Letter to Mr Nelson from the SDNPA

Letter from SDNPA with comments in Red by Coldwaltham Meadow Conservation Group

Dear Mr Nelson,

We have received a number of e-mails about the proposed housing allocation at Coldwaltham.
First, may we say that there appears to be some confusion over the stage the Local Plan has reached and the extent to which members of the public and the parish council can make comments. This is entirely understandable given the complexity of the process. We hope the following will help.
 As you appreciate, the Local Plan has been through a number of iterations and at each stage we consult with the public.  Our main objection is that this is simply not true.
We have gone beyond the statutory requirement by, for example, consulting on an ‘Options’ document at the outset. It is normal practice to test the plan at each stage against the responses to earlier consultations as well as research and evidence. The Plan therefore, rightfully, changes with time.
Based on all of this, our approach is for a ‘medium’ level of growth dispersed across towns and villages.  Nonetheless, SDNPA call the  it a “Major Development” – 40 houses is 4.4% of the total for the whole NP and an 11% increase in our population. So far as Coldwaltham is concerned, some growth is considered desirable and appropriate over the next 20 years.  The site previously identified at the Preferred Options stage for development has since been demonstrated to have a negative impact on nearby nationally designated sites. As a consequence, a different site, adjacent to and seen as part of a larger area within which the previously proposed site was located, is now under consideration. It is a new site, but in the same meadow, just 100m to the west with twice as many houses and four times the area
The process of preparing the pre-submission draft of the Local Plan has been underway for some time. The meeting referred to in some e-mails formed part of that process and was an informal opportunity for parish councils to see how our thinking was developing, subject to further research and evidence as well as their responses.  Our Parish Council considered they were presented with a “fait accompli”.
Subsequently all the draft policies and allocations have been considered by our Planning Committee in public and with the papers available on our website. The latest version of their plans for our meadow, different from all the others, appeared on 4 July!  The Committee also listened to representations about the Plan, both positive and negative. The Planning committee refused to look at our Parish Council’s letter of Objection at their meeting on 15 June.  We have now reached the point at which the pre-submission draft will be considered by the SDNPA Members at our meeting on 11 July. At that meeting we will be asked to approve the draft plan for formal public consultation. That consultation is planned to start in September and will run for eight weeks rather than the six weeks required by legislation. It is at that stage that the parish council and members of the public can respond to the policies and the proposed allocations. The responses will not only be considered by the SDNPA but will also be available to the Planning Inspector who will hold a public hearing on the Local Plan next year.
May we say that the SDNPA places great store on community engagement, which is why we encourage Neighbourhood Plans and have exceeded the statutory requirements on consultation. They have not followed the guidelines set out in their Statement of Community Involvement
Finally, we are aware that there are concerns regarding the possible involvement of one of our Members in decision making of this site who has a financial interest in it. As Members, we take our role very seriously as impartial decision makers. We have strong and rigorous governance arrangements that have been followed in this case. The Member concerned has been scrupulous in absenting himself from decision making on the Local Plan. We do not say that the landowner/member concerned has done anything wrong. We are simply asking why, as “impartial decision makers” the Planning Committee has proposed:   
  1. The largest allocation of land for the largest number of houses on one plot in the whole Local Plan (which includes 37 other sites);
  2.  On such an exceptionally important meadow in the wider landscape with high nature conservation interest, and with adjacent internationally important wildlife sites and 
  3. Why did they go to such apparent lengths to avoid consultation?
 We hope this e-mail clarifies the situation and that you can be assured that there will be the opportunity to comment on the pre-submission version of the Local Plan in the autumn. We should be very grateful if you could help in disseminating this information to the residents of your parish who are concerned about this issue. 

Margaret Paren – Chair of the Authority

Neville Harrison – Chair of Planning Committee


South Downs National Park Authority

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