CMCG Local Plan Submission

Hallo Meadow Campaigners

Well, we’ve done it…. our submission about the Local Plan has been sent off online and it took ages! Still, it’s sent off now and let’s hope they read it!  For those of you who have difficulty sleeping, try reading some of it yourselves, it will send you to sleep in no time. But we said we would put it on our website, so here it is, all 16 parts of it!  Let’s hope it works. In terms of the process, we may not hear anything from the National Park until the end of March, but we’ll keep you in touch with what’s going on.

Coldwaltham Parish Council’s Statement about Coldwaltham Meadow to the National Park

Dear Meadow Campaigners

Coldwaltham Parish Council’s Statement about Coldwaltham Meadow to the National Park
Firstly, grateful thanks to all of you who attended the Parish Council Meeting last night (14 November) to hear what the PC would say about the National Park’s plan to allow 30 houses and a shop, with a public open space and a car park, to be built on Coldwaltham Meadow. It was good to see you.
The Parish Council had prepared a statement for the National Park, which they approved and gave out at the meeting. It will appear on their website, but we wanted to provide you all with a copy in time for you to respond to the SDNPA so we have attached it below with this update. We will also put it on our website.
Good news?
Well, the good news is the statement from the PC: “We cannot endorse or support major development of the Brookview site (SD64) as proposed in the pre-submission document [Local Plan].” 
This is a powerful statement, which the National Park will have to consider, particularly if lots of us have also sent comments in to the National Park. However…
Bad news
The bad news is another statement from the PC: “we would propose that the SDNP [South Downs National Park] should consider the potential for small scale developments of 6-8 houses, which would avoid the impact on landscape, traffic and ecology of a new 30 house ‘estate’ in a small community and location.”
This sounds eminently reasonable, and was partly our suggestion, but for the fact that the Parish Council have proposed that these ‘6-8 houses’ can be built in a variety of locations in the village, including the meadow. Unfortunately, the PC doesn’t indicate where the other locations are, or how many groups of 6-8 houses would be acceptable. We assume that the other areas of land the PC refers to are those that came forward for discussion at the Public Meeting (the areas shown on the map we posted through your door), but the PC doesn’t say this; the only location that is mentioned by name is Brookview.
What does this mean?
We are very concerned that the PC has decided to ignore the convincing evidence we provided and to treat the meadow as if it was no different from any other potential site for development. As you all know, we have spent a huge amount of time gathering considerable evidence about the importance of the meadow for wildlife, and how unsuitable it is for development. The PC is fully aware of how building on the meadow will damage the landscape and cause increased disturbance to the internationally important wildlife sites that lie right next to the meadow. We believe that that the PC is guilty of playing off one end of the village against the other without any recognition of the very large number of Coldwaltham Meadow Conservation Group Supporters there are, compared with the very small number of objectors to the other three sites. It was also alarming to hear Guy Nelson claim during the meeting that he had taken into consideration anonymous comments from local residents: CMCG suggested that a questionnaire be provided at the public meeting at Sandham Hall to record the number of supporters and objectors for each site but the PC were very strongly opposed to this.  Instead, they can claim they are trying to please everybody by proposing a scattering of small developments throughout the village, but we fear that this will only generate more uncertainty; how many clusters of 6-8 houses? Where will they go?
We carry on fighting
Rest assured, this proposal is not acceptable to us. We are opposed to any housing in the meadow, and will continue to fight to save it from development. And just in case anyone out there thinks we are overstating the importance of the meadow for wildlife, the following statement from Natural England, the Government Agency for protecting wildlife, supports our cause:
“Natural England have raised concerns with the National Park Authority regarding the allocation primarily with respect to the quality of the application site itself, the need to re-evaluate the clear biodiversity value of the site and the various ecosystems services that it provides. It is for the National Park to evaluate this allocation to ensure that it is compatible with the various policies within the emerging local plan.” (source: Natural England, responding to a Freedom of Information request, made by us on 1.9.17).
Please write to the National Park
From all of the above, you can see how important it is to make your views known. We really don’t want any houses in the meadow, no matter what the PC says. If you haven’t done so already, please email the National Park about how the meadow is important to you and why it mustn’t be built on. Please include your name and address and say that the meadow’s reference number is: Policy SD64, so they know which site you are commenting about. We suggest you tell them you were not consulted. If you want more suggestions about what you could say, see our website;  The deadline for your response is next Tuesday 21st NovemberYou can email them on: or you can write to them at: Planning Policy, South Downs Centre, North Street, Midhurst, West Sussex GU29 9DH.
Save Coldwaltham Meadow!

Review of the SDNPA Development Brief

Hallo Meadow Campaigners, some more news:
1. The Parish Council has changed the time of theirmeeting on 14 November at Lodge Hill, it starts at 7:30, not 8:30. They will be meeting to discuss what they are going to submit to the Local Plan, so it will be very important for as many of us as possible to be there to tell them what you think and hear what they have to say. We are all entitled to two minutes worth of speech at the start, so if you have any comments, even a few brief words about the meadow or any of the other sites offered by local landowners, please come and make them known to the Parish Council at the meeting.
2. STOP PRESS: The National Park Authority has produced a development brief for Coldwltham Meadow, even though the Local Plan consultation is still in progress. This clearly shows they are determined to press ahead with their plans for the meadow even before they have the results of the Local Plan Consultation. What’s more, they only gave the Parish Council 8 days to make a response – so much for public consultation! To their credit, Our Parish Council objected to this, and as a result, the National Park Authority has agreed to withdraw the Development Brief until the consultation period for the Local Plan is over.  But it will appear again, you have been warned.
This new Development Brief is 40 pages long but we have attached a copy and we have put it in our website for you to see. It will certainly appear again and we suggest you have a look to see what the SDNPA are really thinking. The following is a summary of what we thought of it:
1. A poorly-written piece of work
The Brief is full of mistakes, indicating that it has been produced as a desk study, rather than by anyone with knowledge of the site. This is indicated by references to flood risk mitigation, when the site is halfway up a sandy slope, and by the description of the field as “fairly flat”.
The Site Analysis is incomplete, indicating the direction of views across the site to the South Downs in one direction but omitting to indicate that there is a much wider panorama from east to west. The photograph captioned “wildflower meadow view to the south” is actually a view to the southeast, and the others photos clearly indicate that excellent views from the site are provided to the southeast, south and southwest.
Other mistakes include showing individual trees on a map of the site that disappeared years ago and labelling the disused canal in the nature reserve as the River Arun. One of the pages is headed: ”A vision for land at Brooklands Way, Coldwaltham”, which is the name of the old site that was withdrawn two years ago, whilst at the bottom of the same page, and all the others, is the correct footnote “Land South of London Rd, Coldwaltham”.
2. Pretentious jargon
The email accompanying the Development Brief states: “The brief is a proactive step for the site to shape, guide and control the form of development allowable so that developers, the local community and stakeholders have some certainty as to how the site will be developed.” Yet the Design Appendix, supposed to be at the end of the Development Brief, is missing.
The brief is also full of pretentious, empty phrases such as: “…a new community village shop, which successfully provides a place for neighbours to engage and build social capital” and  “Each landscape layer has a history but it is particularly the landscape elements resulting from the interaction between people and their environment which helps a site’s history unfold.”  and “These [roads & rights of way] are the foundations of movement within and beyond the site, providing numerous ecosystem services such as recreation, tranquility and inspiration from nature.” 
The brief is also riddled with jargon – who knows what the phrases “form and massing”“historic coherence” and “use views and vistas within the site to help legibility and sense of place” mean, apart from Landscape Architects?
3. Future consultation?
How can we be expected to comment on all this “fluff”? That being said, the Development Brief clearly states that there is only one part of the brief upon which the views of the community will be sought (and by the developers, not the National Park), and that is the bit about the children’s play area. As we all know, the children’s play area is currently in a relatively safe location, set in a cul de sac with very limited access; turning this area into the main thoroughfare between the two estates will make it much less safe for children to play in.
4. The details
This is what we think the Development Brief means:
  • The highest density of housing, including a shop, apartments over the shop and two-storey, terraced housing, will back onto Brookview South, stretching from the A29 down to the Children’s Playground;
  • Lower-density detached and semi-detached two-storey houses will be built around the south and west side of the site with fine views across the valley;
  • Roofs will be high pitched and will almost certainly block views from existing houses. This will be particularly noticeable because the land at the top corner of the field, next to Brookview South, is 3-4 metres higher than the existing houses;
  • There will be a new pedestrian and cycle route running from the A29 and the new estate through the children’s play area to the Brookview estate;
  • The shop will have a delivery yard and refuse storage behind it, close to existing houses
  •  There is also likely to be an electricity sub-station (if so, it will hum 24 hours per day; we know this because we have one at the bottom of our garden).
5. Contradictions
The Development Brief is confusing because it is contradictory:
  •  Two parking areas are referred to (one for the shop and one for the “Public Open Space”), but unlike previous documents, no location for the Open Space car park is given;
  • The brief contradicts itself when it states that the primary purpose of the “Public Open Space” will be providing an alternative to the adjacent nature reserves (presumably to reduce disturbance to wildlife) and then goes on to stress: “Trails are to be provided through the site to link with existing trails on the flood plan”. This will actually increase access and levels of disturbance;
  • The north western end of the meadow is earmarked for landscaping, but no details about this are given. There are references to tree planting elsewhere in the brief; this would seem the most likely form of landscaping, but it should be noted that tree planting in the area in question, apart from destroying the meadow, will only provide a limited screen to the west and southwest, where the landscape intrusion is not much of an issue. It would not provide screening to the south and southeast, where the need for landscape screening would be greatest if the development proceeds;
  • The brief then refers to a Meadow Management Plan for what’s left of the area (less than half) once the houses have been built. It also states that an accessible, landscaped open space will be provided, which will feature: “public art and structures, including signing, wooden sculptures, birds, bee and bat habitats/boxes and ‘children learning through play’ equipment to interpret the rich biodiversity of the site.”  This is impossible, because they are talking about the same area.
  •  It seems that the “Public Open Space” is intended as a dog exercise area, to reduce the impact of uncontrolled dogs upon the wildlife sites nearby. However, there is no evidence that dog walkers will prefer to walk around the field behind the new housing estates when there will be direct and easy access to the much more interesting and scenic walks through the open space and onto the adjacent nature reserve. If the meadow does become a popular exercise area, then farmland birds and small mammals will retreat from the disturbance, wild flowers will be affected by the trampling and the nutrient enrichment caused by uncollected dog mess (this acts as a fertiliser for the grass, and the abundant growth then smothers the flowers). A meadow management plan would therefore not be compatible with the public open place, for most of the meadow wildlife would be lost;
  •  The brief is full of impossible assertions about how the development must make the site better for wildlife, when in fact development will be destroying it. An illustration of this is provided by phrases such as: “The Coldwaltham development is progressive in its environmental understanding through the use of ecosystem services; it …supports biodiversity and the natural environment.” and  “local species should be understood from the outset and supported by maintaining key habitats and landscape features in the site by improving their condition and connectivity for wildlife” and “areas of former farmland should be managed and enhanced and where appropriate to maximise biodiversity potential and encourage wildlife corridors”; 
  • Reference is made to the “historic field boundaries” that border the meadow and that “existing mature trees and hedgerows to be retained and enhanced”, yet “A new vehicular access off the A29 should be provided with appropriate visibility splays” and “Any shop unit should be located close to and with good visibility from the A29…” This means that most of the hedgerow along the A29 will have to be removed. Hedgerows are foraging and commuting routes for bats and they will avoid artificial lighting; they also forage over the insect-rich meadow, particularly when the wild flowers are in bloom. The erection of bat boxes will not compensate for their habitat loss, particularly as some of the rarer species that occur in the area will not use them;
  • The Brief requires the development to “provide a significant and characteristic buffer” to the wildlife sites; yet the meadow already serves this purpose. Destroying half of it will drastically narrow and reduce the buffering effect, to the point where it will be ineffective;
  •  The Development Brief is supposed to be landscape-led, yet siting two storey houses with high-pitched roofs at the highest point of the site will ensure that they will be seen for miles from across the valley, despite: “the introduction of new trees to minimise the impact of the development in long distance views”. There are no native species of tree (and reference is made to planting “new, native and locally indigenous trees”) that will grow tall enough to do this, even after many decades of growth;
  • The brief refers to cultural heritage, yet omits any reference to the site being a flower-rich hay meadow, The Local plan does not recognise any historic land use in the National Park as cultural heritage, only ancient buildings and this is clearly wrong;
  •  All the Perceptual Qualities described in the brief will be adversely affected by the development: ”Tranquility”; “Dark Night Skies”; “A real sense of nature”;
  •  It is deeply ironic that having infilled the largest of the two fields between Coldwaltham and Watersfield, the development must “create a full stop to the settlement of Coldwaltham”; the new development is already outside the existing settlement boundary for the village. Only a 150 metre wide field will be left between the two villages and how long will it be before they merge? Perhaps this will feature in the next Local Plan.
The claim that the National Park Authority has produced this development brief “to give increased certainty to the local community” may be true, if by that they mean we will be certain the National Park does not care about the damage that will be done and will make up any nonsense to justify their plans. An extremely scarce, eight-hectare flower-rich hay meadow (the only one in the Arun Valley) will be destroyed to provide two hectares of housing. The National Park may have been in ignorance about the meadow’s status as a biodiverse cultural heritage asset, but they no longer have this excuse. There never has been any excuse for allocating so many houses on such a large plot (the largest area out of all the residential allocations in the Local Plan) immediately adjacent to the most important and sensitive site for wildlife in the National Park.
If, like us, you are outraged by the plans to develop Coldwaltham Meadow, and want to know what the Parish Council thinks about all this, come to their meeting at Lodge Hill on Tuesday 14th November at 7:30. 
And most important of all: please remember to send your comments on the Local Plan to the South Downs National Park before 21 November.
Link to the brief:

Comments on the Coldwaltham Parish Council Report for The Link Parish Magazine, October 2017

The attached PC report of the Sandham Hall meeting on 19th October for the Parish Magazine makes interesting reading, not least because it appears to give the views of the PC, who said that they would not be discussing and agreeing their views until the next PC meeting on 14 November. However, we have been urging them to act sooner and so they have!  Our group, our map and our comparative table are not mentioned by name but we are pleased that the PC urges everyone to use this information in their submissions to the National Park.
Comparative table correction.  One new revelation at the meeting requires a factual correction to our comparative table: Criteria No 15  “Cultural value of site?”  The suitability score for sites 2 & 3 should be decreased to low in view of their historic “fieldscape assart” status.  The final scores for site 3 & 4 are now 12 & 9 respectively. This makes very little difference to the overall score and it is worth noting that the National Park indicates in their “Settlement Context Study Sensitivity Analysis” map that they do not regard fieldscape assarts to be of cultural sensitivity and so they are unlikely to be seen as a constraint.
The PC statement that all four sites “have, to differing degrees more negatives than positive about them” is a good way to bring us all together but it ducks out of the important point that one site is far less suitable than the others. A small number of articulate neighbours of the new sites made passionate objections, including a number of unsubstantiated claims, about the wildlife and historic value of their local sites. We are all very fortunate that our village is surrounded by wonderful wildlife and anyone who lives next to a green field is unlikely to welcome houses instead.  The point that the PC have failed to acknowledge so far is that only site 1 has a very high wildlife value. We have considerable evidence that not only confirms this but also shows that the other 3 sites have low value by comparison.  There were also a number of exaggerated claims about the close proximity of the Stane Street Roman Road to sites 2 & 3 and to a lesser extent site 4.
It was the owners of site 3 & 4 who first suggested that a better approach would be a number of smaller sites integrated into the village instead of yet another separate Estate.  We recommended this approach to the PC and we are glad to see that they appear to be taking it up. It remains to be seen how potential future neighbours of even small groups of houses will respond to the prospect of new houses next door. It is also far from certain that the National Park will be willing to give up their easy, quick and dirty solution to new housing rather than work with our PC to develop a carefully integrated long term plan.The reason why the SDNPA is seeking to dump so many houses on Coldwaltham is simply because unlike the other two villages in the HDC area we are the only one where the PC did not produce a Neighbourhood Development Plan.
Guy Nelson said at the meeting that if anyone wants a Neighbourhood Development Plan (NDP) then they should join the PC and do it. This begs the question why our PC is not willing to do it. It really will be essential to have a NDP  before the next housing allocation comes along in a few years’ time.  In the meantime, we have been advised by our Planning Consultant that it is not too late to have a Neighbourhood Development Order.  This could protect our Meadow and advocate alternative sites, but this can only be done by our PC. We must therefore urge them to take steps to protect our village, both now and in the future.