CPRE Sussex responds to the Mid Sussex Sites Allocation DPD consultation

CPRE Sussex has made a submission to Mid Sussex District Council (MSDC) on its draft Sites Allocation DPD.

Our main points are:

The draft DPD document proposes sufficient sites for allocation to enable MSDC to more than meet its total housing target for the remainder of the life of its Local Plan to 2031 (subject, of course to the required 5 year review of the plan due in 2023).

Overarching themes in our submission include:

• With 60% of Mid Sussex designated as National Park or AONB or SSSI, there is an environmental constraint on the District’s capacity to absorb ever-more housing, especially in terms of absorbing overspill from neighbouring districts (This comment really just a flag ahead of the 5 yr plan review);
• MSDC needs to do more work on the deliverability of town centre locations as that may enable them to switch away from allocating so many greenfield sites. We have in mind particularly the possibility of reviving the stalled Burgess Hill Town Centre scheme by exploring whether its viability could be improved with more housing and in place of shopping mall space; and the potential for regeneration opportunities elsewhere in the District;
• our view that the Habitats Regulations are not being properly applied in site selection for the required restoration of Ashdown Forest’s degraded habitats, and SANGS are an unproven avoidance solution to visitor disturbance affecting protected birds on the SPA site there;
• MSDC should not be selecting greenfield AONB sites for major housing development ahead of other sustainable non-AONB sites when MSDC’s own assessment concludes that development would cause “moderate” harm to the High Weald given MSDC’s legal + NPPF duty to conserve and enhance the High Weald’s natural beauty. On the other hand we support the principle of small-scale development within the High Weald on rural exception sites and in other sustainable locations, including sustainable brownfield sites, where that development is focussed on providing affordable and social housing and employment for local people;
• MSDC is proposing to change its air quality policy in its Local Plan, but its new draft policy is still far too vague.
• MSDC needs to develop a climate change policy as part of its Local Planning Framework, and apply more stringent criteria to its consideration of design in planning applications;
• we offer restrained comments on individual proposed site allocations, but do advocate the de-allocation of a small site that is identified as a Local Green Space in Burgess Hill’s neighbourhood plan.
• there is no sign of a site within Mid Sussex to accommodate any of the proposed Mayfield Market Town development. Mayfield’s ambition seems to have been scaled back somewhat, at least for the time being, and focussed wholly on Horsham.

There will be a second public consultation round on the allocation of sites within Mid Sussex next year. The 5 year review of MSDC’s Local Plan gets under way in 2021.

The full submission can be downloaded below.

Letter: MSD sites allocation [PDF 528KB]
CPRE Sussex Response [PDF 83KB}