See below for the text of KSG’s official objection to the revised planning application submitted by Berkeley Homes, reducing the total number of units to 594. This was addressed to Dr Chris Lyons, Director of Planning, Economic Development and Property, Horsham District Council, and dated 24th November 2014.
Planning Application: DC/14/0590 – Land West of Worthing Road, Southwater, West Sussex
Residential development of up to 540 dwellings and 54 retirement living apartments, associated vehicular, cycle and pedestrian access, drainage and landscape works and provision of land for sports/recreation facilities (Outline) (Development affects the setting of a Listed Building)
OBJECTION submitted for and on behalf of KEEP SOUTHWATER GREEN
This is a ‘dormitory’ development with no work creation in situ and no public transport planned within the development. There is no railway within the village and no easy access to either Christ’s Hospital Station or Horsham Station. We already know from the 2011 Census that 71% of Southwater residents who are employed leave the village by car or van – this development will increase traffic load on the Worthing Road by at least a further 1000 cars.
It does NOT reflect the will of the people and can in no way be considered a ‘collective enterprise’. It certainly cannot be said to conserve and enhance the natural environment – indeed it threatens the countryside which forms a natural barrier on the west side of the village as well as providing a highly valued and much used amenity for residents.
It is an unsustainable development which is not well designed to make the best of the strategic site identified by Horsham District Council and is not in accord with the emerging Horsham District Planning Framework.
Specific Areas of Concern
Traffic and Highways Issues (see also Representation letter ‘Kindersley’ dated 14/4/2014)
- The numbers of houses and their layout in a long stream with a single main artery road is grossly excessive. Consequent traffic flows will lead to very inconvenient and possibly dangerous congestion both within the development itself and on the access to the Worthing Road; itself an unclassified supply road for the whole village which is already severely congested at busy times. It has pinch points, speed bumps, multiple entries from housing areas to the east of the village, a large caravan park (both residential and retail) as well as two primary schools.
- The apparently favoured concept of taking all the cars through the entire ribbon of development before exiting into the Worthing Road is totally unsustainable given the numbers that are being considered.
- All other approach roads are tiny. Church Lane, running east towards the Worthing Road, is not amenable to any significant improvement and is already severely congested with roadside parking.
- A ‘rat run’ will inevitably be created going west past the Church and down Bonfire Hill. These roads are totally unsuitable for increased traffic flow. The bridge by the Bax Castle has a weight restriction which will be ignored by vans etc to everyone’s peril. The problems of the dangerous Boars Head junction will be compounded.
- A significant junction at the top of Bonfire Hill servicing both the Church Car Park and also the proposed new Sports Facilities will be blind to traffic coming up the hill towards the village and will be dangerous.
- The small slip lane and run into the dual carriageway at Hop Oast – seemingly all that is now proposed – is totally insufficient. At peak times in the morning now traffic backs up far down the Worthing Road into the village as it waits to gain entry onto the A24 or go on to Horsham. This can only get worse and create the situation where motorists will either use Southwater Street and Kerves Lane as a ‘rat run’, or actually turn south back through the village hub to reach the southern end of the dual carriageway bypass. Recent road problems around Hop Oast – be they roadworks or flooding or an accident – have demonstrated how vulnerable the whole system is now, before the West of Horsham developments have significantly contributed to traffic flow as they are bound to do.
- There is no consideration or demonstration of how remedial measures might be incorporated to separate construction traffic from existing traffic during what would be a long build out. The effect on the quality of life of everyone living nearby will be catastrophic and prolonged.
- The entire approach to the parking provision round community facilities such as the Sports Fields, are totally inadequate. When a number of home and visiting teams are playing, or some event is taking place at the Church or on one of the other proposed Facilities, parking will inevitable spill out onto the roads which will already be at or above any sensible limit of congestion. This will also impact on the safety of the difficult junction at the top of Bonfire Hill – see above.
The recently announced “Planning Practice Guidance” stresses that insufficient local road capacity to serve a development is a justified reason to stop such development. We consider that insufficient local road capacity has been demonstrated above.
We appreciate the country’s need for houses, but for the above reasons this number is far too high to be sustainable given the existing road infrastructure. An answer can only sensibly be found if the number of houses is substantially reduced.
Great House Farm and the issue of Anthrax
- The proposal to build on about six acres of the field in front of Great House Farmhouse is seriously flawed. It is especially in this field that the risk of Anthrax has to be considered.
- However you try and quantify that risk, the risk can never be zero as Professor Silman of Public health England has agreed (November 2014). We dispute the right of either Berkeleys or the District Council to impose that risk on the village.
- Further surveys and, as suggested, the constant presence of Health Protection Agency staff, do not remove the risk. This risk will continue long after properties have been sold; for example someone digging foundations 20 years hence for an extension could expose an infected carcase undiscovered initially.
- Whose responsibility will this be legally? Will it be Horsham District Council’s responsibility as has been suggested since they were the statutory authority that allowed building to proceed when the risk was known to exist. There is some case law that supports this view.
- We consider – AND PROFESSOR SILMAN IS AWARE OF THE FOUNDATION FOR THIS CONCERN – it mandatory that all potential purchasers are explicitly made aware of the risk and the only way this can be ensured is to make it a condition that it is mentioned specifically in the deeds of all houses that are sold in that field.
- The risk can be totally avoided by leaving this field alone. It is surely only common sense to do this. This will of course reduce the number of houses by about 30 – but they must be reduced by many more than that to provide a sustainable development.
- It would have the further advantage of obviating the need to construct a new road down to a big roundabout opposite Cedar Drive. Such a road will be heavily used by cars, especially if it is, as proposed, the main access road into the development. It will also be the only road into the farm. There will be the inevitable, and highly undesirable, prospect of cars mingling on a regular basis with farm traffic, lorries and animals.
- There are also a number of proposed houses that are far too near the main cattle barns which are regularly full of cows in the winter months. This is bound to create problems of noise and smell as well as the risk of vermin.
- Abandon this section of the development and farm retains its own simple exit drive and the main vehicle access is further south into the Worthing Road – still away from the Schools.
- Great House Farm cannot afford to lose any acreage and remain viable. This was established by the report on the farm as a business enterprise commissioned by Horsham District Council in 2012 ( the Kernon report) – the only report which has ever been prepared with specific reference to this farm – as opposed to the theoretical projections put forward by the developers.
- One of the major constraints concerning any development in the area has always been the preservation of the farm:
1. Because it is needed by the Country given the overall imperative to increase food production by 70% by 2050 (Government Figure).
2. Because it is hugely valued as an amenity by the village.
3. Because English Heritage have acknowledged its importance in safeguarding their 2* asset and crucially its setting. Please note recent legal guidance that “considerable weight and importance”, NOT simply “careful consideration” should be given to preserving the setting of important listed buildings such as Great House Farmhouse, when the benefit/harm analysis of the application is made.
- In relation to this please consider: The Developers “Agricultural Land Classification” document submitted 31.3.2014. This claims that all the farmland under consideration for development is classified as 3b and therefore suitable for development without serious concern as to its loss to agriculture. This is highly misleading:
1. Because according to DEFRA this land has never been formally classified at all and therefore its classification is an assumption and NOT a fact.
2. Because the classification is primarily formulated to establish a hierarchy of land suitable for the growth of field crops. It does not cover land that is primarily, and in this case totally, used for the grazing of farm animals. For this purpose this is highly suitable and valuable land as has been amply demonstrated by generations of the Charman Family.
The Provision of Fresh Water and Sewerage
- Note should be taken of the submission of Southern Water to the EIP of HDPF in which they highlight that at present both the arrangements to supply both fresh water and sewerage to the new development is “Inadequate”.
- In the case of fresh water provision Southern Water itself has publically said “the area in which we live (referring to Southwater) is already under serious water stress” (Letter to Customers in Southwater dated January 2014). We all have experience in recent summers of how supply has become critical. Further development can only increase the severity of this problem.
- It must be clearly understood that in the case of the sewerage provision for the whole village NOW – before any additional development – a very serious failure of the system as a whole has been demonstrated. Southern Water have acknowledged that a major review of the system which will need significant uprating is needed. Not only is it “needed” but it is absolutely imperative and very urgent. At present – and for many years – major inconvenience, serious pollution and a potentially serious health risk is being inflicted upon a number of residents. Reference can and should be made to Francis Maude MP who has been directly involved AND WHO STILL IS.
- Recent Planning Guidance makes it quite clear that under these circumstance, and until the problem has been fully resolved, no permission should be given for further development to be added to the system. This statement has been confirmed to us privately by a senior planning barrister as being correct.
- To ensure the present serious problem is indeed put right BEFORE any further development load is placed on the system there MUST be a requirement that this outline planning application must include a full and detailed application with regard to sewerage provision. Nothing less will be sufficient.
Emergency Health Care Provision (see Appendix)
- South East Coast Ambulance Service have to provide emergency care for what are called Category A emergencies in the area they serve which includes Southwater at its southern extremity. Government targets demand that they reach 75% of these cases within 8 minutes. In most of their district they achieve this but in Southwater for many years they have often been 50% or sometimes much less.
- The problem is logistical; the ambulances have further to go and the roads are congested and becoming more so. Recent figures indicate no improvement. (See Appendix B of KSG’s submission to the EIP of HDPF in October 2014)
- We question whether the Planning Authority should be allowed to ignore this dangerous lack of provision which WILL endanger and cost lives. It must be considered part of the infrastructure and a condition should be made that it has to be improved BEFORE any new building takes place.
Other areas of concern
- The area to the west of the new cricket field is marked for hard surface sports – tennis courts and a skate park plus a new building. For this to be of real value it would need to be floodlit and the situation of it here compromises what should be the ‘soft’ green boundary of the development. These facilities would be more appropriate nearer to the housing and nearer the centre of the village.
- The green barrier abutting Shaws Lane has been significantly encroached to fit in more houses. This should be returned to the original concept outline, or indeed increased in size. This will also ease congestion numbers overall.
- There remains significant problem with surface water and flooding to the rear of houses in Woodfield and to some houses on the west side of Worthing Road. See Environment Agency new data on surface water flooding.
- There remains concern about contamination along the line of old railway cutting which was filled in an uncontrolled fashion and has still not been properly investigated.
- An old coal mine – active from 1810 to 1850 – was present in what was called College Wood. We do not know the extent of this mine but suggest the ground in this area should be subject to a clause demanding assessment to cover the risk of future subsidence.
We consider this development, as proposed, is still unsustainable and indeed unsafe for all the above reasons.
We demand that it is refused.
DR IAN THWAITES FOR KEEP SOUTHWATER GREEN