Comments on Mid Sussex DC Regulation 19 Site Allocations DPD – September 2020
This draft Site Allocations DPD proposes an extra c800 dwellings to be added to the District Plan target for the East Grinstead area – this would bring the total number of homes to be provided in the East Grinstead area during the District Plan period (2014 to 2031) to around 2500 – thus adding around 25% to the population of East Grinstead. Our comments below relate to the Housing Sites SA18. SA19, SA20.
The East Grinstead and District Cycle Forum is supportive of sustainable development, but there is nothing in these proposals that gives us any confidence that the necessary investment in sustainable transport infrastructure and services (Cycling, Walking and Public Transport) will be made. If these plans take away the open countryside we enjoy for our physical and mental wellbeing, and add 25% to the number of car journeys undertaken in the area, the health, economic and environmental damage will be enormous.
Paragraph 110 of the National Planning Policy Framework 2019 (NPPF) states that development applications should” give priority first to pedestrian and cycle movements both within the scheme and within neighbouring areas”. Neither the various developer’s proposals for these sites, nor the Systra Transport study, have been carried out with the focus required by the NPPF, a focus now reinforced by the publication of Local Transport Note 1/20.
Very little is proposed for sustainable transport measures in this DPD – bus priority lanes on the A264 to Crawley, a bus stop on the Imberhorne Farm development, a new cycling/walking link to the Worth Way. The Systra Transport study states these measures might deliver a 2 or 3% reduction in the additional car journeys that another 750 homes, GP surgery, new primary school, care home etc. might generate. A completely inadequate response to the challenge.
The highway improvements to A264/A22 junctions, as proposed in the Atkins 2012 study, are referenced in the draft DPD at SA35, and the junctions shown in Appendix E. However, it is acknowledged that these were designed to address existing congestion and will not provide capacity for significant additional journeys. There seems to be an acceptance of permanent rush hour gridlock on the A22/A264 London Road in East Grinstead, and a suggestion that new traffic generated from Imberhorne Farmlands (SA20) can be allowed to use routes B2028/B2110 via Turners Hill until they are also gridlocked. Only then would people be forced to use sustainable transport options. No specific transport measures are proposed to support 200 new homes on Crawley Down Road (SA19), beyond the minor improvements included in Surrey CC investment plans.
The East Grinstead Cycle Forum will object to this Site Allocations DPD as the following issues raised at Regulation 18 stage have not been addressed:-
· Completion of a fully funded Local Cycling and Walking Infrastructure Plan (LCWIP) for the whole of East Grinstead, to work out how we can achieve the modal shift to cycling/walking journeys in the town, through safer roads and new purpose-built cycle routes. We are ready and willing to contribute to the execution of an LCWP in East Grinstead. This is a required
first step under Local transport Note 1/20, and planning this scale of development in advance of an LCWIP does not meet national or local sustainable transport objectives.
· Provide much greater clarity on the level of private car usage that is predicted on the A22/A264 and other routes to the west of East Grinstead, and how this is forecast to change over the next 5, 10 and 15 years.
· Upgrade the surface of all existing Bridleways and Restricted ByWays in the East Grinstead area to provide conditions suitable for commuter and everyday cycling.
· Develop plans for a step change in investment in local buses, to ensure that bus services are much more frequent, reliable, quicker and more competitive on price. Honestly address the problem of how this can be delivered and maintained in the long term, given the current deregulated bus services in West Sussex, and the history of subsidy cuts to rural buses in this area.
In order to illustrate the real-world impact that well-designed safe cycling infrastructure can have please take note of the following:
1. The East Grinstead Strategic Development Transport Advice Report states that 7,346 car journeys are carried out every morning rush hour.
2. A recent survey by the Brake road safety charity stated that “35% of people would switch to cycling for commuting if the roads were less dangerous”
3. 66% of all British journeys are under 5 miles – a distance easily cycled in less than 30 minutes.
Using the above data, it is clear that good quality cycling infrastructure has the potential to take nearly 1,700 car journeys off the road every morning rush hour. The positive impact of this on congestion, air quality, public health and well-being as well as parking, road maintenance, road policing and road safety is too significant to ignore any longer.
Since we made these points in 2019 in response to the Reg 18 consultation, there has been a significant national increase in cycling levels during the Covid 19 pandemic which adds weight to all our arguments.
In conclusion, the East Grinstead and District Cycle Forum doesn’t believe that the proposed additional development for East Grinstead will be “sustainable”, as defined in the 2019 NPPF, without clear and realistic transport strategies to avoid ever increasing reliance on the private car. These proposals in their current form merely lock in car dependency for another generation.