Ashill Regen Between The Broyle and Round House Road

Application LW/22/0255

ASHILL REGEN, LOWER LODGE FARM Land between the Broyle and Round House Road

Plan: 53 houses

Please comment on the planning portal using the following link:

https://planningpa.lewes-eastbourne.gov.uk/online-applications/applicationDetails.do?activeTab=makeComment&keyVal=RA4VDMJD07Y00 

Ashill Regen have submitted 4 changes to their original application:

 

  1. Removal of the 3 storey flats
  1. Removal of 4 units, down from 57 to 53 with loss of 1 affordable rent, 1 shared ownership and 2 private houses.
  2. Increased car parking by 3 to 115 to align more closely with the RNP. The issues of insufficient visitor parking spaces (4), and some tandem parking remain.
  1. Removal of the 6m urban street lighting (but no details of what is proposed.

The main issues remain:

 

  1. Employment

The site is a designated employment site EMP7; the applicant refers to a previously approved outline application LW/18/0880 for a Village Care facility and 16 affordable rented houses for employees but states that there is no demand for these nor for other employment options. This is untrue – there is a demonstrated need for new employment space in Ringmer and the LDC Planning Application Committee, in refusing the Averys application in April, accepted this. As a commuter based and unsustainable location, additional employment is a major priority in the RNP, specifically Key Principle 3.2 and RNPPolicy 5.1 and this proposal provides none.

 

  1. Infrastructure and Utilities

It provides yet more commuter housing at a car-dependent location, which would place an additional drain on Ringmer’s sewage works, schools, doctors, road network and other infrastructure, contrary to RNP Policies 8.7, 8.8, 8.9 and 8.11.

 

  1. Affordable Housing

Removal of the 3rd storey from the block of flats, i.e. 4 off 1 bed affordable rent units

(AFUs), has resulted in a reallocation of plots with more of the AFUs being located adjacent to the Caburn Enterprise Park, the least desirable part of the site. This is contrary to RNP Section 9 Village Design Statement and the Lewes Local Plan for social housing to be indistinguishable from in nature and appearance from market housing. To quote Cllr Turner at the planning committee which refused the Thakeham2346 development at Bishops Lane, social rent tenants are being treated

as second class citizens.

 

The flats have no private garden space, instead communal areas are provided which would be subject to high noise levels and possibly pollution from the business park.

 

  1. Recreational Space and Gardens 

There is inadequate communal space and recreational space, apart from four micro-play areas handily placed by the roadside, including one on the corner of the access route via the existing development, hardly safe and secure. It is suggested that residents can use the facilities at Fingerpost Field but as there is no parking there, residents would have to walk or cycle there with small children and/or strollers down a busy B2192. Even using the cut through, they would have to cross two busy roads, Laughton Road, crossing this and Lewes Road at Kennel Corner.

Other garden space is inadequate and below recommended size, some have no rear gardens only side or front ones which are not secluded.

 

  1. Parking

 The car parking provisions are still inadequate and include tandem parking, against ESCC policy, and only 4 visitor spaces. The village edge location will be especially car dependent.

 

  1. Noise and Pollution

The site is adjacent on 2 sides to industrial parks with associated noise and potential pollution, Caburn Enterprise Park to the north and Brockwells Industrial Estate to the west. The noise assessment shows that there is either a significant or a dominant observed effect with significant adverse effects on health and quality of life, at night as well as during the day, especially at the north and but also the west boundaries, which under NPPF para 187 would preclude residential use even with mitigation.

 

The applicant proposes that the blocks of flats, whether 2 or 3 storey, would provide noise blocking barriers to mitigate the effect of industrial noise in conjunction with the acoustic fencing along the north side. The communal garden areas for the flats would still be subject to unacceptable noise levels. Another sad reflection on how social tenants are viewed by this developer. There is no acoustic fence to the west by Brockwells Industrial Estate despite high noise levels.

 

Environmental Health have recommended that a test of noise levels in the residences be undertaken before occupation but this is too late. The noise is already noticeable for local residents off the Broyle and Broyle Lane, acoustic fencing would reflect more noise back to existing properties.

 

Air pollution from the industrial parks has not been sufficiently assessed, relying on AQM

points in Lewes.

 

  1. Sewage

Foul sewage would connect to the existing drainage system which cannot be accommodated at the Neaves Lane WWTW and which, as previously discussed, discharged untreated sewage into streams leading into Glynde Reach for 895 hours in 2021. Southern Water have just been rated as 1 star with their performance in 2021 “terrible across the board”, which highlights the lack of capacity to cope with additional load from new housing.

 

  1. Transport and Traffic

The applicants are proposing 2 access points, one onto the B2192 but also vehicular access to the Laughton Road via the existing access for the 30 houses at Round House Road, a private unadopted road, creating a potential rat run and disturbance to the existing residents. A condition should be imposed to prohibit construction traffic using the southern access point.

 

ESCC Highways produced a holding statement requiring developers to look at the cumulative impact of proposed developments on Earwig Corner and the other stress points on the A26 leading to the A27. The applicant has argued that this is not required as it would generate a reduced level of traffic through sensitive junctions compared to a care home, which is illogical, and that those numbers would have been included in the previous modelling, which shows a complete misunderstanding of the figures. Their trip generation fails to take into account the high percentage of out commuting for work in villages especially Ringmer which has been accepted both by LDC and ESCC.

 

The main access is adjacent to that for Caburn Enterprise Park and just within the 40mph limit along a very busy road. They have stated that there is no requirement for any junction improvements on either the B2192 or the B2124 in the form of e.g. a ghost right hand lane. By comparison the applicant for the adjacent site LW/22/0282 proposes to do so based on actual traffic counts and a Stage 1 Safety Audit, which this applicant has not done. The close proximity of 4 access junctions, should both applications be approved, necessitates a cumulative impact assessment of that stretch of road as it would frankly be dangerous andan increased safety risk, especially with the levels of HGV traffic. Their assessment is therefore defective and less than rigorous.

 

  1. Sustainable Travel 

It is a long walk down The Broyle to the nearest useful bus stops at Broyleside Cottages or the Green Man. It is also a long and unpleasant walk alongside a busy main road to the shops and services in Ringmer village, and no cycle route is planned. It will inevitably increase the number of road trips.

 

There are limited bus services along the B2192, mainly in the evening and not suitable for work travel although there is mention by ESCC of new bus stops and an undefined contribution to improving bus services. We know from experience that what ESCC often proposes is not what residents would view as an improvement.

 

  1. Landscape including Trees and Boundary Treatment

There is a “significant” removal of trees but most of these are low quality and many new mixed native trees will be planted along the west and north boundaries by the industrial estates. Some of these will be used to screen the unsightly 3.2m acoustic fencing along north boundaries but this will only be partial as gaps are left in between groups of trees. There will be a 7m buffer zone between the fencing and the properties, presumably replacing the so called “trim trail”. So, some positive points but issues with the visual aspects of the boundary and the noise impact. The eastern boundary treatment is inadequate.

 

  1. Community Involvement

The developer claimed that they had personally consulted the residents in the existing site , we understand this did not happen. They have failed to take into account most of the comments submitted.

 

There are still two full planning applications for adjacent sites at Lower Lodge Farm off The Broyle and to the north of the recently built 30 houses at Round House Road off the Laughton Road, of which this is one, which together form a combined site of 153 units, much bigger than Bovis! That is why it is so important that we make our objections known.

 

 

THANK YOU FOR YOUR SUPPORT.

Ashill Regen Build on Employment Site

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