tony Mace Page 2Mr and Mrs Utting. Page 3Keith Evans Page 3Brian Griffin Page 4Paul and Chris Dupee Pages 7-6Gerard Conway Page 7Turley on behalf of Countryside Developments, promoting Bolney Road site Pages 7-10Parker Dann on behalf of Norris Farms, owners of land at Ansty Farm. Pages 11-15

1. Lynne and Nigel Pink

In regards to the proposed development of land bolney road.

We have lived on this road since 2002 and have noted the increase in traffic, bolney road is used by traffic when joining the Cuckfield by pass and is extremely busy with commercial vehicles of all sizes. The Sainsbury's lorries are a constant but they are only a small part of the heavy load both from the A23 onto the Cuckfield bypass and the Burgess Hill road. The road is in constant use by the emergency services. When we have issues on the A23 the bolney road is used as a run off from the A23 causing gridlock.it is a very well used road and we have problems exiting our drives as many other residents do. It is also dangerous walking along the path as the traffic does not abide by the 30 mile speed limit, which the police will not enforce as it is too dangerous to do so.

As for public transport if any of the Parish council use the buses they will know we have a school bus around 8.30, a bus at 11.38, one at 2.38 and the final one at around 5pm going to Haywards heath. If you catch any of these you have about 15 minutes in town before boarding the one bound for Horsham otherwise the wait is 2 hours or as in the later one no return, there are no buses from Ansty into Burgess Hill.

If you wish to walk to Burgess Hill there is no Footpath either.

I have been informed that the piece of land has already been looked at and is deemed

'Not currently developable' and 'unlikely to be delivered'. See Mid Sussex SHLAA 2015 paper Site reference 629 (AS/09)

We note that Ansty would seem to be the target for the biggest development, am I right?

Staplefield has a (one) development, Brook street seems to have none.

Ansty is on the cards for two developments one for 10 houses on the Burgess Hill road and one on Deaks Lane for 17 houses. Some of the residents seem to have been unaware of these planning applications.

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We were told that the development of the Ansty Cross would include an underground car park however that did not happen but the owner has only 6 car parking spaces for two houses and 5 flats (one retrospectively) on the planning application it calls for the need for 'associated car parking and landscaping' the car parking is below minimal and the only landscaping is on the fantasized picture adorning the hoarding in front! and what has happened in regards to the two terraced houses next to the garage they have blighted the adjoining,once detached house, making it a terraced also.

We call that over development! what will happen to all the planned development here? Developers always want more.

This is not the place for it.

2. Suzanne and Tony Mace

We are opposed to the proposal to develop land in Bolney Road (A272), Ansty

We have lived here since March 1992 and despair of the increase in traffic during that time in spite of an additional road off the A23 to take heavy traffic to Burgess Hill and its environs. Our speed limit, after much agitation, has nominally been reduced to 30 mph from 40 mph, although the majority of traffic using it seems not to take any notice. It is almost impossible to walk safely along the footpath because when the heavy lorries such as the Co-operative's and Sainsbury's pantechnicans drive past its feels as though you are being sucked off your feet. Trying to drive into Haywards Heath or indeed Cuckfield during the rush hours is avoided whenever possible as the A272 is used as a rat run from the A23 for both Haywards Heath and Burgess Hill. The mini roundabout in the centre of Ansty is regarded as a continuous right of way for those drivers coming up from Burgess Hill and anyone coming out of or trying to get into the CMW Garage for car servicing is very lucky not to have to leave their car for bodywork repairs.

I have never bothered to get a bus pass as the service is very sparse with the school bus at around 8.30 am, the next bus is at 11.38 am and after that 2.38 pm with the final one of the day at 5.00 pm, no good for going to the theatre or cinema. These are all buses into Haywards Heath, well sometimes Burgess Hill is the destination and for that there is nothing.

Our village currently has around 70 homes, not counting those presently under construction which have yet to sell. There are about 10% of those homes for sale currently and these have mostly been for sale for some time. The proposals under consideration or indeed passed would add around 27 properties (plus those recently constructed), that is assuming that plans submitted would not increase the density on a given site. It does seem that plans are put forward, objections raised, objections overruled and then the plans altered after that decision has been taken., as in the case of the Ansty Cross development as this was supposed to have an underground car park, the projected 6 car parking places allocated at present for 2 houses and 5 flats would seem to be unrealistic given the lack of public transport for travel to work.

Next to the recently enlarged garage there was a semi-detached pair of houses. Another house has been built attached to the first of this pair which now makes it a terrace of three properties, not very nice for the original semi-detached house which must have suffered a loss of value as it is now "end of terrace". The properties in the terrace can hardly be described as "affordable" accommodation as indeed I suspect will be the case with the Ansty Cross development. We were

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surprised that the building line was not set back further from the roundabout with this development, having it as a pub on the roundabout was bad enough but living on the roundabout will be very stressful. there is no room for landscaping as was originally intended.

Please don't swamp our tiny rural villages with developments we don't want, for which there is no planned additional infrastructure, and which may encourage more people to live in our delightful area of outstanding natural beauty, but they will most probably not join in with the limited amenities which already exist and hence will add nothing to the well-being of the community.

Once our agricultural land is built on it is very rare for it to be returned to its original purpose, and we need to produce all the food we can for ourselves.

3. Mr and Mrs Utting.My name is Ricky Utting and I live at Oakdene, Bolney Road, Ansty with my wife Sharon and son Nathaniel. I'm writing regarding our concerns about the proposed development of agricultural land in to houses on the field opposite our property. One of our concerns is that we have not received any formal information from any official department about this proposed development. All the information we have obtained about the development has come from Mr & Mrs Griffin who live at Harwood, Bolney Road and who have been kind enough to pass it on to us.

We have in the past been in touch with Sussex police regarding the speeding along Bolney Road and asked what could be done about it and if there was any chance of the local policing traffic unit to set up a speed check. The answer we got back from Sussex police was that it would not be possible due to the bends on the road not giving them enough distance to get a correct speed on the speed gun and that it would be to dangerous to stop vehicles along Bolney Raod!!!! If it's to dangerous for police to stop vehicles on Bolney Road then why would the council consider granting planing for more houses which in turn would mean more traffic coming onto Bolney Road on these blind spots. Every time we leave our driveway my wife and I have to take our lives in our hands due to the blind bend we live on and the speed that the traffic comes round the bend.

Please feel free to contact me regarding the above.

Keith Evans – response 1

We would like to comment on the proposal of AS6 in Ansty.

We understood, that when developments are granted to Rural Villages, that one of the criteria was for them to fit into the Existing Village,However this Proposal, We think will actually Dominate the Village of Ansty.The reason for this is that the proposed Development is at the Highest point in the Village at a height of 79 metres.The shared drive with my Neighbour in “Leafield”, Has the 75 metre “ Trig line “ passing through it.This means that the proposed housing will be 4 metres / 12 feet above my Drive entrance, My house is about 1 metre lower than this.In New developments in Haywards Heath, We have seen the construction of many 3 Story Houses.

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These would be inappropriate on this site. The present tree line to the south of the A272 maybe used as an argument by the developer to ensure screening,However we have seen this abused in the past, When trees suddenly get taken down without permission.The development in Folders Lane Burgess Hill is a good example of this. The other issue is, that the type of housing in the proposed development , Has not been matched to existing HousingIn the proposed Layout. Our next concern is that entrance to the proposed site has not been considered correctly.We understand that the Highways Agency has recommended a change to the Parish Councils original preferred entrance spot,Which made more sense. The A272 had its speed limit in the village reduced a few years ago, under the auspices of improving road safety.This really is a myth, the speed of traffic seems not to have been calmed much at all. The Police at the timesaid they would be unable to enforce it, which is what has happened. Also volume of traffic since the opening of the Haywards Heath By pass, seems to have increased dramatically,Perhaps due to a change to signage? And we think this has not yet been taken into account.During peak times the Traffic tails well back to the west of the village, so I feel that any new road entrance will compound this problem. We would appreciate If you could forward our comments on.

Keith Evans – response 2Further to my comments which I sent to you last week, I would like to add some more comments before the closure date.

I understand that there is a ‘Ransom Strip’ along the Bolney Road which I presume was put into place by the County Council to stop such developments as proposed at site 629. Another concern is regarding drainage, which would need considerable improvement, if this site is to be recommended. A further issue is why this site is not included in the Mid Sussex Draft District Plan dated June 2015, but is now being put forward even though Mid Sussex rejected this site as unsuitable by its SHLAA team? I think most residents along the Bolney Road would agree strongly with the overall conclusions in their Professional report.

4. Brian Griffin

7th September

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1. We are surprised and concerned, especially living on the Bolney Road at Ansty, as to why agricultural land on this particular section of the Bolney Road has been given the green light in the above Neighbourhood Plan for not just a housing development, but the main housing development in the whole of the Ansty & Staplefield area.  (Apparently, land in Staplefield is not being selected for development asit is designated an ANOB).  See the Mid sussex SHLAA 2015 paper Site Reference 629 (AS\09) Land at Bolney Road for a comprehensive explanation as to why this site is considered to be 'Not currently developable' and 'unlikely to be delivered'.

2. The A272 on this section of the Bolney Road has a 30 mph speed limit.  Noticeably, in the last few years the speed and volume of traffic, especially heavy goods vehicles including 5 axle vehicles, has increased markedly.  Recently, a neighbour who is fairly new to the area, tried to find out why there was obviously nothing being done about the violation of this 30 mph.  He eventually received a reply from the police basically saying that it would be too dangerous to try and enforce this limit in the village.  This follows what we were told at a meeting a few years ago.

It would be a good idea if anyone who recommended this site - councillors or otherwise - tried walking along the footpath, exiting our properties by car, or crossing from the Bus Stops on either side of the Bolney Road.  It might be then realised how dangerous it would be if vehicles from another 18 houses were to exit on this road.

8th September

Could you please confirm that you received our email re comments on the Neighbourhood Plan yesterday, 7th September 2015...our email was 'playing up'.

Also, We would like to reiterate our request made at the July 25th discussion in Ansty that a mail shot is sent to everyone in the village when the next draft plan is produced.  Several people I have met who live on the Bolney Road have no idea what is happening.  These particular neighbours are working families with young children, did not received any emails re July , and are 'not happy'!

We do not mind delivering an mail shot in Ansty village ourselves if help is required.

5. Paul and Chris Dupee

31st JulyI would like to make the following comments:-

As the owner of Leafield in Ansty we are directly opposite the proposed AS6 policy proposal. The land proposed for development is on a level about 2 meters higher than the road and our property. With new houses often 3 stories high nowadays it would mean the new dwellings would look down straight into our house and our neighbours houses and be very intimidating. In fact, the submission by the owners of that land has just that scenario for that part of the site.

We would like to have an additional condition, either included as part of no.89 or within the criteria of AS6 in the plan to mitigate future problems. Suggested wording could be along the following lines....

"Any development in AS6 would need to ensure that the height of any properties close to the A272 is minimised to reduce as far as possible any invasive and intimidatory impact on the existing houses on the opposite side of the road. This could involve use of single storey dwellings or garages nearby the A272.".

We also fully support maintained trees along the boundaries of the site.

We are concerned at the increase in traffic on a currently extremely busy main road, both from the additional traffic from developments to the north of Burgess Hill, and from the existing and proposed developments in Ansty.

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We also believe that the absence of a bus to Burgess Hill from Ansty will become increasingly difficult for residents to travel to required facilities. The existing number 271 from Crawley to Brighton goes from Cuckfield to Burgess Hill via Isaacs Lane, along which there are no villages. Diverting route to Burgess Hill via  Ansty should be more lucrative and be possible to provide service to/from Warden Park School.

We hope above comments are reasonable and constructive.

5th September

Having attended the Staplefield Village hall consultation on 5th Sept, where issues were discussed with Jon and Brad, we would like to comment as follows:-

The issue is why was the Bolney road site chosen for the NP instead of Challoners, considering the district plan assessment of the 2 plots was "not currently developable" for Bolney Road and "developable in time frame 6yrs to 2031" for Challoners.

Apparently, Challoners was not considered as it had not been submitted before the deadline. (On checking pc website afterwards it would appear that the Challoners plans were listed under an entry of 19th Oct 2012, with the deadline of July 2013 so maybe the pc website is wrong.)

Anyway the chronology of events is not the main issue of today with the NP still in draft form and consultation nearly complete. The main issue is, given the information available today, which is the most suitable site of those deemed develop-able before 2031. The 2015 MSDC assessment clearly thinks Challoners is develop-able, and Bolney Road not.

The reasons being the Challoners site would have/be  :-

-  easier access onto "B" road, rather than very busy "A" road, and easier to implement the access.-  more land (0.76 vs 0.5 hect), 

 -  does not have the intimidatory aspect of development on higher ground over existing properties - in fact houses on the Bolney road site would be at the highest point of the village (74m) and dominate the village.

-  less visually intrusive in landscape

-  not detract as much from existing village character (if 2015 assessment followed by not demolishing Challoners).  

Although we admit to being an interested party and would personally be less affected by the Challoners site we believe the case for it are more compelling.

We would therefore ask the committee to reconsider NP plan sites and decide which one is preferable for the village, given all the information available today.

Acknowledgement that main addressees have received these comments would be appreciated.

Thank you in anticipation

7th September:

Thanks for your reply Liz confirming Challoners was considered. This only makes us more confused. 

One of us has been to both public meetings, and read the draft NP, and we have not seen or heard any sound reasons for the choice of Bolney Road site, especially considering the MSDC assessments which were updated only this year and which are part of the proposed District plan. The NP draft proposals fly in the face of those assessments, resulting in differences between the 2 plans, so one would expect there to be compelling reasons for the NP to be different. As yet, we cannot understand how public spirited council members acting impartially could arrive at such a decision.We would appreciate acknowledgement that you have received this and that together with our other 2 comments they will be included formally as part of the NP consultation process.

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6. Gerard ConwayThank you for the opportunity to submit comments on the above plan. As a resident of the parish, I am very grateful to the Parish Council for its work in establishing the plan. It is clear that a tremendous amount of thought and care have gone into its preparation. I have one comment, which relates to Policy AS12. The objective of the policy is clear to me. However, I wonder whether the proposed criteria for establishing redundancy could subject the Parish Council to lead to unforeseen consequences. Here I refer to the: • 12 month period over which a building must be redundant; and • 6 month period over which it must be marketed. Loss of rent during a 12 month period may be relatively insignificant when compared to the uplift in capital value of a building from its conversion from business to residential use. Consequently, a freeholder could offer a property for rent at an inflated price so as to deter prospective tenants and thus support the claim of redundancy. Valuation reports may also be prone to distortion. Separately, at times of economic stress such 12/6 month periods may be too short. The 2008 economic downturn continued well beyond 12 months. If business use buildings are prematurely withdrawn under such a scenario, economic recovery could be hindered. MSDC’s approach to drafting around this issue appears to take a more subjective approach. Policy DP-2 of the draft MSDP, (Sustainable Economic Development) states : “Protecting allocated and existing employment land and premises (including tourism) unless it can be demonstrated that there is no reasonable prospect of its use or continued use for employment”. I wonder whether a similar approach based on “reasonable prospect” would give the Parish Council better protection against possible attempts to abuse AS12, as well as against other anomalies?

7. Turley on behalf of Countryside Developments, promoting Bolney Road site.REPRESENTATION ON BEHALF OF COUNTRYSIDE PROPERTIES TO THE ANSTY AND

STAPLEFIELD NEIGHBOURHOOD PLAN 2015-2031

We are pleased to have this opportunity to comment on the pre-submission consultation draft (Regulation

14) of the Ansty and Staplefield Neighbourhood Plan 2015 - 2031. Turley is acting on behalf of

Countryside Properties who are promoting land south of Bolney Road for residential development.

Our client welcomes the proposed allocation of the site and is looking forward to working with the local community to bring forward a successful residential development. As part of this process our client has already commissioned detailed site assessment and master planning work in order to better understand the opportunities and constraints at the site. This information will be used to inform the number of units, layout and design of a detailed scheme, ahead of the future submission of a planning application.

We are now pleased to provide our detailed comments on the plan, which are set out in the table below.

Paragraph / Policy Comment

Ansty and Staplefield Plan 2015 – 2031

P.3, para. 1.7 Relationship with the District Plan

The Neighbourhood Plan (NP) is being brought forward in advance of the

District Plan (DP) and as a consequence may need to be amended or updated to reflect any changes that are made to the DP before it is adopted. We would suggest that this relationship is explained within the NP along with the review

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timescale and process for updating the plan.

Paragraph 184 of the National Planning Policy Framework (NPPF) states: “The ambition

of the neighbourhood should be aligned with the strategic needs and priorities of the

wider local area. Neighbourhood Plans must be in general conformity with the

strategic policies of the Local Plan.”

As the pre-submission version of the DP was only published in June 2015 and will be

subject to further consultation and a public examination, which is likely to lead to

further amendments, the NP must offer a degree of flexibility to ensure that it can

remain consistent with the strategic policies set out in the DP.

Explain process and timescale for reviewing the plan in light of any conflicts with the final version of the District Plan.

P.15 Vision for Ansty and Staplefield

The vision statement includes the aspiration to see ‘no significant expansion’ of the villages Ansty, Staplefield and Brook Street. This statement is considered to be vague and does not appear to be supported by clear evidence.

We would suggest that the word ‘significant’ is replaced by ‘harmful’ as this can be judged on a case by case basis, whilst the quantum of appropriate development can be better defined in the more detailed policies within the plan.

Change wording of first paragraph to state: ‘In 2031 the villages of Ansty, Staplefield and Brook Street will remain distinct communities from the larger nearby towns and villages such as Burgess Hill and Cuckfield, having seen no significant harmful expansion of their settlements into the surrounding countryside’.

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P.18 Built-up area boundary

The diagram on p.18 of the NP which accompanies Policy AS1: Built up area boundary is considered to be a little bit misleading because the outline of the area does not accord with the built-up area in the adopted Local Plan. The northern extent of the boundary extends further north beyond Deaks Lane than that shown in the Local Plan.

The diagram on p.18 should be amended so that the built-up area boundary accords with the Local Plan, with the exception of the extension to accommodate the two residential allocations.

P.22 Housing mix

Policy AS4: Housing Mix requires new developments to provide a mix of dwelling sizes (market and affordable) that best reflect the housing need evidence. This approach broadly follows the guidance in para. 50 of the

National Planning Policy Framework. Whilst our client supports this approach it is considered that the requirement for the majority of dwellings during the early part of the plan period to be brought forward as 1 and 2 bedroom dwellings is too prescriptive and unrealistic in terms of the established context of the settlements. It would also be likely to lead to new development that was highdensity and out of character with the existing village. It is therefore suggested that the wording should be changed to require a proportion of 1 and 2 bedroom dwellings in all new residential developments.

The second paragraph of policy AS4 should be replaced with the wording ‘Residential developments shall include a proportion of 1 and 2 bedroom dwellings to meet current housing needs’.

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P.23 Residential allocations

This section of the plan references the housing figures that have been included in the Pre-Submission draft of Mid Sussex Council’s District Plan, which will cover the period 2014 - 2031. This document was published in June 2015 and will be subject to public consultation and further scrutiny through the Local Plan examination process. Given the early stage of the District Plan, the Neighbourhood Plan should provide flexibility over the eventual quantum of housing that it is proposing over the plan period. This should be achieved through a monitoring process, to enable further housing sites to come forward if required.

If the Neighbourhood Plan does not provide such flexibility, it may render itself out of date more quickly, which in turn could create additional pressure for Mid Sussex to produce a separate Site Allocations document identifying further residential sites in the village. In addition an out of date Neighbourhood Plan, may make the village more vulnerable to speculative residential developments outside of the built-up area boundary.

Our client controls further land to the west of the proposed allocation at Land off Bolney Road (policy AS6), which is also considered to be suitable for residential development. This site should be considered as a potential allocation or expansion of the existing allocation if further housing is required in the village.

The Neighbourhood Plan should provide more flexibility over the provision of housing sites between 2014 and 2031 and include a monitoring policy to assess the progress of housing development in the Parish.

Consideration should be given to the inclusion of land to the west of the existing allocation (policy AS6) to provide further housing within the village.

p.25 Land off Bolney Road, Ansty

Our client supports the allocation of this site for housing and considers that it provides a logical expansion of the village. Our client is in the process of undertaking detailed assessment work to determine how the site can be successfully developed. This work will inform a detailed design, which will then

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be discussed with the local community ahead of the submission of a planning application.

Para.6.14 refers to vehicular access to the site and suggests that this should be gained from the south-western corner. This reference is included in the third bullet of the policy AS6. Whilst our client’s consultant team are currently investigating the most appropriate access point, this is likely to be located somewhere along the northern boundary, to connect to the Bolney Road (A272). It is suggested therefore that the reference to access should either be changed or omitted.

Para 6.16 suggests that the site is suitable for development of approximately 18 dwellings. Our client’s initial capacity work suggests that the site is likely to be capable of accommodating between 20 and 30 dwellings. The precise number of units will be dictated by the location of the access, site constraints and housing mix. At this stage it is suggested that the supporting text to the policy should acknowledge that the site is capable of accommodating a higher number of dwellings pending further site analysis.

Reference to the vehicular access in policy AS6 should either be amended to refer to the northern boundary or omitted.

The supporting text to proposed housing allocation at land off Bolney Road should acknowledge that the site has capacity to accommodate between 20 and 30 dwellings.

Summary

In summary our client is pleased to have this opportunity to comment on the pre-submission consultation draft of the plan and has set out the following broad comments:

• The intention to produce the Neighbourhood Plan ahead of the District Plan is welcomed,

but the Neighbourhood Plan must include mechanisms to set out how it will be updated to

ensure it remains in general conformity with the District Plan.

• We support the general vision for the Parish set out in the Neighbourhood Plan, but believe

that the current wording is too subjective. We therefore suggest that reference to ‘no

significant expansion’ is removed and replaced with ‘no significant harm’.

• The built-up area boundary in the plan should be amended to accord with that shown in the

District Plan, subject to the proposed amendments.

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• We support the overarching objective of policy AS4: Housing Mix, but consider in its current

form it is too prescriptive and does not respect the established form of the Parish.

8. Parker Dann on behalf of Norris Farms, owners of land at Ansty Farm.Introduction

Following the publication of Ansty Parish Council’s Neighbourhood Plan for consultation under Regulation 14 – The Neighbourhood Planning (General) Regulations 2012, please find below our comments made in respect of the Plan on behalf of our client Norris Farms Limited.

We would like to preface our comments by acknowledging that the Neighbourhood Plan Steering Group have had the task of preparing a Neighbourhood Plan somewhat thrust upon them by Mid Sussex District Council. The District Council’s approach designed to supposedly embrace localism has been testing for many Parish Council’s to understand particularly given the lack of clear guidance on how many dwellings each Parish / Town Council should be planning for. Bluntly Mid Sussex District Council has asked groups of enthusiastic amateurs to produce detailed documents that stand up to professional scrutiny. In this context the Neighbourhood Plan Steering Group should be commended for its hard work and dedication and we acknowledge that some errors are almost inevitable.

In the preparation of our representations we have reviewed the requirements under paragraph 8(1) of Schedule 4B to the Town and Country Planning Act 1990 to confirm that:

• the policies relate to the development and use of land for a designated Neighbourhood Area in line with the requirements of Section 38A of the Planning and Compulsory Purchase Act (PCPA) 2004;

• the Neighbourhood Plan meets the requirements of Section 38B of the 2004 PCPA (the Plan must specify the period to which it has effect, must not include provision about development that is excluded development, and must not relate to more than one Neighbourhood Area);

• the Neighbourhood Plan has been prepared for an area that has been designated under Section 61G of the Localism Act and has been developed by a qualifying body.

We are satisfied that this is the case.

We have assessed whether the draft Plan meets the Basic Conditions as set out in paragraph 8(2) of Schedule 4B of the Town and Country Planning Act 1990 following the Localism Act 2011. In order to meet the Basic Conditions, the draft Plan must:

• have regard to national policies and advice contained in guidance issued by the Secretary of State;

• contribute to the achievement of sustainable development;

• be in general conformity with the strategic policies of the development plan for the area.

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On these points we have serious concerns with the Parish Council’s draft Plan. The Parish Council appears to have acted unilaterally in an attempt to garner public support and has not paid due consideration of the evidence base which should have been informing its decisions. In our view, should the Plan be submitted for Examination in its current form, the Examiner would recommend that the Plan does not proceed to Referendum, on the basis that it does not meet the relevant legal requirements. To assist the Parish Council we have identified the areas of concern, explained the problems and recommended solutions.

We accept that the Neighbourhood Plan falls to be considered against the Mid Sussex Local Plan 2004 in terms of its strategic policies. This is a regrettable situation for both the Parish Council and landowners in the Parish as the Neighbourhood Plan could very swiftly be out of date following the adoption of the emerging Mid Sussex District Plan which has will shortly be submitted to the Planning Inspectorate for independent examination. This state of flux most pertinently affects housing provision. We therefore urge the Parish Council to consider carefully the emerging District Plans evidence base when determining the level of housing it seeks to accommodate. It should also be borne in mind that the housing numbers for the District as a whole are far more likely to go up as a result of independent examination than down. This has been a trend evident across the south-east and locally in Lewes District, Brighton and Hove City and Horsham District very recently.

The Ansty & Staplefield Neighbourhood Plan 2015 - 2031

On the emerging plan itself we have some general comments although it is fair to say our primary interest relates to the level of housing provision and the distribution of the provision throughout the Parish.

On page 3 of the emerging Plan reference is made to the consultation that has taken place. It includes a Parish wide Housing Needs Survey. This document dates from March 2012 and is therefore three and a half years old. In our view it therefore does not provide a suitable basis for the estimate of housing needs and should be updated prior to using it to inform the level of housing provision within the emerging Plan. The document should also include an estimate of the quantum of market housing required.

If the document were used, it identifies that 26 households are in need of housing. Having regard to Policy DP29 in the emerging Mid Sussex District Plan the ASNP would deliver just 6 affordable dwellings to meet this need. This sits uncomfortably with national planning policy which requires full, objectively assessed needs for market and affordable housing in the housing market area providing this is consistent with other polices elsewhere in the National Planning Policy Framework (NPPF) (see paragraph 47). In its current form the ASNP would clearly not achieve this aspiration in conflict with the Basic Conditions.

The vision for Ansty and Staplefield on page 15 indicates, inter alia:

“Ansty will have accommodated new housing to help meet the demand and need for new and affordable homes by using land within or close to the established settlement boundary.”

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Whilst the aspiration to help meet the demand for housing is laudable, national policy is clear that the full housing need should be met for the area. As currently worded the vision seeks to meet only a portion of the housing need. We note that the Ansty Farms North site is close to the (emerging) established settlement boundary and could readily assist in providing new market and affordable homes. These comments are also relevant in respect of the Neighbourhood Plan Objective 3.

The Neighbourhood Plan seeks to introduce a built-up area boundary. It indicates the purpose of a boundary is to help prevent sprawl. We agree with the comments made at 4.2 of the emerging plan that development will (and should) be focused on Ansty.

However, the introduction of a development boundary for Ansty will perhaps have some unintended consequences. It will lead to the de facto allocation of additional land in the settlement which is highly unlikely to deliver affordable housing. The introduction of a built-up area boundary read in conjunction with Policy H3 of the Mid Sussex Local Plan 2004 would mean that infill housing and the demolition of existing properties and the erection of multiple replacements would be acceptable in principle subject to the criteria in the policy. This has the potential to dramatically change the character of Ansty. Several houses benefit from large gardens and these could be infilled with multiple dwellings essentially meaning that sites which perform poorly in the Sustainability Appraisal and are not favoured for development by the public still come forward. This is inappropriate and we strongly suspect the implications of AS2 are lost on the vast majority of the Parishioners. We suggest that the imposition of a development boundary is carefully reviewed particularly given that Question 16 of the Parish Survey confirms that less than 50 per cent of respondents support this policy. 50 per cent of course being the necessary percentage of favourable respondents required to carry a Neighbourhood Plan through Referendum.

Local Gaps are addressed by the Plan on page 4. Paragraph 4.7 acknowledges emerging plan policy DP11 of the District Plan and accepts that local gaps can be introduced where here is robust evidence to support their use. The Neighbourhood Plan provides no such “robust evidence” and therefore policy AS2 should be deleted.

In terms of residential site allocations, the plan provides for these in Section 6 beginning on page 23. Paragraph 6.3 is incorrect in its assumption that as part of the Northern Arc development will address a significant portion of Ansty’s need. This development will address the needs of Burgess Hill primarily although it is accepted that there is some capacity in the allocation for the wider needs of the District (including Ansty and Staplefield Parish’s unmet need) to be accommodated at Burgess Hill. This is an argument which if repeated by every Neighbourhood Plan Steering Group would quickly see the capacity diminish.

Paragraph 6.5 is incorrect in its assertion that 26 dwellings plus “inevitable” windfalls are sufficient to address the needs of the community and the wider needs of the emerging Mid Sussex District Plan. We do not regard windfall sites as inevitable whatsoever, they are by their very nature hard to predict. The Plan provides no evidence of historic windfall sites covering the previous 20 year period to show that further windfalls are likely. The affordable housing need alone, based on the Parish Council’s own evidence base, is 26 dwellings yet the current proposals will deliver just 6.

The figure of 132 dwellings identified in paragraph 6.5 is not theoretical. It is the Council’s best estimate at the objectively assessed housing need which national planning policy instructs Local Planning Authorities to meet in full. In this case Mid Sussex District Council has absolved itself of responsibility and foisted it upon Parish Council’s preparing Neighbourhood Plans to justify their housing numbers. The Neighbourhood Plan contains scant justification for a number so far below

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the objectively assessed housing need. We suggest the amount of housing provision is increased significantly.

It is welcome that the Sustainability Appraisal acknowledges that the land at Ansty Farm North is the most sustainable site. We also welcome the acceptance that the site represents a sustainable allocation although not one necessarily supported by the entire community. At this juncture it should be noted that the Ansty Farm North site actually performed very well in the first preference voting. In our view public opinion should be given less weight than usual in the formulation of the Neighbourhood Plan because, as the aggregated preferences show, nearly 4 times as many people filled out the form expressed No Opinion as those who voted for the next most popular choice Barn Cottage. Given this lack of strong opinion from local residents the findings of the Sustainability Appraisal should be more closely followed leading to the allocation of Ansty Farms North.

Turning to the Sustainability Appraisal itself, we would like to reiterate our approval for the acknowledgement that the Ansty Farm North site is the most sustainable site in the Assessment of Neighbourhood Plan policy options relating to AS5 and AS6. It would be helpful if this table contained a key. Assuming that red is bad and green is good, we would welcome an explanation as to why Ansty Farm North site would have a red - - impact on social objection 1 housing. We anticipate this is a typographical error as it is inconceivable that providing housing on a site will have a negative impact on the availability of housing.

Given that the Ansty Farm North site has the highest number green boxes (and one more to come once the typographical error has been corrected), it can therefore most readily contribute to the achievement of sustainable development as required by the Basic Conditions. This approach should be taken rather than one which simply seeks to garner public opinion. The Ansty Farm North site should be allocated for residential development. We would be happy to discuss the development with the Parish Council and how it might also contribute to affordable housing delivery if the Parish Council is minded to embrace our representations.

Conclusion

The draft Ansty and Staplefield Neighbourhood Plan has been thoroughly prepared through a transparent process undertaken in a professional manner. Regrettably the outcomes of this process are not manifested in the draft Neighbourhood Plan and we are unable to support it in its current form. In our view the draft Plan would not meet the Basic Conditions as set out in Paragraph 8(2) of Schedule 4B of the Town and Country Planning Act 1990. We have suggested modifications to assist the re-drafting of the Plan and would be happy to discuss these further with the Parish Council and its advisors if this would be helpful. Similarly if there is any aspect of our representations which the Parish Council would appreciate further explanation on, we would be pleased to provide it.

If substantial alterations are not made to the draft Plan we will continue to oppose the Plan when it is submitted for Examination.

• The proposed housing allocations within the Neighbourhood Plan are welcomed, but the

plan needs to include more flexibility should the overall requirements increase.

Consideration should be given to the inclusion of land to the west of the proposed

allocation within policy AS6: Land off Bolney Road, Ansty.

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• We support the allocation of land off Bolney Road as a residential allocation, but consider

the capacity of the site has been underestimated and the likely location of the vehicular

access incorrectly referenced.

We trust that these comments are helpful and look forward to participating in the next stage of the plan. In the meantime we would welcome the opportunity to meet with the Parish Council to discuss our comments and our current proposals at land off Bolney Road.

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