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Our Reponse to the Community Infrastructure Levy Consultation
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Response to Haywards Heath Neighbourhood Plan, July 2015

THE HAYWARDS HEATH SOCIETY
RESPONSE TO NEIGHBOURHOOD PLAN CONSULTATION, JULY 2015

The Haywards Heath Society strongly supports the Haywards Heath Town Council in putting in place a Neighbourhood Plan rather than leaving the allocation of its housing to Mid Sussex District Council. 

The Society's vision is that the Neighbourhood Plan should provide an innovative, forward thinking framework to enable the town to develop in a sustainable way, whilst respecting and protecting its natural and cultural heritage and sense of place; maximising the benefits of development for all the community.  However, development also has adverse effects on localities.  The Society therefore believes that the Town Council should, through the Neighbourhood Plan, encourage the District Council, as Planning Authority, to use current planning enforcement laws to mitigate these effects.

It is clear that demand for extra housing in Mid Sussex means that further major development in Haywards Heath is inevitable.  All parts of Mid Sussex must, however, take their fair share

The Housing Consultation states that MSDC has allocated an extra 2204 dwellings in Haywards Heath over the 17 years of the Plan.  Is there some double counting here?  The draft MSDC District Plan (page 31) gives a figure of 1515 for the District as a whole once the completions in 2014/5, existing housing commitments and the strategic development at the northern arc of Burgess Hill are deducted. The Housing Consultation itemises potential sites for housing development within the town's boundary.  Including all these sites, plus those developments which have recently received planning permission and the contribution from very small sites, the consultation document estimates a total new housing potential for the town of 1413 over the plan period.

Rather than opposing the inevitable building of new housing, we think the Society should use its influence constructively to soften any adverse impact and indeed treat this as an opportunity to build a town to be proud of.   However, we would not support those developments which do not maintain the strategic gaps between our towns and villages.  A Strategic Objective in the draft District Plan states (page 8):
"2. To promote well located and designed development that reflects the District’s distinctive towns and villages, retains their separate identity and character and prevents coalescence.”
Nor would we support developments which mean the loss of important community space.  In the latter case, we would include the College playing field which we think would be better used as a sporting/recreation facility and/or, given the growth of the town, for the extension of Harlands School. 
We feel very strongly that the town and district boundaries we have are not fit for purpose.  Neighbouring Councils frequently propose developments on the edge of Haywards Heath, well away from their own centres.  It is patently wrong that Haywards Heath should be forced to shoulder the essential infrastructure costs that will be needed as a result of these proposals with no corresponding income from developers.  We should campaign strongly for boundaries to be sensibly re-drawn and money to go where impact is felt.  Responsibility for designating boundaries and enforcing strategic gaps should rest with the District Council.
As regards Haywards Heath specifically:

  • The District Council should ensure, with appropriate restrictions and penalties, that new developments are sustainable, with high standards of energy utilisation, water and waste efficiency, and adequate green spaces for play and relaxation.   Provision for cycle paths and footpaths would reduce car journeys and hence traffic congestion and pollution.  They should be integral to all new developments unless they are very small.  Where possible, any existing footpaths and areas of woodland should be incorporated into new developments.  Ideally, footpaths and cycle paths should be kept separate so that people can walk safely.
  • The Council should work actively with good developers with a proven track record of good community projects and sensitive working practices.
  • Developments should contain a mix of housing to cater for different household’s requirements.  Demographic and historic data would enable an estimate of the types of housing most likely to be needed.
  • With more pressure on land, house prices are unlikely to fall significantly.  Adequate numbers of Affordable Homes and Social Housing, which prioritise those who live or work locally must be part of any development.
  • Development must be accompanied by appropriate infrastructure - schools and health facilities are priorities.  
  • Local employment opportunities should be fostered - for example, could empty office or shop space be better or differently utilised to attract new, possibly small, businesses?
  • As the town grows, green spaces for relaxation, exercise, play and reducing pollution become not just pleasant but vital.  Existing green spaces should be cherished and greening of the town made a priority.  The planting of trees in the town centre would be visually attractive and help reduce pollution.   The choice of plants in public areas should be wildlife friendly.  Wildlife corridors in and around the town should be preserved and be an essential part of any new development.. 
  • Apart from greening, we should look actively at the town centre to make it as pleasant as possible.  The hanging baskets and Peace Garden are excellent ideas; one of our members has suggested the use of colour in resurfacing the pavements to give a sense of unity.  A pleasant town centre is also more likely to be economically successful!
  • The town's need for suitable leisure facilities and community centre(s) will grow.  Existing facilities such as the Dolphin Leisure Centre and Clair Hall should be retained unless replaced by comparable facilities that are centrally located with good access to public transport and parking. Siting these out of the centre of the town is not an option.
  • It is essential that the town should protect its historic buildings and their setting.  Apart from those listed, the idea of protecting and enhancing areas designated as of townscape interest is excellent and one to which residents might actively contribute. We would suggest that any new development takes this into account when designing the style of the new buildings, and ensure they are in keeping with the character of the area adjacent.
  • Towns evolve - in general, it would be better to work with existing areas rather than undertake massive redevelopment.

 

Haywards Heath Society Executive Committee
July 2015

 
 
HAYWARDS HEATH TOWN CENTRE TRANSPORT STUDY

To see the original document we commented on, please click here

26/10/2015
CONSULTATION RESPONSE  FROM HAYWARDS HEATH SOCIETY
From:  Janet Rider, Secretary
Shared footways/ cycleways  (in proposals A,B,D,G,H, M, O,P)
We support the encouragement of safe cycling, and proposed extra cycle parking spaces.  However, we have grave concerns about the shared footways/ cycleways in a number of the proposals.  If cyclists share the same space as pedestrians they create a hazard.  Pedestrians include, for instance, children and dogwalkers, where child or dog might suddenly change direction; disabled people, who cannot move out of the way swiftly; the hard of hearing, who may not hear a bicycle bell behind them, and people with pushchairs or suitcases.  Also, pedestrians should not be forced by narrow paths always to walk in single file, or wait to pass each other.
For safety reasons cycleways should always be marked off from walkways by at least a white line, and the walkways should always be wide enough for two adults to pass each other without encroaching on the cycleway.  Existing paths for many of the proposed shared footways/ cycleways appear too narrow for this, and unless widened would be unsuitable.
Muster Green Gyratory (prop. J)
The proposal has been well thought out and has many potential benefits.  In addition our brief and rough analysis indicates that the proposed layout would reduce traffic along the sides of the gyratory by around a sixth on average, and would alleviate the commonest queues of traffic currently entering the gyratory, ie from the west, from the north along the Broadway, and from the east down Church Road.   We were surprised that the modelling work seemed to indicate longer and slower journeys for much of the traffic, and would welcome a closer look at this.
South Road (prop. K,L)
We would like to see the current hedge between Victoria Park and South Road retained.  It provides a habitat for wildlife and acts to reduce noise and air pollution in the park. We support the 20 mph limits proposed here and for adjoining roads.  We are in favour of discouraging through traffic along South Road, but think this may be better achieved by narrowing the road selectively rather than using raised sections which can be noisy.  The wider footpaths could help with pedestrian and cycle traffic, and offer opportunities for planting trees.

Entrance to the town (prop.R,S,T)
We support proposals for a visual gateway to the town and for road narrowing where the east-west road through the town meets the A272, as encouragements for through traffic to use the new relief road.
Lighting the Clair Park walkways  (prop. P)
There are health and safety and crime deterrence benefits in lighting the relevant paths within and around Clair Park.  However, light pollution may impact on bats and other wildlife.  The lighting levels and the hours they are used should be set at the minimum needed to achieve the benefits.
Improved business park and bus stop signage  (prop. V, W)
We are in favour in principle.  Potential downsides might be street sign clutter (the Town has recently pursued a de-cluttering programme), and failure or vandalism of electronic bus signs.  We suggest prioritising the individual sites and phasing their introduction accordingly.
Setting Priorities
We have real concerns about many of the shared footway/ cycleway proposals.  Also many of these are interdependent, so piecemeal adoption delivers only limited benefit.  We are in favour of the Muster Green gyratory as the lynchpin of the proposals, but believe that closer investigation of the traffic/ business case implications are an essential next step before committing to it.
By contrast, a number of the proposals are stand-alone, would deliver immediate benefit, appear uncontentious, and are relatively low cost - important if we are to see early concrete results from the study in these tough financial times.  We therefore give first priority to R, S and T, the gateway measures which would strengthen the town's visual identity and discourage through traffic.  Priority should also be given to proposal U, the proposed 20pmh speed limits through the centre of town.  

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Haywards Heath Society's Response to the Draft Haywards Heath Neigbourhood Plan
General

The Society is of the view all sections of the plan are inter related and inter dependent, and as such, should be viewed, not in isolation, but together, with all sections of the plan dovetailing together to form a robust vision for the towns future.  All sections of the plan are essentially vital in securing the development of a sustained future of the town, with the aim of achieving enhanced and secure living and working conditions for all in the community.


It is considered the plan should include an introduction to Haywards Heath which would indicate a stronger sense of its character and history, than the draft “About Haywards Heath” section appears to suggest, which could better then lead into and inform the main plan.  The Society believes an ideal introduction would focus on the towns economic and social history, from its basis in agricultural activities, its development as a market town, later railway driven expansion of the town, and its links with medical services, all of which the town was noted for.  The towns considerable Victorian heritage, of which several examples of houses, gardens,  and green spaces, remain and are cherished by the towns inhabitants, could, in our view, be better exploited in a revised introduction, providing greater emphasis on the towns rural setting, parks and green areas, which continue to give the town a unique green and pleasant aspect.  Overall, there should be created in the introduction a distinct sense of the town’s value and identity, which are the very aspects which make the town special for its residents, workers and visitors.  It is believed by accentuating, within the vision statement references to the towns green aspect and market based history, might well better connect with the council’s intention to promote a family focused town with a vibrant economic base.  Being situated in the very centre of Sussex, it should be demonstrated Haywards Heath is more than a commuter town, and much valued still for its links with the past, whilst being able to positively plan for future economic and social development.


The Society remains concerned all sections of the draft plan suffer from a lack of a demonstrable evidence base upon which the predictions contained within it are based, and which can be used to support the plans proposals.  In particular the Society believes the evidence to support housing numbers and type assertions and highways and transport assessments made by the Council or their agents, are lacking in supportive evidence.  The Council will be aware other published Neighbourhood Plans, have been rejected, at least in part for this shortcoming, at inspection.  The Society urges the Council to take steps to strengthen the evidence base for its proposals in order to establish a realistic chance of success at inspection and referendum stages of the process.  It is of course appreciated research aimed at strengthening the plans evidence base, may prove difficult.  However, all parties who are interested in the town’s future should be prepared to assist the Council in this task.  For its part, the Society is always available to contribute to this process should the Council believe it appropriate. 
It is noted in several instances in the plan, the Council, in its choice of words, appears to assume powers it does not actually posses in law.  The Society fully acknowledges the Council’s intentions, but expressions such as “developers shall not – will not be permitted – will only be permitted” will not only be beyond the Council’s power to enforce, but will risk challenge from the district Council and others at later stages.  The Society suggests the moderation of such expressions to reflect the fact that the Council having limited power in these situations, will exert pressure on the planning authority urging them to undertake such controls.  It is believed such revision will reflect more fully the realities of the legal situation.


In any overview to the plan, the Society would like to see more emphasis placed on stressing that green spaces and sustainable development can complement one another, for example in the provision of flood controls, public amenities, educational opportunities and a healthy and happier community, rather than be seen as competing elements of the plan.


Listed here under are summaries of the draft plan.  The comments follow the published order of  the plan and at their conclusion are attached more detailed submissions from the Society on those sections.


ENVIRONMENT, SUSTAINABILITY AND DESIGN QUALITY

  • The Council’s incorporation of wide ranging environmental policies in the plan are acknowledged and endorsed by the Society although some doubts remain regarding the lack of evidence to support some of the plans ambitions.
  • Haywards Heath and it’s neighbouring authorities should consider promoting local foods as an aid to local business and the local economy.
  • The setting up of a Community Interest Company, focused on the towns green infrastructure, working with local environmental organisations, and perhaps pooling resources and accessing grants, might be worth the Council’s consideration.
  • Exercise trails are supported provided protection was ensured for nature reserves, green spaces and areas of arable farmland.  The Society supports efforts to promote a country park and nature walking trails.
  • The Council is commended for its recognition of the importance of a green corridor.  The Society feel the plan should support this aspect with a broader and more detailed evidence base.  The Society would suggest the Council considers undertaking an audit of the towns green areas, categorizing them according to their importance in biodiversity terms, and to ensure their linkage to other areas.
  • The Society feels strongly areas prone to flooding should not be built on, and that the natural environment should be regarded as a first defence.
  • The Council is urged to join with other Council’s in petitioning the government to take a strong lead in ensuring all buildings are as energy efficient as possible.

BUSINESS AND RETAIL

  • In general, the Society supported and commended the proposals made by the Council, within this section of the plan.
  • It was felt Perrymount Road was a crucial approach to the town centre and should be maintained as such.  The station plans were welcomed especially now they will incorporate pedestrian access with direct entrance onto Perrymount Road, and car park access direct to station platforms.
  • The Council might well consider some retail use of ground floor office blocks in the Perrymount Road area of the town.
  • Gap analysis to determine what type of shops residents would like/where gaps are .
  • Advertising and financial incentives to attract business users (office/shop) – Haywards Heath is a good location, cheaper than London, commuting going opposite way, excellent transport links, well qualified local workforce.
  • Signage – particularly to less obvious areas, when coming from station such as Sussex Road .
  • Possible pavement design which leads pedestrians through the town.
  • Greening where possible, e.g. planters in Sussex Road.
  • Pedestrianisation of part of the town is impractical and unpopular at present except on an occasional basis.  More research required, especially of the wider effects on local areas, transport and the economy.
  • Possibly identity given to town to make it small local hub – e.g. local food or market  on  rotational basis with e.g. Cuckfield’s local market.

HOUSING

  • The Society is of the opinion the number of houses proposed in the Neighbourhood Plan was probably unrealistic given a general growth in population and a need for more affordable homes.
  • The Society feels there are not enough brownfield sites in Haywards Heath even for the number proposed without sacrificing green spaces within the town which are valued and very arguably essential for the wellbeing of urban residents.
  • Boundaries between neighbouring towns/villages were already being reduced and the only real option is development to the north, which is unpopular and has problems of drainage as well as impact on the Area of Outstanding Natural Beauty and the green setting of the town which make it so attractive.
  • The Town Council should press MSDC to look more widely at the whole Mid-Sussex area and not simply concentrate development in the towns.
  • The villages should take more houses – these could be built to fit in with the local architecture (as, for example, village houses proposed recently in the press by Prince Charles).
  • Any development should have the least possible impact on the environment and there should be rigorous standards of architecture and sustainability.
  • Green spaces should connect and development should take place in the context of this connectivity.

HIGHWAYS & TRANSPORTATION

  • The Society welcomed the work done on assessing the future traffic needs of the town and how they might be mitigated.
  • Despite the assumption of more cycling and walking in the supporting document, the committee thought that the predicted growth of 11% in traffic in the a.m. peak by 2031 was probably too low given a growing population.  If the figure was too low, the estimated mitigation costs would also be too low.
  • It would be useful to have several case studies for potential traffic growth with different scenarios (supporting document).
  • Car parking was a major issue in the town, especially at the hospital and by the station, and this affected residential roads nearby.  Parking needed to be affordable and also accessible for traders in the town.
  • The Society is concerned too much emphasis was being put on the relief road.  The relief road would not affect north/south traffic and new developments would also bring more traffic. Much of the traffic would also be heading into the town, particularly at peak times.
  • Some already busy roundabouts were likely to become more so, particularly at Commercial Square, with increased station parking, Waitrose, and possible local development.
  • The Society did not think pedestrianisation of the Broadway, except on an occasional basis, was a good idea because of the impact on traffic circulation and on some of the traders. South Road, as a town centre, would have a better case but here too traffic flow and impact on residential roads were likely to be problems.
  • Pedestrianisation may not be advantageous to local traders, and may increase crime and vandalism.   More detailed research and evidence is required.
  • The Society would welcome an improved gyratory system at Muster Green but again more detailed research and evidence is required.
  • The Society thought that insufficient emphasis had been put on Haywards Heath’s role as a transport hub, between London and Brighton and in the middle of Mid-Sussex.  The Society believes dedicated space for drivers to relax and somewhere to buy drinks, would be appropriate.

LEISURE RECREATION AND CUMMUNITY BUILDINGS

  • The Heath should be specifically included in the list of green spaces which need to be protected.
  • Clair Hall and the Dolphin Leisure Centre were ideally situated at present and should not be moved elsewhere.
  • Cinema/theatre facilities might be more successful if they could be purpose-built with comfortable seating; adapted Clair Hall would be the right location – the Hub and the former  Platform Theatre are too small and less well situated (and the Platform did not succeed before).
  • A Town Museum would be welcome, possibly in Clair Hall if this could be adapted as a general arts centre for the town.
  • Beech Hurst should be kept as a quieter garden area, differentiated from Victoria Park, using it as an open air venue did not seem appropriate.
  • The country park would be welcome and the burial ground is essential; they should not be compromised by housing developments.
  • Extension of the Bluebell Railway into the town would be welcome.
  • The nature reserves should be specifically named in the document and protected.
  • An exercise trail would be appropriate in the country park; nature reserves were inherently unsuitable for cycling or running on a large scale.
  • It would be useful to compile a list of halls/ meeting places in the town with their hire rates; this could be kept at the Town Hall.  Possibly the Society could help with this?

 

March 2014

 
 
 
Penland Farm Planning Application
HAYWARDS HEATH SOCIETY
PLANNING APPLICATION 13/03472/OUT
PENLAND FARM


STATEMENT
The society has never been opposed to development within the town’s boundary where it has been demonstrated the proposals are of benefit to the local community and are appropriate.  Appropriate in terms of location, scale, design, impact on the local area, local infrastructure, and services, and in the preservation and enhancement of local wildlife habitats and areas of countryside.


In the case of this proposed development, the society is unable to recommend any aspect of the scheme as “appropriate”.  Overall, the society believes this scheme would produce an unacceptable intrusion into countryside within and surrounding the town, and would create a damaging effect on the town’s services and amenities.  In addition, the development would likely destroy acres of arable farmland and pose a significant threat to the areas ancient woodland and wildlife habitats.


Previously, Mid Sussex District Council has rejected the majority of this site as being suitable for housing, citing reasons of poor drainage, effect on local woodland, lack of access to the town and local services, increase in vehicle traffic and safety considerations, etc.  The society is unable to identify where there has been change that would justify supporting such development.


Whilst it may be possible to argue that some development in the north east of the site is supportable, the bulk of the proposed development site is clearly unsuitable for large scale housing.  Not only is the farm good quality agricultural land with areas of woodland which should be preserved and managed as a feature of this part of Sussex, the farm itself and adjacent land have a long history of poor drainage and flooding after severe weather.  Areas of the town close to this site already experience drainage issues owing to the number of streams which meander across the region.  To build such numbers of houses in a location noted for poor drainage facilities can only lead to added discomfort to local residents, and a strain on local authority services.


In the society’s view, the need for this volume of housing on this site has not been established.  Developments in progress and committed elsewhere across mid Sussex would appear to meet the likely demand especially if all villages and towns are encouraged to share the burden of housing provision.
The proposals are likely to generate an increase in vehicle traffic in and around the Balcombe Road area and will add to the general congestion that already exists on the approach to the town from Mill Green Road.  In addition to increase in noise, pollution, and road safety issues in the Balcombe Road area, these proposals by aggravating the congestion around Mill Green Road will further encourage through traffic using adjacent roads such as Burrell Road and Penland Road.
Clearly local education and health services are already stretched to keep pace with increased housing and population numbers.  This proposal can only make the situation worse and unbearable for locals.


Haywards Heath Town Council has encouraged the use of brownfield sites for development.  The society welcomes this although such sites are scarce in the town.  However across the district such sites do exist and the district council should be urged to follow this path.  To do so would negate the need to eat into the countryside as this scheme does.


In summary, the society believes this scheme has little to offer the community but has the capacity to seriously impact in an adverse fashion on the local environment and services.

The society is supportive of the opposition to this scheme offered by the Penland Farm Action Group and others and would endorse the views they have made.
 
Neighbourhood plan 2012

 

SUBMISSION BY THE HAYWARDS HEATH SOCIETY RELATING TO

THE MID SUSSEX DISTRICT COUNCIL’S COMMUNITY INFRASTRUCTURE LEVY – DRAFT CHARGING SCHEDULE.

The Society has carefully considered the draft proposals for the Community Infrastructure Levy currently submitted for public consultation and wishes to record its serious concerns on a number of issues, wholly related to the proposed treatment of residential development, namely:-

 

1.         Mid Sussex District Council is one of a relatively small number of Local Authorities which proposes to adopt different level of levy depending on whether the development concerned lies within the urban area of the three principal towns, within the defined built-up area of the villages or in a rural location in the countryside.

We do not see any evidence in the supporting documentation – the Paper on the Community Infrastructure Levy and Affordable Housing Viability Assessment – Technical Report dated December 2011 and the Community Infrastructure Levy – Review of Viability Assessment and Advice on Draft Charging Schedule – Technical Report Update May 2013 - for the adoption of this strategy.

It is recognised that due to its appeal as a place in which to live and work Mid Sussex District, in common with other Districts in the South East, has attracted a level of housing growth greater than other less favoured locations in the United Kingdom. This in turn has placed demands on its infrastructure resulting in a deficit in some locations and a backlog of works to meet even recently consented developments. The proposed Mid Sussex District CIL rates ranging from 150 to 210 to 235 pounds per metre on market housing appears to be considerably more than those being proposed by other authorities.  The markedly higher levels of levy proposed by Mid Sussex poses the question of whether they are sustainable and whether their adoption will seriously affect housing delivery in the District.

2.         The Society has flagged up its concerns in the past at the level of reliance in the District Plan on the delivery of a total of 4,000 new homes in Burgess Hill in the Plan period, principally in the Northern Arc. Enquiries by the Society as to the precise gross and net developable areas of land within the proposed Northern Arc produce different figures and for the purposes of this response to the consultation draft the Society has adopted the areas confirmed by the Northern Arc consortium in its presentation in 2011, namely 110.8 hectares gross, 85.7 hectares net developable, to provide approximately 3300 homes over the Plan period.

Given that the purpose of the CIL is to make a substantial contribution to the off-site costs of new and improved infrastructure required to support housing provision together with improved commercial and leisure facilities it is essential that the Levy arising from the private housing element should realistically be expected to achieve that objective. 

To provide 3300 new homes, 3385 if the District’s own figure is adopted, on a net developable area of 85.7 hectares suggests a density of about 38.5 dwellings per hectare or more, towards the upper level of a sustainable density compared with more usual densities of between 30 and 40 dwellings per hectare.

In the experience of members of the Society involved in the construction process locally a realistic sales value for conventional new homes in Burgess Hill would be unlikely to exceed 280 pounds psf or about 3,000 pounds psm at present, and flats considerably less.

Since the 30% of Affordable housing will not be subject to the C!L it follows that the 70% private housing element alone in any given development will be required to provide the necessary monies. It is understood that at present Section 106 monies produce approximately 9,000 pounds per private dwelling in the District and 5,000 pounds per Affordable home, a weighted average of 7,800 pounds per market home.  A CIL rate applied in the Northern Arc with 30% Affordable homes, even at 180.00 per metre reduced rate as suggested in the May 2013 revision paper, would require a CIL payment of 19,230 pounds for even a modest 3- bedroom house of 1150 square feet or 106.8 square metres.

Notwithstanding the encouraging growth in house prices in recent weeks an imposition at this level would be unsustainable, and it is difficult to anticipate an Inspector supporting it, let alone the higher levels proposed for village or Greenfield locations. It is interesting to note that the neighbouring Wealdon District, which faces similar challenges to those in Mid Sussex, went out to consultation with a proposed flat rate 100 pounds psm, and is likely to adopt a tiered rate from 110 psm to 180 psm, with the bulk of the housing expected to take place in Hailsham at a CIL rate of 110psm

3.         The Society notes that in the past wind-fall sites have contributed as much as 40% of the housing supply in the District, a proportion of which are one-off dwellings in the countryside with septic tank drainage but the majority are small developments of less than 10 dwellings on the periphery of the villages in gardens or infill sites able to take advantage of existing drainage and other services but generating a level of demand which is comfortably within existing capacities.

Historically approximately 40% of residents in the District have chosen to live in the villages or in the surrounding countryside rather than any of the main towns. This being the case it is difficult to rationalise a penal rate of Levy either in the villages or in the countryside when compared with a location within the urban boundaries, where infill sites and brownfield opportunities are increasingly scarce.

4.         In recent years the loss of facilities in the smaller villages of the District has been a common feature, with shops Post Offices and village inns closing due to falling trade and suffering a reduction in public transport facilities serving these communities.  Changes in retail habits and the growth of out-of-town supermarkets are the principal cause, and although there has been some growth in internet orders for local grocery deliveries and indeed other durables this general pattern is likely to remain.

The inevitable result is that residents of these small villages are forced to make wider use of the private motorcar, both for general shopping and to access doctors’ surgeries in the larger villages, a growing demand with an aging population.

It may prove impossible to halt the decline in the smallest villages and for some a gradual slide into dormitory status may be inevitable, but in some such rural locations a relatively small increase in local custom would permit struggling Post Offices to stock a better offering of convenience food and other goods and make the difference between a continuing service and closure.  A modest increase in local housing availability, with a proportion of Affordable housing, would bolster local trade and provide for some of the needs of local families in the High Weald villages where built-up area boundaries are so closely drawn that any new housing will inevitably fall within the countryside.

In consideration of the above it would seem both illogical and perverse to apply higher rates of CIL in the villages and countryside. Again, in such locations the demand for additional infrastructure is likely to be minimal and higher CIL rates hard to justify.

           
SUMMARY AND CONCLUSIONS.

There is a total absence in the CIL Consultation Document of hard evidence to support the proposed different levels of CIL. It is difficult to escape the impression that the Consultation Draft of the CIL is a policy-led document designed to recover a high proportion of infrastructure costs without considering the impact upon housing delivery, and that Members have been content to rubber stamp the consultation draft without examining in detail the justification and validity of the proposals it contains. The Society believes the present proposals are utterly unsustainable and there is a serious risk they will be rejected at Examination.

The Society feels that if levels of CIL remotely approaching those proposed for village and Greenfield locations were to be adopted they would be found unsustainable. In relation to the proposed development of the Northern Arc of Burgess Hill, even at the reduced level of 180psm lately proposed, the Society has grave doubts whether they would be sustainable, in view of the very high costs of infrastructure, without requiring the sacrifice of other elements including a reduction in Affordable Housing in order to achieve financial viability.
           
The Haywards Heath Society attaches a great deal of importance to the adoption of an evidence-based sustainable level of CIL. It is fearful of the impact of the present ill-considered proposals on housing delivery if adopted as currently proposed and urges the District to urgently re-examine the levels proposed in the Consultation Draft.

The Society wishes to reserve the right for its representatives to appear before the Inspector at such time as any revised proposals are considered in public.

 

11Respondent: Mr E Bassett
Organisation: Haywards Heath Society
Behalf Of:

24th July 2013

Dear Sir/Madam,

Submission Mid Sussex District Plan

Thank you for your representations to our proposed submission District Plan. I am writing to let you know that Mid Sussex District Council has formally submitted its District Plan and accompanying documents to the Secretary of State. The District Plan is being produced jointly with South Downs National Park Authority.

The District Plan will now be subject to an independent public examination by a planning inspector. As part of this examination the Inspector will hold a public hearing, these hearing sessions are anticipated to take place during Autumn 2013. Once confirmed, all details relating to the examination process will be advertised, made available online and sent to those people who asked to be notified of the examination.

The District Council has submitted the following documents in accordance with regulation 22 of the Town and Country Planning (Local Planning) (England) Regulations 2012:

- Submission Mid Sussex District Plan and Policies Map
- Submission Mid Sussex District Plan - Sustainability Appraisal
- Habitats Regulations Assessment of the Submission Mid Sussex District Plan
- Statement of consultation (Regulation 20)
- Copies of representations made under Regulation 20
- Duty to co-operate statement
- Housing implementation strategy
- Schedule of minor modifications
- Soundness and legal compliance self-assessment checklists

Please note that the District Plan, Habitats Regulations Assessment and Sustainability Appraisal are unchanged from the May 2013 proposed submission version.

The Submission documents will be available for inspection from Wednesday 24th July 2013 online at www.midsussex.gov.uk/districtplan and during normal opening hours at Mid Sussex Libraries and Help Points. Full details can be found on the formal Notice of Submission.

Should you have any queries relating to the District Plan, you can contact the Planning Policy and Economic Development Team on (01444 477053) or email planningpolicy@midsussex.gov.uk

Yours faithfully,

Claire Tester
Head of Economic Promotion and Planning

26th July 2013

MSDC has notified us that it has now formally submitted its District Plan and accompanying documents to the Secretary of State.  The Plan is being produced jointly with South Downs National Park Authority.   It will now be subject to an independent public examination by a planning inspector.

The Submission documents are available for inspection online at www.midsussex.gov.uk/districtplan and during normal opening hours at Mid-Sussex Libraries and help points. 

If you have any queries, you can contact the Planning Policy and Economic Development Team on 01444 477053 or e-mail planningpolicy@midsussex.gov.u

 

The Society's Response to Mid Sussex District Council on their proposed 'District Plan'

Ms Clare Tester
Head of Economic Development & Planning
Mid Sussex District Council
Oaklands, Haywards Heath
West Sussex, RH16 1SS

14th June 2013

Dear Ms Tester
DISTRICT PLAN – COMMENTS
Attached please find the society’s comments on the recently produced District Plan, which should be read in conjunction with those comments the society previously submitted to you when the draft plan was out for consultation.
In general terms, the society is of the view that the council has taken appropriate steps to secure a document that is fit for purpose and produced in accordance with central government directions.
It would, at this stage be impossible for the society to comment on all aspects of the plan, so our remarks are directed towards essential aspects of it.  Some of our comments mirror those we expressed at draft stage which is why both sets of comments should be read together.
The plan, as published, is obviously a holding document designed to conform to central government’s law and direction, to attempt to close the gap in the districts lack of a land supply for housing, and to allow for the incorporation of locally produced Neighbourhood Plans.  By following this process through, the council is clearly confident the plan will be accepted both across the district and by central government.
Please take on board the societies comments, which are made in  a constructive manner to assist the council in what is clearly an unenviable task.
If you wish to discuss any aspect of our comments, please contact me.  The society look forward to participation in future stages in the production of the district and neighbourhood plans.
Yours sincerely


Eric J Bassett

HAYWARDS HEATH SOCIETY
COMMENTS – MID-SUSSEX DISTRICT PLAN

GENERAL
The Plan seems essentially a political document, to fill the hole (no agreed 5-year housing supply) which building developments are currently able to drive through.  Thus we interpret the objectives as:

  • to be accepted by a government which is very keen to encourage development as an engine for growth;
  • to contain checks and safeguards via the various Development Policies to curb over –development, maintain the character of the District, etc;
  • to allow space for the various Neighbourhood Plans to fill a meaningful role;
  • to be acceptable to its Mid Sussex constituency.

The society believes the council generally meets these objectives in that;
it focuses on a five-year figure for housing, in the sure knowledge that the plan will be rewritten long before its twenty-year horizon, and we don’t  want front-end loading of a twenty-year allocation; the figure is on the low side, compared to South East Plan.

  • It includes the Burgess Hill proposed developments, since it’s been agreed by the Town Council and fits the Neighbourhood Plan framework.  It doesn’t discuss the local opposition, the downside risk if businesses are not attracted, etc; but to do so would not help the plan’s credibility to the government.
  • It contains little about Haywards Heath, except for the maps outlining primary and secondary shopping areas, etc.  This puts the onus on the Town’s Neighbourhood Plan, which seems right.

SPECIFIC  ASPECTS
Housing Numbers
The society is of the opinion that the evidence base for housing numbers over the plan period of 10,600, is deeply flawed and the Plan may be found to be unsound upon examination in this regard.  The society is concerned that if the evidence base is found to be unreliable, the whole process will have to be revisited.  Revision of the currently produced numbers may not be possible.
It is understood that in arriving at the figure of 10,600 MSDC relied largely if not entirely upon a ‘model’ devised by an in-house member of the planning section who is also a statistician but who has no extensive experience of this specialised task.  The model most favoured by planning authorities appears to be the Chelmer Model or similar ones based upon it but MSDC have not used it, perhaps because it is only licensed to a limited number of Developers or Planning Authorities in any planning district and two major developers have already employed it to calculate housing need in the plan period for Mid Sussex.
Significantly both suggested that the annual requirements for Mid Sussex will be in excess of 720 new homes compared with MSDC’s suggestion of 530 per annum.
A major weakness in the MSDC figures is its failure to build in sufficient provision for inward migration over the plan period.  An emphasis on meeting largely local housing need is understandable but, in the society’s view, unrealistic.  Local estate agents will confirm that in recent years a significant proportion of houses sold in the District have been purchased by people not previously resident in the District, mostly individuals working in London but seeking a rural lifestyle for their families.  In Lindfield it is believed the proportion of sales to ‘incomers’ is about 50%.  The attractions of West Sussex will endure – pleasant surroundings – excellent commuting to London,  Gatwick and the south  – good leisure facilities and a wide availability of schools for all age groups, so there is no likelihood that the inflow will diminish significantly in the next two decades and it must be provided for if local demand, including affordable homes, is not to be severely compromised.
Lastly both Central Government and the Plan make reference to ‘growth’.  The District already has a higher than average older population and that is set to increase as people live longer.  With a fairly static birthrate in recent years, the percentage of local residents who are economically active, is falling year by year, and without an inflow of ‘fresh blood’ the level of economic activity is certain to fall and with it relative prosperity locally.  A high proportion of the people moving into the district, especially those from London,  will help to support local businesses including retailers.

Burgess Hill Townwide Plan/Northern Arc
The society has already flagged up its concerns relating to the Burgess Hill Townwide Plan including the Northern Arc.  The BHTW was originated by local district councillors, later adopted by the Town Council and welcomed by MSDC for the contribution it could make to housing numbers.  It was initially promoted on the basis that by agreeing to accept 4,000+ houses developers would contribute £40 Million, in addition to Section 106 monies/CIL and other inducements subsequently offered by central government to encourage house building, and this money would be available to re-vitalise the town centre, create a state of the art public transport system and improve leisure facilities.

There was never any commitment on the part of the developers controlling the designated area to make £40 Million or indeed any specific sum available, and all reference to this prospect seems to have disappeared.  The case for 4,000 plus new houses in the Northern Arc was promoted well before any evidence base was available to support it or the proposed Business Park.  Burgess Hill will clearly be able to satisfy a portion of the new homes required in the District Plan but not in the initial period and probably not in the numbers suggested owing to the huge investment required in supporting infrastructure.
It remains to be seen whether local residents, in the absence of the promised contribution from developers, will support the Burgess Hill Townwide Plan in the numbers required to approve it at the Referendum stage.

Employment
The society believes its concerns regarding the level of emphasis laid upon employment in the District Plan, and provision for maintaining present employment opportunities locally and generating fresh opportunities in the years ahead, are widely shared.  With a continued emphasis placed on creating  employment opportunities in close proximity to housing in order to minimise the use of private cars for transport to work one would expect this to be given high priority in the emerging District Plan.  The urban/rural population is roughly 62%/38% so one would expect the parishes to make a particular effort to provide local workplace opportunities but there is instead a widely held reluctance at local level to see small estates or starter units proposed in rural areas, and even in Haywards Heath there is little sign of any enthusiasm for creating new industrial opportunities – just a modest scheme of redevelopment at the end of the Bridge Road Estate.  With few exceptions the stock of office space in Perrymount Road is for the most part no longer fit for purpose, and unless the Town itself adopts a more hands-on role of promoting Haywards Heath as a place to live and work in order to stimulate demand then this important financial services sector will gradually decline.

Detailed Points

  • On the HH/Lindfield/Cuckfield map, the new developments now approved north and south of the A272 to the west of Beech Hurst don’t seem to be marked.  The maps require updating.
  • Para 3.6:  No economic forecast sees a national economic growth of 3% annually within the foreseeable future.  So growth will not drive housing needs.  The housing assessment studies which are referred to all pre-date to 2011 census figures, which contained some surprises – if possible they should be revised.
  • Business development, notably in Burgess Hill, may be vulnerable to the growth assumption; It is suggested the Council should explore the financial impact of a lower growth rate.
  • Para 3.17:  The latest year’s figures on housing provision, should be included up to April 2013.  This applies also in DP5, Housing.
  • DP3, Town Centre Development:  This seems a sensible and pragmatic approach to shopping targets, given the changing nature of the high street.
  • DP17, Sustainable Tourism:  We support the provision in the Plan for potential extension of the Bluebell Railway to Haywards Heath.
  • DP29, Affordable Housing.  The new requirements for a minimum of 30% affordable housing for developments of 4 houses and above looks tough at the lower end.  For a 4-house development then a minimum of 30% translates to two houses, or 50%.  We suggest that the threshold is set at 6 houses or above.  Also, that precedence for affordable housing should be given to households with a local connection, through local work or local relatives.

 

Neighbourhood Plan – Consultation

Dear Town Clerk

As previously arranged with you, the society hereby submits an initial response to the Town Councils Neighbourhood Plan consultation process. A more detailed response will be prepared for the council’s consideration by the agreed date 30th June 2012.

In making this response the society understands the consultation process is at an early stage and that further opportunity for public comment will be available later in the year when more definitive council proposals have been formulated and published.

The society acknowledges efforts made by the council to bring the Neighbourhood Plan issue into the public arena, and encourage local participation in it.

Prior to the commencement of the consultation process, you will be aware the society urged the Town Council to consider the co-option onto their member panels, of external advisors and appropriate experts drawn from the local community, to assist them in the difficult task of producing an effective Neighbourhood Plan. The council declined to follow this route and relied on base evidence provided by MSDC and others to arrive at their consultation proposals.

The society again requests that the council considers making full use of the experience and expertise that must be available both in local and district wide communities, to assist them in the completion of this task.

You will be aware the society believes that in order for the community to adequately respond to the consultation process in an informed and constructive manner, full public access should be provided to the base data which members had at their disposal when forming their initial consultation proposals on housing numbers and site location potential.

The society is conscious of the fact that you are currently seeking council member approval for the release of this data into the public domain. It must be restated however that without the information being available the society’ view is that any attempt to make a balanced judgement on the proposals would be impossible.

Currently the consultation exercise has provided a list of potential housing sites within the town’s boundary, with an indicative number of units they could possibly provide. The public has been asked to comment on the sites and on the overall extent of housing units the council has determined might be provided within the town area over the next two decades. The society believes that the lack of information, evidence and rationale behind the proposals determined by the council precluded an objective and constructive response at this time.

The information requested of you included:-
Evidence of housing supply and demand in the town and the extent of resources available to meet the demand proposed.
Assessment of each housing site viability and basis for choice.
Details of the likely infrastructure benefits that could be generated by the proposals if proved and their costs.
Historical records of housing units built in the town in recent years.

It will be appreciated if the information could be provided as soon as possible.

In addition the society would be grateful if the council could supply a time table for the completion of the Neighbourhood Plan with the indication of critical dates where public involvement will be expected.
Generally the society is of the belief the council should not assess the housing potential of sites in isolation. It is considered that all such sites must be considered in conjunction with those that are proposed/committed around the periphery of the town and which would have such an impact on it. The society is concerned that all potential sites should not be viewed solely in terms of housing units they could provide, but that the assessment process must be linked to and determined in consideration of the town economy, ecology, employment capacity and all infrastructure resources.
The society has always sought to protect and enhance the town’s parks and open spaces and views with some concern housing number proposals both committed and potential which equate over the period to over 20% of the total district housing provision in the period. It is inevitable the town s green spaces will be under considerable threat.
As stated the society will make a formal response later. At all times the society is willing to discuss their matter with you and your members whenever appropriate.
I look forward to an early response.

CONSULTATION DRAFT MID SUSSEX DISTRICT PLAN

RESPONSE BY THE HAYWARDS HEATH SOCIETY.

Generally the thoughts of the Society are as follows:-

1.Having carefully read the Consultation Draft of the District Plan the initial impression it creates is that the Draft District Plan is more of a containment exercise, designed primarily to limit the amount of residential development in the Plan Period rather than to accurately establish the likely requirement for housing numbers and other supporting facilities within the Plan Period and plan positively to meet these needs.


2.The above impression is strengthened in part by the statement that the proposed net increase of 10,600 dwellings in the period up to 2031 is the minimum requirement, but without any indication of what the maximum figure might be. Given that the South East Plan called for an additional 17,100 houses, and in response MSDC suggested informally that it would be inclined to support a figure in the order of 14,000, the reduced figure of 10,600 needs to be supported by a robust evidence base, franked by external experts, and neither are provided.

3. It is worrying that a significant proportion of the underlying evidence base to support the proposed housing numbers is not yet in place.
It would seem a prudent first step, especially in the very challenging economic conditions prevailing at present and probably for some time to come, to identify sites for new housing in those locations that already enjoy a well developed infrastructure and are otherwise suitable, but there is little evidence in the Consultation Draft District Plan that an appropriate infrastructure audit to establish such suitable locations has taken place.

4. The huge cost of making good a serious infrastructure deficit in any chosen location has a serious knock-on effect upon the percentage of Affordable housing and other community benefits a developer can provide, and this is likely to be especially the case in Burgess Hill. The Society feels that in the absence of robust and independently certified evidence that the Burgess Hill Town Wide proposal will indeed deliver the suggested housing numbers, or indeed the community benefits claimed by its promoters aggregating £40.00 million, the incorporation of the Burgess Hill Town Wide proposal into the adopted District Plan must be seen as a high risk strategy, one which could render the District Plan unsound and expose the District to unwelcome development on a huge scale.

In view of the pivotal role the anticipated contribution of the Burgess Hill Town Wide Plan plays in the District Plan the Society’s reservations are more fully outlined below:-

 

The Burgess Hill Town Wide Plan.

The Society acknowledges the very considerable body of work done by Councillors with the support of Officers in formulating the framework of the District Plan following the abandonment of the Core Strategy, and welcomes the bold and vigorous approach of Burgess Town Council in support of Mid Sussex District Council’s aim to create a thriving and attractive District, a desirable place to live, work and visit.

The wider strategic objectives of the District Plan rightly command universal support, and the stated commitment of Burgess Hill Town Council to taking a leading role in the future development of the town and its economy in partnership with its community, the Local Planning Authority of Mid Sussex District Council and West Sussex County Council is both welcomed and shared by other towns and villages within the District.

However the proposal by the Better Environment Advisory Group, at its meeting on 7th September last, that the incorporation of the Burgess Hill Town Wide Plan be adopted as part of the emerging District Plan marked a very significant step, involving as it did major planning and financial implications for the entire District. In these changed circumstances it is imperative that the Burgess Hill t\own Wide Plan should be the subject of detailed examination by independent experts with proven abilities in this field before it is incorporated into the District Plan.

It is essential, both for Burgess Hill and for the District, that before the proposed incorporation of the Burgess Hill Town Wide Plan into the District Plan all parties are entirely satisfied that delivery of the 4,000 additional houses can be achieved within the Plan Period, and the suggested £40.00 million of benefits to the town can indeed realistically be expected.

Projected costs of enhancements identified in the Burgess Hill Town Wide Plan.

At present there is a worrying absence in the public domain of information as to how the cost of £40.00 million for the enhancements described in Steps 1 and 2 in Appendix B have been calculated. Since the generation of this sum is stated to be a principal reason for the proposed construction 4,000 new dwellings, increasing the town’s population from present numbers to approximately 40,000, accuracy is clearly a matter of real importance and some more detailed information relating to the cost exercise referred to in Step 3 of Appendix B needs to be provided at an early date.


The Burgess Hill Town Wide Plan is correct in identifying developers’ contributions, in one form or another, as the most likely source of funding for the proposed improvements in the town in the current economic climate, and it is noted that this sum is expected to be provided by those developers providing the 4,000 new homes in addition to Section 106 contributions which currently average between £9,000 and £10,000 for all dwellings including Affordable housing. The draft proposals for The Community Infrastructure Levy to replace Section 106 contributions (other than on-site costs) are calculated to rise to approximately £20,000 per dwelling excluding Affordable Homes

There is scant reference in the Town Wide Plan to the costs of infrastructure required to be in place before the proposed 4,000 new dwellings can be completed and it would be foolish to speculate what this might amount to without a detailed appraisal, but historically in those situations where sewers, treatment works, roads and other services are required from scratch costs can amount to £20,000 per dwelling or more, and require an extended lead-in time. The Transport Study for the Atkins Feasibility Study for Development Options at Burgess Hill prepared in 2005 for example suggested that the cost per dwelling associated with transport proposals alone would be £13,500 -£13,800, depending on the public transport option chosen.

The Summary of the Burgess Hill Town Wide Strategy (Appendix B) invites comparison with contributions, believed to be in the order of £7,000 per dwelling, secured from developers when the last major housing developments in Burgess Hill took place in the 1990’s, which contributions are understood to have paid for significant infrastructure improvements on the western side of the town together with the Triangle Leisure Centre. It must be recognised however that circumstances then differed significantly from the present ones, the developer was not required to provide any Affordable Housing at that time, and the economy was buoyant, a very different position from the current highly challenging economic climate which offers little prospect of improvement in the near future.

The contribution the Burgess Hill Town Wide Plan would make towards satisfying housing demand in the District within the plan period, if realisable, is crucial. Equally failure to convince the Inspector at the Examination in Public that Burgess Hill can realistically make the anticipated contribution of 4,000 or so dwellings over the plan period will result in the District Plan being declared unsound, with serious consequences for the District. The District has had recent experience both of having to abandon its Core Strategy because it was judged to be unsound and of seeing its ‘vision’ for major improvements to Haywards Heath fail to materialise through a combination of unrealistic expectations of benefits from redevelopment proposals and a declining economic climate.

The Society is concerned that reliance by the District on unrealistic levels of new housing, in the Northern Arc especially, combined with slower and lower contributions from developers, could lead to a ‘double whammy’ – fewer houses being completed than anticipated and developers being unable to pay the CIL, at whatever level is determined, and also still make meaningful contributions towards those improvements identified in the Town Wide Plan.

Housing demand in Burgess Hill.

The conventional way of assessing housing and other needs is to base them upon population trends with adjustments for anticipated changes in circumstances – greater local employment opportunities perhaps and, in the South East, to allow for a degree of inward migration, and indeed this is broadly the approach adopted in the emerging District Plan.

It must be questionable whether it is prudent to use an estimate of the cost of desired improvements in Burgess Hill Town and its periphery, as the Burgess Hill Town Wide Plan appears to do, as the yardstick for arriving at the size of the housing contribution the town can make to the District Plan requirement. What evidence is there of demand for 4,000 new dwellings in Burgess Hill, representing an increase in the housing stock of approximately 34%, even over the plan period?

Certainly there is a need for smaller low-cost housing to meet the requirements of the younger generation who are presently priced out of the market. Developers under pressure to make contributions over and above current Section 106 monies are only likely to be able to do so from the sale of larger 3 and 4 bed-roomed houses. Average incomes of the younger generation in Burgess Hill are too low to afford this type of house and the majority of these houses are likely to be sold, assuming there is sufficient demand, to incoming residents who for the most part must be expected to earn their living outside the town, the majority either by commuting to London by train or driving to Gatwick and other areas.

Furthermore developers will not continue to build in the absence of demand, and there is no practical way of compelling them to do so. It follows that anticipated contributions from developers will be at risk both in terms of timing and quantity.

Reference is made in the Burgess Hill Town Wide Consultation document, and in the summary in Appendix B, to discussions with those developers who control land in the Northern Arc identified as suitable for housing development. The impression is created that the developers concerned have agreed to make contributions towards enhancements in the town, but there is no confirmation in the public domain that those contributions will agregate to the £40.00 million estimated to be required, or indeed any specific amount, nor any evidence produced that discussions have proceeded beyond an exploratory stage. These conversations need to be progressed to a stage of conditional commitment, backed by appropriate guarantees, before any reliance can be placed upon them, as the delay in completing the Southern Relief Road has amply demonstrated.

When political objectives and unfounded optimism are stripped from the development equation the reality is that in Burgess Hill, as elsewhere, house construction costs are unlikely to reduce significantly, infrastructure costs are unavoidable, as are Section 106/CIL contributions, and a reduction in the proportion of Affordable Housing being provided below 30% would be unpalatable when demand for Affordable Housing is rising to new levels. It may well transpire that the anticipated £10,000 ‘developers’ contribution’ per dwelling towards promised Town Centre improvements, a state-of-the art public transport system and enhanced leisure/sporting facilities will ultimately rely on affected landowners being willing to accept a lower price for their land than current market prices, which are already at a very low level by comparison with prices prevailing three years ago. If this should prove to be the case the cause for concern regarding deliverability would be enhanced.

Summary.

1.Whilst acknowledging widely-held concerns of over-development in the District, a concern shared by the Haywards Heath Society, it is difficult to reconcile the reduced housing numbers proposed in the Consultation Draft District Plan with calls by central government for Local Authorities to plan for economic growth, or with the economic strategy of the Gatwick Sub-Region.

2. The housing number of 10,600 proposed does not appear to take account of the acknowledged shortfall in earlier years which is understood to be in the order of 850 for the Regional Plan period 2001-2006 and a further 2,400 or so for 2006-2011 under the South East Plan. To totally ignore this accumulated shortfall would seem to expose the minimum housing numbers now suggested to challenge, aggregating as they do to some 30% of the numbers now proposed for the next 20 years.

3. The absence in the public domain of evidence based documents, specifically a current SHLAA and the latest AMR, fundamental to determining the soundness of the housing strategy proposed in the District Plan, call into question the haste with which the District Plan is being progressed. It is possible that when these are available the Society’s concerns will be alleviated but their absence at the present time is a matter of regret.

4. Within the District approximately 40% of the population choose to live outside the three main towns, and the Society is supportive of the principle that the villages should accept a greater share of the new housing required in the plan period, both to improve the sustainability of those villages where local amenities and services are under threat and also to relieve the burden hitherto largely carried by the towns. However the preparation of Neighbourhood Plans is not mandatory and progress so far appears to vary hugely, with some villages yet to make a meaningful start. In these circumstances the Society has concerns regarding the identification of sites to take the suggested 2,300 – 2,800 new homes in village locations.

5. The Society shares concerns with other interested bodies regarding the weight given in the emerging District Plan to the preservation of green spaces in urban areas and the extension of interlinked wildlife sites/green corridors on the periphery of the towns and larger villages.

Energy Debate - Held on 24th May 2014
 

Organisations and speakers

Community Energy South
http://www.communityenergysouth.org.uk/
Community Energy South is an unincorporated association of energy groups across the south east of England who have come together share best practice, skills, expertise and resources.  They encourage the growth of community owned renewable energy, increasing energy efficiency, reducing fuel poverty and promote and grow awareness of how communities can use less fossil fuel and generate their own energy.

Energy Group

Fig.1. Shows the affiliated groups that make up the Community Energy South network.
Core groups are shown in bright green, while the other newer members are shown in pale green.

Barcombe Energy Group
http://www.barcombe.org/energygroup/index.htm
The local parish plan highlighted local residents wanted more support with energy and so in 2011 working with the backing of the parish council and Communities Matter, the Barcombe Energy Group was set up to research energy use and requirements in the village and to develop an energy plan for the community. 
The Group has carried out the Barcombe LEAF project during which they not only undertook research into energy use in the village and developed an energy plan but also insulated 30% of the village for free.  Currently they are planning to form a co-operative and are developing a feasibility study on district heating.  Already two solar projects have been set up with OVESCo on a horticultural farm and on a campsite, with requests from the church and village hall being investigated through the project.

Ouse Valley Energy Services Company (OVESCO)
http://www.ovesco.co.uk/
Members of the Transition Town Lewes Energy Group formed the Ouse Valley Energy Services Company Ltd and OVESCO Limited IPS to deliver a range of energy-related projects to the people and businesses of Lewes and surrounding areas.  Their long term plan is to make the Ouse Valley self-sufficient in energy.
They were one of Britain's first community-owned energy renewable providers and consider all forms of renewable energy generation, including sun, wind, water, geothermal, anaerobic digestion and biomass.   Their first energy generation project was the installation of solar photo voltaic panels on Harveys depot in Lewes, which has generated 30.99MWh in the first five months of operation. Following the success of working with Harveys, OVESCO has installed the 35kwp solar photo voltaic array at Lewes Priory School with the help of local company Southern Solar.  During term time the school will use most of the generated energy but in the holidays any surplus will be sold back to the National Grid. 
In addition to working on energy generation schemes, they provide advice to the public on energy efficiency measures and undertake energy assessments using funds from the DECC Local Energy Assessment Fund award.  Currently, OVESCO are using the funding to assess opportunities for renewables and energy efficiency in Mountfield Road, Lewes and are supporting the Barcombe Energy Group in carrying out an energy audit of the village.

Ollie Pendered
Ollie specialises in strategic communications and is an associate member of the Consultation Institute.  In his capacity as Director of Communities Matter and as a Senior Account Manager at Copper Consulting, he has a wealth of experience of community engagement on many infrastructure and planning projects, including a major offshore wind farm and the London Congestion Charge.
He has a particular interest in promoting Community Energy Plans as a tool for Neighbourhood Plans.  He believes every community should benefit from their own Local Energy Plan and is working with OVESCO and Sussex Local Authorities to develop this concept.
As founder and Chairman of the Barcombe Energy Group he has helped set up Community Energy South and currently is working on a peer monitoring scheme supporting the growth of new energy groups in the south east in his capacity of Director of OVESCO.

Brighton Energy Co-operative (BEC)
http://www.brightonenergy.org.uk/
The Brighton Energy Co-operative is the south's largest community-funded renewable energy scheme.  Set up in 2010, BEC has not only delivered renewable energy projects, but by engaging communities on energy issues, has empowered local people to improve their environment while making them less vulnerable to energy price increases.
Funds are raised to install solar PV installations from community investors.  Once these renewable energy systems are generating electricity, monies to finance further schemes and maintain existing ones, as well as providing dividends for the community investors, are secured from selling the electricity to the solar landlords and the national grid and from the government's feed in tariff.
Projects to date have included installing a 10kw photo voltaic system on St. George's Church in Kemptown, which saves the church hundreds of pounds on their electricity bills each year; a 35kw array on City Coast Church in Portslade; and their most ambitious project to date at Shoreham Port, where they have installed solar PV on five buildings at the Hove Enterprise Centre, providing electricity that feeds the yacht charging points, the port's water pumps and the Enterprise Centre itself.

Will Cottrell
Will is chairman of the Brighton Energy Co-operative.  He has steered the organisation through its first launch and installation and regards grassroots groups as key to addressing the environmental issues we face today.
He began his business career in publishing and currently owns Yoga Travel, which operates in Egypt, Thailand and Morocco, as well as running the website, Yogaholidays.net.

Brighton & Hove Energy Services Co-operative Ltd (BHESCo)
http://bhesco.co.uk/
Brighton and Hove Energy Services Co-operative is a founding partner of Community Energy South and as a community co-operative they develop energy efficiency and micro energy generation projects on a pay as you save model, in addition to providing energy advice and helping people in fuel poverty take action to insulate their properties.
As independent community energy suppliers, they offer energy and light assessments, prepare energy plans, recommend and select appropriate technologies and then project manage the installation by approved installers.  Currently they are preparing an energy plan to help local residents and businesses become more energy efficient and save money on energy bills for the Hove Station Neighbourhoods Forum and are working with Energy Express to pilot a new way to carry out home energy assessments and installing energy saving devices in Brighton and Hove households.

Kayla Ente
Kayla set up Ente Consulting, her own financial and strategic consultancy, focusing on renewable energy and energy efficiency in 1999, after working in the finance sector, and more recently she founded the Brighton & Hove Energy Service Co-operative.  With over 12 years of experience working in renewable energy project and enterprise finance, she has provided insight into business and project developments on solar thermal, solar PV, biomass and wind, for clients ranging from utility companies, such as Nuon, to community co-operatives, such as the Green Building Partnership.

Sussex Energy Saving Partnership
http://www.westsussex.gov.uk/living/communities/energy_saving/sussex_energy_saving_programme.aspx
Sussex Energy Saving Partnership is a joint venture between all the district and boroughs of East and West Sussex, Brighton and Hove focusing on developing an energy efficiency and renewable energy generation programme, which will maximise use of the governments' grant schemes, including the Green Deal and Energy Companies Obligations (ECO), to deliver energy upgrades to residents' homes, thus reducing energy use and carbon emissions; improving health and well-being for vulnerable residents; as well as strengthening the local economy by creating and safeguarding jobs, promoting growth and establishing training opportunities and apprenticeships.

Tom Coates
Tom works for West Sussex County Council who has been leading on the setting up of the Sussex Energy Saving Partnership and the appointment of the lead partner, Carillion.

 

Gladys Bunn J.P.

The Cooperative store in South Road kindly agreed to place a plaque in the store in memory of our late Chairman, Gladys Bunn.

As many of you will know Gladys spent her whole life furthering the Cooperative principals, as well as giving her time and assistance to many Haywards Heath projects.

We are very grateful to Southern Coops for allowing us to place this plaque and look forward to working with them on local public issues of mutual concern.

 

 

 

NEW BLOOD

The Society has never pushed for membership but some of us have been at it for a long time and new blood is the best form of renewable energy. The subscription is £12 per annum. Pensioners, children, the unwaged and students can join for £10.00 per annum.

We have lectures and debates, an annual meeting, an autumn supper. Isn't £12 cheap for a chance to join other nice people to protect the environment and get out of the house for our mutual pleasure.