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Mid Sussex District Update January 2023

10th January 2023

CPRE Sussex news – what’s been happening in Mid Sussex July – December 2022

Everything else

Our ordinary work monitoring the potential impact of larger scale development proposals within the District against our countryside and rural vitality charitable purposes – and making representations to the decision makers in Haywards Heath when those proposals raise issues of concern – took a back seat during the second half of 2022 with little of concern happening.  We will be looking at a recent application by the Bluebell Railway to re-open part of the old rail line extension between Horsted Keynes and Haywards Heath to see whether we can offer a positive contribution to the outcome in terms of by pressing for measures to ensure that any adverse ecological, noise and landscape impacts are minimised.

Center Parcs has yet to turn its threat to build a huge leisure facility in the middle of the environmentally precious Oldhouse Warren into a planning application; meanwhile we keep a close eye on the situation.  We noted with satisfaction that neighbouring Crawley Borough Council voted unanimously on a cross-party basis to oppose the application as and when it is submitted – as will a coalition of leading environmental charities with whom we are working, and a local group called Protect Oldhouse Warren.

Whilst no significant new planning applications or appeals came forward during the last six months, we still await determination early in 2023 of two applications submitted in earlier periods: namely an application to develop part of the Ardingly showground for 35 houses (which CPRE Sussex has already successfully argued down from 100), and an application dating back to the first half of 2021 to create a large battery storage facility opposite one of your author’s favourite pubs in Wineham village.  If the precautionary principle were to be applied to address unquantifiable safety risks in respect of such facilities it ought to be, but probably won’t be, turned down.

And then the big one – the 2018 District Plan Review

Lest it be thought that all has been quiet on the Mid Sussex front, and that we at CPRE Sussex have been able to put our feet up, there has been the little matter of the long delayed first exposure to the public of Mid Sussex District Council’s (MSDC) intentions to upgrade its 2018 District Plan.  MSDC ran a little trailed, all too brief, public consultation exercise on its draft proposals in the run-up to Christmas.

Five yearly plan reviews are an integral part of the planning system, but MSDC has been particularly slow out of the blocks.  As a result, whatever happens from hereon, the current plan will be deemed to be out of date after March 2023, which in planning terms risks putting developers rather than the Council in the driving seat when it comes to deciding where new development should be allowed within the District.

The draft Plan update, in its present form, would have a number of significant implications for Mid Sussex residents and businesses.  It would extend the Plan period from 2031 to 2039, and increase considerably the number of homes that would need to be built within the District over the Plan’s extended life.  It proposes allocating 28 new sites across the District for future housing development.

They include three new “20 minute communities”, each of between 1,400 and 2,300 houses, all in the countryside in the southern part of Mid Sussex.  Other significant policies are upgraded (environment) or introduced (climate change).

CPRE Sussex has made extensive representations to MSDC in respect of the draft Plan Review.  This submission was the product of an extensive review of the plan and supporting evidence base – some 3,000 pages in total – by a dedicated group of local CPRE Sussex members, to whom I am hugely grateful.

Those of you who want to understand the full scope of the issues we have raised and why we have called on the Leader of the Council to withdraw or pause the Review in its current form, can read our submission at: www.cpresussex.org.uk/news/cpre-sussex-urges-withdrawal-of-draft-mid-sussex-review-plan/.

In summary, though: Last February, Jonathan Ash-Edwards, the leader of the Council wrote to Michael Gove, the Secretary of State for Levelling up, Housing and Regeneration (a snappy Departmental title if ever there was one) to tell him that the Government’s standard method algorithm that dictates to councils how they must calculate the minimum number of houses they must build  is (we quote) “simply not an accurate reflection of local needand that, if that standard method has to be applied by MSDC it is highly probable that Mid Sussex cannot achieve a reviewed Plan with community support”.   

Those are sentiments with which CPRE Sussex is in full agreement.  The Government’s arbitrary standard method algorithm produces housing targets that exaggerate and distort reality, especially in South Eastern rural areas.  We calculate that the algorithm requires MSDC to plan for about 10,000 excess homes between 2022 and 2039.  For details see our blog at: www.cpresussex.org.uk/about-us/our-blog/

You may therefore be surprised that MSDC is proposing exactly what Mr Ash Edwards concluded involves much more housing than is locally needed in a Plan Update that he admits cannot achieve community support.  And MSDC is proposing to locate the bulk of that new housing in the countryside, including three large greenfield strategic sites that are as unsustainably located as they are unnecessary, as we explain at some length in our submission to MSDC on their Plan Update.

One important thing has changed since MSDC published its proposed Plan Update: On 6 December the Government announced that it was going to relax some of its prescriptive centrally controlled rules by which planning authorities calculate their housing needs, and give some environmentally constrained local authorities a greater measure of discretion to decide this for themselves.  The extent and details of this relaxation is yet to be finalised.  But it is a change that MSDC needs to explore whether it can take advantage of to reduce the excessive housing burden that their Plan Review imposes on our communities.

Mr Ash-Edwards should be putting his money where his mouth is: we have called on him to pause his draft Plan Review and engage with us all on options that the Mid Sussex community can rally round as a Plan: proposals that meet local needs for new housing without such terrible damage to our countryside.

We need policies that do more to improve our precious environment and ensure that Mid Sussex plays its proper part in helping the country honour its climate net zero goal and interim carbon budgets.  But they need to be policies that carry local support not, as hitherto, policies foisted on people without engagement.

Pausing the Plan Update would also provide MSDC the chance to revisit and improve its proposed environment and climate change policies.  Planning authorities have a key role to play in leading change and improvement in both areas.  The Plan Update contains the seeds of good ideas and intentions; but, if they are to bloom, those seeds need to be turned from fine words into positive action.

Climate mitigation policy is meaningless unless the Plan sets target dates for achieving quantified reductions in emissions levels – targets that track the Government’s own five yearly step-by-step commitments.  Why for example does the policy on building design and construction not require new homes to be built to a net zero standard by 2030, as many other authorities are calling for?  Without such targets and monitoring of them – neither of which does MSDC promise – the effectiveness of policy to deliver net zero, and the potential need to change course, cannot be measured; nor can there be any accountability.

Equally, on the environment policy front, MSDC continues to attach no perceptible economic or social value to the countryside that makes Mid Sussex the very special rural district that it (just about) still is.  We argue in our submission that an independent natural capital impact study should be a requirement of every significant development application: one that enables the decision makers to weigh up the economic and social value of the land that a developer wants to turn (irrevocably) from green to concrete grey.  Also needed (but missing) is an ecological map of the district showing ecological hotspots and networks, and how better planning can safeguard them and join them up.

MSDC, which claims to be a high performing Council, really does have to decide between demonstrating leadership in its use of its planning powers, or just doing the minimum that it is allowed to get away with.  The Climate Change Committee tell us that local authorities use of their planning powers could influence one third of England’s greenhouse gas emissions.  If those with the power tools won’t lead, who will?

There is still time for MSDC to make changes like this to its plan if it approaches issues like this with a genuinely open mind.  There is an opportunity here for MSDC to come up with changes to its 2018 Plan that can win community support.  But a hitherto unexhibited store of fresh thinking, and a willingness to engage and listen, are needed!

My last hurrah

This will be my last accounting to you as Mid Sussex’s lead volunteer on planning issues.  I have been doing this for 14 years now, and that’s long enough.  Any longer and I will risk stifling the opportunity for someone with fresh energy and ideas, and more years ahead of them, to step up to the plate; and that’s not healthy.  I have had the privilege of working with, and learning from, a great team of dedicated people at CPRE who promote the values and charitable purposes of the organisation throughout Sussex and beyond with great effect.  I thank them all – and to all those of you who have contacted us over the years – for making my role so interesting and, dare I say it, enjoyable.  I may sit largely on the sidelines in future (though I have offered to continue to lead our opposition to Center Parcs); but I will always be a firm supporter of CPRE Sussex’s work.

And looking back, I am pleased at the level of success with our campaigning.  It is in the nature of our work – too much of which involves goading the decision-making authorities to change their minds or to make brave decisions – that the case we make doesn’t sell well, however positive our message and whatever its environmental merits.  Much of our work is naturally collaborative with others; but in the last 18 months alone, we have successfully helped to protect local communities from inappropriate schemes affecting Ansty, Ardingly, Balcombe, Burgess Hill, Cuckfield and Slaugham, as well as seeking to shape for the better Mid Sussex’s long term strategic plans for us all.

So I thank you all for your support for our work at CPRE Sussex.  Please know that support really matters to us.  And that our work, and your support, together do make a real difference.

Michael Brown, Mid Sussex lead for CPRE Sussex, the Sussex countryside charity.

January 2023