Planning application LW/13/0620, Land at Gradwell End
Comments by John Kay on behalf of the Lewes District branch of CPRE Sussex
Overview
The Lewes District branch of CPRE Sussex supports the provision of suitable accommodation to meet the
needs of the elderly, including those with care needs, and recognises that the demographics of the Lewes
District project an increase in this need.
However, it is vital that the needs of this vulnerable group of residents (and in particular those of the
partners of those suffering from dementia and allied conditions) are met at appropriate locations.
The answer to the question “Are those needs appropriately met by creating a large new facility at an
isolated greenfield location on the edge of a ‘local village’ with very few facilities?” must be a resounding
“No!”
There are additional negative impacts on (1) the amenity of local residents living at Gradwell End or using
Mill Road and (2) biodiversity.
The views of the Planning Application Committee considering the previous iteration of this proposal still
apply, despite the changes that have been made. We thus recommend strongly that this application
should be refused.
Location
The site concerned was formerly part of the Chailey Poor Law Union workhouse constructed in 1873. Such
workhouses were deliberately constructed at isolated locations, so that the resident paupers would be
isolated from society. This is no longer the policy for housing the elderly suffering from dementia or allied
conditions and their partners. The Union workhouse later became Pouchlands Hospital, used by the NHS to
accommodate the elderly in need of residential care, but this was closed down because of its inappropriate
location. It was not an appropriate location when the hospital was closed, and it is still an inappropriate
location today.
This point is emphasised by the locations for alternative facilities for the elderly identified in the Planning
Brief accompanying the application. They are all in or near towns (Burgess Hill, Uckfield; additional facilities
in Haywards Heath, Lewes), or within larger villages with facilities such as Ringmer (categorised in the 2012
Lewes District Rural Settlement Study as a ‘Rural Service Centre’). South Chailey is categorised in this study
as a ‘Local Village’. In Fig.36.3 of the Design & Access statement accompanying this application a future
resident is pictured setting off on a trip on his mobility scooter. One wonders where he is heading. South
Chailey has no shop, no railway station, no village hall, no parish church and no pub within mobility scooter
range unless he is prepared to drive it amongst the traffic speeding along the A275. All these facilities
would be accessible in any of the towns, and all except the railway in the ‘Rural Service Centres’ of Ringmer
and Newick. Taxis to and from this isolated location would be prohibitively expensive for most older
people. Unless residents or their partners were able to drive, and had access to a private car, they would be
trapped within the development, confined to the facility’s ‘Club House’ or the destinations of the single
minibus proposed.
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This isolated location will also mean that few if any staff will be recruited from communities within walking
or safe cycling distance of the site. The poor local bus service means that most will have to commute to
work by private transport. This is not ‘sustainable’, and given that the wages commonly paid to the basic
grades of care staff do not cover private car ownership, means that recruitment is likely to be a challenge.
The proposed location for this facility is thus contrary to:
 NPPF paragraph 34. Plans and decisions should ensure developments that generate significant
movement are located where the need to travel will be minimised and the use of sustainable transport
modes can be maximised.
 NPPF paragraph 95. To support the move to a low carbon future, local planning authorities should
(inter alia) plan for new development in locations and ways which reduce greenhouse gas emissions.
These paragraphs underpin the core planning principle in NPPF paragraph 17 that development should
support the transition to a low carbon future.
The applicants argue that there are no other suitable sites. They base this conclusion on an Alternative Sites
Assessment, that is flawed because of its reliance on outdated planning considerations (sites allocated for
development in the 2003 Lewes Local Plan). The Alternative Sites Assessment should also have taken into
consideration alternative sites proposed to the 2010, 2011 & 2012 Lewes District & Wealden District
SHLAAs, in and around the local towns or ‘rural service centres’ and considered ‘deliverable’ or
‘developable’. While some such sites will be allocated for residential development (and thus the present
proposal priced out), many others will not, and it is improbable that all of these would prove unsuitable for
a development like that proposed here. In particular it should be noted that a very large “Strategic Site” for
both commercial and residential development has been added adjacent to the A22 Uckfield by-pass. As
Uckfield is the, or a, local town for many of the rural villages considered, this would be a far superior
location. There are also possible alternative sites on the edges of Lewes, Burgess Hill and Haywards Heath,
around Ringmer and Newick, and in North Chailey but very close to Newick. Not to have considered these
alternative sites is a fatal weakness to the overall argument in the Planning Brief.
The Lewes District Branch of CPRE Sussex thus considers that the following arguments used to refuse the
previous application apply with equal strength to this present application:
i) The site lies outside of the defined Planning Boundary for Chailey as set out in the Lewes District Local
Plan, and falls wholly within an undeveloped, greenfield, countryside location. The proposal will result in a
very large new development in the countryside, in an unsustainable location and not in conformity with any
of the planning policy exceptions for new development in the countryside. The isolated location is
considered inappropriate for the uses proposed and the need for a development of this type and scale is not
sufficient to override the strong presumption against major development in a rural location such as this
which is poorly served by local amenities and facilities. The proposal would result in a considerable
intensification of built form, unacceptably spreading development well beyond the planning boundary, and
in view of the size, scale, floor area, height, layout and indicative design would detract from the rural
character and appearance, and the intrinsic landscape value of the area. The proposal is therefore contrary
to Policies ST3 and CT1 of the Lewes District Local Plan and guidance contained within the National Planning
Policy Framework.
ii) The proposed development would not constitute sustainable development as advocated by the National
Planning Policy Framework due to its isolated location in relation to local infrastructure (including: regular
public transport facilities and access to local shops and services) and reliance on private motor vehicle. The
site's isolated location at the edge of Chailey in an area poorly served by public transport, combined with
the lack of facilities in the village, would result in staff, residents, deliveries and visitors, being heavily reliant
on private motor vehicle use to access the site. The proposal would therefore fail to meet the aims of
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promoting sustainable transport or assisting with the reduction of greenhouse gases, contrary to Policies
ST3, T1 and T2 of the Lewes District Local Plan and Section 4 of the National Planning Policy Framework.
Impact on the amenity of residents in Gradwell End or using Mill Road
The proposed access to this large institution is via the small residential cul-de-sac of Gradwell End, which
comprises affordable housing, mainly for families. The amenity of these residents, and the safety of their
children, will be substantially affected by this new access. Users of the narrow Mill Road, to which the
access leads, will also be adversely affected.
The Lewes District Branch of CPRE Sussex, while recognising that the scale of nearby parts of the
development has been changed, reducing some visual impacts, still considers that this access issue justifies
the following reason used to refuse the previous application, and which applies with equal strength to this
present application:
iii) The proposed development, having regard to its size, scale, location, intensity, internal road layout and
parking, the resultant change in the character of the local area and the routing of access through Gradwell
End, would result in a serious detrimental impact on the residential amenities of properties in Gradwell End
[and The Martlets], through increased noise and disturbance from traffic, intensification in use of land and
proximity of the development to existing residential properties, contrary to Policy ST3 of the Lewes District
Local Plan and Core Principles of the National Planning Policy Framework.
Impact on Biodiversity
The application proposes to provide new ‘receptor’ land for protected wildlife displaced from the
development site. However, while the area to be developed has for many years been unused scrubland
adjoining ancient woodland, the receptor area is managed pasture. If the great crested newts and dormice
to be displaced from the development site thought this was an acceptable alternative location, they would
already be there! There is no evident commitment to make the ‘receptor’ land attractive to its putative
new residents (is it known how to do this?) or maintain it in this way in the medium or long term.
NPPF paragraph 109 requires that the planning system should contribute to and enhance the natural and
local environment by (inter alia) minimising impacts on biodiversity and providing net gains in biodiversity
where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity,
including by establishing coherent ecological networks that are more resilient to current and future
pressures. This supports the core planning principle in NPPF paragraph 17 that development should
contribute to conserving and enhancing the natural environment. The present proposal fails this test.
John Kay
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