Draft to Clymping Parish Council for consideration on 23 May 2017 Arun District Council (ADC) Local Plan comment 1. Introductory comments This consultation is very welcome as it is first time Clymping Parish Council (CPC) have been consulted on these issues that both impact Clymping and on our Neighbourhood Plan (NP) vision so seriously. Parish representatives have attended liaison briefing meetings run by ADC but these have focused on the overall issues facing Arun District. There is also a material difference between a briefing (being told what is going on) and actively engaging in real consultation with a parish. The consultation document contains completely new information which has not been shared with CPC before. For instance, CPC was not aware that Clymping had moved inland and was no longer a small rural coastal village! Delivery of the plan and its stated objective of new jobs and 20,000 new homes is dependent on new highways capacity. This is because the key issue is the attractiveness of Arun for business investment in competition with Chichester, Worthing and Brighton along the coast and the Crawley/ Gatwick hub to the north. With no change to the East West highways capacity, and no meaningful plans to improve public transport capacity, Arun will continue to be handicapped. It is doubtful that employment can improve simply by providing business development land and by improving the A29 and A284 but not the A27. The delivery of the Local Plan is dependent on delivery of the Arundel A27 bypass. This issue has arisen before at the time of the decision on the proposed Ford Ecotown. Obviously, the Local Plan is not the Ecotown per se however the strategic proposals in Section 12 include a total of 3600 dwellings west of the river Arun through Clymping Yapton and Ford, not to mention 2300 at Barnham/ Westergate/Eastergate and 400 at Fontwell. The spatial layout is a different but the transport impact is comparable given the constraints of the road and rail layout in the area. The following references are relevant: The ADC Select Committee Report on Eco Town Proposals at Ford dated 17 June 2008. without a bypass for Arundel, major development in this location would cause significant congestion on the strategic and local highway network, Department of Communities and Local Government (DCLG) Eco Towns Location Decision Statement July 2009 Ford (pages 23 and 24) highlighted key weaknesses of the location highlighted the Key Weaknesses of the Location, including: Potentially severe congestion on the surrounding road network and a heightened need for an A27 bypass at Arundel; It is almost entirely green field; Although the area is not designated there is still a potential to change the setting and character of local villages (e.g. Climping and Yapton). DCLG Sustainability Appraisal and Habitats Regulation Appraisal of the Draft Planning Policy Statement: Eco Towns. Addendum July 2009 Ford (pages 58 to 66). Included in the Key weaknesses of the location is the statement potentially
severe congestion on the surrounding road network and a heightened need for an A27 bypass at Arundel. The pressure for housing may have increased but on the ground, nothing has changed, indeed there is evidence that the highways situation has deteriorated markedly since 2009. The proposed bridge at Ford is also completely dependent on the proposed Arundel A27 bypass. Otherwise, as the transport assessment notes, there will be a doubling of traffic at the existing Ford road roundabout at the A27 during peak hours. This roundabout and Ford Road only work today because northerly traffic is pulsed by the level crossing at Ford. This was also a major concern when Ford Ecotown was considered. It is the view of CPC that it is essential to improve highway capacity and critical junctions before development is undertaken given the dire transport situation described so well in paragraph 3.18. It is interesting that Horticulture is stressed but not agriculture. Given the high quality of agricultural land on the coastal plain, agriculture should be of major strategic economic importance in the plan. The assumption that each village needs retail capacity is highly questionable given the full range of major retail outlets already in the district. A previous proposal in Clymping has not gone ahead as it was simply not viable (see the officer s report on CM/10/08, a planning application to replace a shop with a 4 bed dwelling). CPC strongly supports the text in paragraphs 1.3, 3.46, 3.47 3.48 and 3.39. CPC feels that 3.50 should not be redacted (MC47) as it is an important statement of value of the natural environment, landscape and historic environment to both residents and the visitor economy. CPC identifies with the statement in 4.18 as this is totally consistent with the vision and objectives of Clymping s adopted Neighbourhood Plan that anticipates small scale development coming forward to meet demonstrated local housing needs. 4.18 states that The District s smaller settlements and rural areas will retain their character with limited new development to meet their needs The proposed plan is however full of contradictions: CPC notes however that whilst Clymping is described as a smaller village with very limited services and facilities (3.9), it becomes a large sustainable inland village in paragraph 12.1.17. Paragraph 12.1.11 describes Clymping as one of a number of inland villages undergoing sustainable growth in order to develop their role as well connected sustainable villages serving inland Arun. The strategic housing allocation proposals in Policy H SP2c will inevitably lead to the coalescence of Yapton, Ford and Clymping (and potentially Littlehampton). Policy H SP2c is at odds with the geographic coastal location of Clymping, the spatial portrait 3.9, the vision and objectives 4.18, the conclusion of the Sustainability Assessment (4.109), the objectives in Table 4.1, and the importance of the distinctive settlement pattern in Arun (7.4.1 and 7.4.2).
CPC notes that the schedule of Major and Minor Modifications are difficult to follow as the page numbers are not consistent with the issued consultation Local Plan. Some Policy numbers are wrong and some are not referenced. CPC comments will relate to the reference numbers given which are hopefully in accordance with the identified modifications on which ADC seeks comment. 2. Major Modifications MM4 CPC notes that the proposed LEGA boundary on the key diagram extends deep in the gap between Littlehampton and Clymping. Since CPC was last consulted on this the boundary has been extended to the Ferry Lane/A259 Junction. This open land between Littlehampton and Clymping is key to Clymping s sense of place. CPC fears that this represents a first step towards complete coalescence with Littlehampton contrary to policy SD SP3. Much of this land lies within the Clymping Parish boundary although no reference is made to this throughout the proposed Local Plan. CPC is however supportive of much needed development along the west bank of the river Arun. This should run closely along the line of the river. CPC sees no justification for the proposed incursion into the gap between settlements and loss of agricultural land. The key diagram also shows the coalescence that will occur between Yapton, Ford and Clymping because of Policy H SP2c SD7, SD8, and SD10 contrary to the principles of 7.4.1 and 7.4.2 and LAN DM1. Policy H SP2c SD8 development at Ford has the potential for major impact on Clymping and its setting. The proposal for 1500 houses is the same as that proposed in the Ford Neighbourhood Plan put out under Regulation 14 pre submission draft Plan Consultation. CPC s objection is attached. MM7 Policy SD SP1a section c seeks to maintain the setting of villages in open countryside. CPC supports this. Policy H SP2c unfortunately contradicts it with respect to Clymping and this is also contrary to the adopted Clymping Neighbourhood Plan. MM8 CPC agrees with Policy C SP1 as it provides important context to the Clymping Neighbourhood Plan. MM9. CPC agrees with Policy LAN DM1, and, in particular, the final paragraphs Development throughout the plan area should respect the particular characteristics and natural features of the relevant landscape character areas and seek, wherever possible to reinforce or repair the character of those areas. It continues The historic character and development pattern of settlements should be respected taking into account their distinctive identity and setting. This is inconsistent with the proposals in H SP2c that will involve development on Grade 1 and Grade 2 farmland contrary to policy SO DM1 b and c and Policy C SP1.
MM14 Presumably refers to EMP SP3, and not EMP SP2. CPC is supportive of the principles of the LEGA development (EMP SP2) but strongly challenges the boundary change. MM15 CPC feels that to deliver the intent of Policy EMP DM1 Para 6, it is necessary to define modest to take account of the cumulative effect of a series of small developments. To deliver an effective policy Part 6a should read that it is part of a modest total cumulative extension of an existing employment site assessed over the Plan period and no acceptable. Without the and large extensions would be possible at unsuitable locations that should be restricted by Policy C SP1. With this is mind, CPC wishes to object to the inclusion of development land in the HELAA south of the A259 within the Gap between Littlehampton and Middleton contrary to Policy EMP DM1 6h and Policy SD SP3 Gaps Between Settlements. CPC supports Policy EMP DM1 10 and sections 10 c, 10e and 10f in particular. MM21. Paragraph 12 1 1 is at odds with the definition of Clymping as a small village with very limited services and facilities (3.9). It is inconsistent with the Vision in 4.18 for a small village with regards retention of character with limited new development to local needs. Strategic allocation SD10 virtually doubles the size of the existing village. It is also important to note that approximately 50% of the housing in allocation SD4 lies within Clymping Parish. The proposed LEGA boundary is a major change on which CPC has not been consulted up until now and strongly challenges this as contrary to policy SD SP3. In paragraph 12.1.17 Clymping has suddenly become a large sustainable inland village. Reference to the adopted Clymping Neighbourhood Plan shows that Clymping in in fact a small coastal village in a distinctive rural setting. MM25 This presumably refers to Policy H SP2 on page 141 not SP1. It is unclear how H SP2 b, c, d, j and m are consistent with H SP2c with regards Clymping. CPC have already objected to planning application CM/1/17/OUT as this is inconsistent with the adopted Clymping Neighbourhood Plan. This planning application would also be inconsistent with Policy H SP2 b, c, d, j. Within Policy H SP 2b it is important to note the extent to which the proposed LEGA boundary lies in Clymping. CPC is unaware of any improvements to the A259 proposed between Littlehampton and Clymping. 1000 new homes and new businesses will inevitably worsen peak traffic issues. MM30 CPC supports Policy D SP 1 Design policy. MM34 CPC feels that the definition of open spaces in paragraph 14.1.1. is too narrow given the specific meaning of open space in planning terms. CPC supports the intent but feels that paragraph 14.1.1 should also refer to free access to the countryside and coast given the importance to the visitor economy. MM36 CPC supports Policy HWB SP1 with a wider definition of open space as in MM34. It should be noted that safe crossing points of the A259 are currently lacking for cyclists and
pedestrians wishing to access the countryside and coast south of A259 in Clymping Policy (HWB SP1 a). MM47 Paragraph 15.1.3 states the A27 Arundel bypass is a strategic priority for Arun DC without indicating the impact on the proposed Local Plan should it not be delivered (T SP1 g). It is key to improving the transport network across the District (8.1.4) and therefore the attractiveness of Arun as a location for new business investment. Policy T SP 1 Transport and Development item g only works if it connects to a new A27 Arundel bypass, otherwise it will cause severe disruption at the Ford Road/ A27 junction at Arundel and at the Church Lane A259 junction in Clymping. It would be one of the shortest links between the A259 and A27. MM53 CPC supports policy ENV SP1. It is important to the rural setting and character of Clymping. MM63. With regards to policy INF SP 1 CPC notes the complexity of the costings in the infrastructure Delivery Plan. It was not possible to assess whether the sums add up or not i.e. if the required infrastructure can be delivered. CPC has adopted an assessment of Arun Transport Study (paragraph 22.0.17) that is attached to this consultation response. This review concludes that the study wholly underestimates the impact of the proposed strategic developments and whilst it may address the deficiencies of some junctions it adds no new highways capacity to cope with journeys associated with 20,000 new homes, let alone the needs for business investment. 3. Minor Modifications MC1 Paragraph 2.1 refers to the important role of Neighbourhood Plans but CPC noted that Counsel for ADC sought to invalidate existing NPs during the inquiry into planning application Y/19/16/OUT. CPC feels strongly that Neighbourhood Plans should be respected given the importance assigned to them in paragraph 12.1.17. MC2 Paragraph 2.2 This states Crucially the Local Plan will also protect those aspects of the District.. or are otherwise valued by local people It is not clear to what extent ADC are listening to local people. MC4 Paragraph 2.4 CPC feels the redacted sentence should be retained given the stated importance of Neighbourhood Plans. MC5 Paragraph 2.5 refers to the need to review Neighbourhood Plans on adoption of the Arun DC Local Plan. Neighbourhood Plan already have a requirement for review. There is a need to confirm the legal basis of adopted plans once they are subject to review. MC15 CPC welcomes this consultation of the proposed Local Plan but notes that much is completely new to us leading us to question how effectively ADC has engaged local communities (2.17)
MC21 Paragraph 3.3 refers to the importance of the Littlehampton and Middleton on Sea Gap, so why is the HELAA indicating development halfway across it North to south in Clymping? The phrase North of the coast is redundant as there is no open countryside south of the coast. MC26 This refers to paragraph 3 09 and the smaller villages and hamlets having very limited services and facilities. Clymping has the services and facilities it needs today either within the village or accessible within neighbouring communities. Within the parish, the village has a popular primary school, church, church hall, village hall and playing fields, farm shop, two public houses, a hotel and B&B residences, holiday cabins, beach, beach car park and beach café. The statement Most of the coastal plain is high quality agricultural land and intensively farmed, with areas of large scale horticulture should be retained. It is a defining characteristic of Arun outside the built up boundary. MC27 CPC feels that this statement should be retained. The open countryside and setting of Clymping is important to the village s sense of place and emphasised in the adopted Clymping Neighbourhood Plan. MC32 CPC feels that the statement in paragraph 3.18 that The A27 at Arundel is often congested and requires a solution to improve journey reliability and vehicle emission reduction is true. Delivery of the plan is dependent of this solution. MC 38 The statement in paragraph 3.33 that Arun is likely to experience some of the most severe impacts in the United Kingdom due to climate change is both important and disturbing given the uncertainties of these impacts. Building on, or close to, areas prone to flooding should be of high concern and subject to vigorous control. MC 43 Paragraph 3.39 refers to lower earnings in Arun district. MC122 also references links to this given the historically low ratio of earnings to house prices (12.3.2). This data should be updated as the central issue in the plan is not simply growing employment numbers per se, it is the provision of enough new, high quality employment, capable of providing earnings to allow people to afford to live in Arun District. Without addressing this, local housing needs will not be satisfied. Migration into the area from more affluent areas and commuting out to other employment areas will simply continue. The Plan only makes passing reference to this discrepancy of earnings. MC213. This refers to paragraph 15.1.3 and simply underlines the critical import of the A27 Arundel bypass to the delivery of the Vision and Objectives of this Local Plan.