To: Adur Council planning dpt 8 th November 2013 Dear Sir, RESPONSE TO REVISED DRAFT, ADUR LOCAL DEVELOPMENT PLAN 2013 The Shoreham Society welcomes being consulted on the Revised Draft Adur Local Plan. Following publishing of the National Planning Policy Framework (NPPF) in March 2011, which replaced previous planning policy documents, the role of Local Plans has become more important as they provide the framework for future development within the District. The Shoreham Society Is an independent, non-political civic society providing a voice for the residents of the town on matters concerning town planning, conservation, development and its environs. It works for the conservation of Shoreham s historic architecture and the enhancement of the town s environment by encouraging an enlightened approach to planning. Our previous comments on the Local Plan made last year are still relevant but we would like to be quite clear what the Adur Local plan is for. We feel it is to enhance the quality of life for Adur residents. At the very least, it should halt any deterioration in this quality of life, which might occur with inappropriate development or poor advance planning. We know that developers are inclined to come in and make money from the area that is their core business but if allowed, this could be with little regard to the character of the town. We know that traffic will increase with development although the growing use of electric vehicles may contain pollution to existing levels. However we note that parts of the plan are bland, toothless and fairly vague. There is a great deal of aspirational padding which sounds nice and which hardly anyone could disagree with, yet sometimes no substantial proposals follow. So how well does the plan serve Shoreham? Detailed comments on the document are set out as below: Eleven key needs are listed for the plan to address, three in particular being of interest to the Shoreham Society. These are:
Key Issue 3 Balance: Allow development whilst retaining environmental quality Key Issue 7 Reduce road congestion and pollution Key Issue 11 Preserve or enhance the quality of the environment (built, historic and natural) We have identified the main policies that pertain to these issues and have made comments against those that we think need strengthening or where Society members have made suggestions. Policy 7 Shoreham Airport We agree that the Airport plays a key part in the commercial, cultural and historic character of Shoreham. We note with concern the increasing deterioration of the Grade 2* listed terminal building (identified as a heritage asset ). The terminal building should not be lost through neglect or used as a pawn in some kind of planning game by the current airport operators. The local authority through its Enforcement Officer must exert its powers to ensure this does not happen. We support employment-generating floor space in the north east corner of the airport but we consider that improvement to the A27 Sussex Pad junction (in Appendix RD10) does not go far enough. Members are puzzled by the package of site specific travel behaviour initiatives. What are they? It has been suggested that an improved road from the Sussex Pad to the Saltings roundabout, going under the Railway Bridge alongside the river, provides o Good access for trading o o Allows for a through public bus service Reduces traffic on the Upper Shoreham Road A283 and the High Street (Ropetackle) roundabout. Policy 11 Shoreham-by-Sea It is vital that the town s heritage assets are protected whilst ensuring they are not undermined by new development. In general we support this policy but members feel that the plan should be more robust to enable it to resist planning appeals. Members have made suggestions listed below. To avoid developments having an adverse impact on St Mary de Haura Church it may be advisable to specify a maximum height for buildings within a specified distance of the tower. Pond Road Car Park We have concerns that the amount of public spaces in this convenient town centre car park will be significantly reduced due to spaces required by the new Civic (and possibly future Police) presence in the Community Centre. Members have suggested therefore that the Civic Centre Staff car park be not sold off for the time being and used as a public car park. There is even more reason to do this if the Police Station is redeveloped as retail. It will still be an asset that could be sold off in the future.
Any car parking strategy should attract shoppers to the town centre shops with an appealing package, for instance 2 hours free parking onstreet (possibly by parking disk) plus at the retained Civic Centre Staff Car Park. Cars should not be seen as cash cows, generating money for the Council through charges & fines as happened in Worthing. Neighbouring towns (e.g. Steyning) currently have better specialist shops with generous free and disc parking, thereby attracting shoppers away from Shoreham town. We are told that shoppers will be encouraged to park at the Frosts/Minelco site (Morrisons) and walk into the town centre. To facilitate this members have suggested that some of Section 106 monies be used to build a contemporary footbridge over the A259. This will Create a safer and more stylish pedestrian route to the town centre & station Reduce air pollution because traffic will not have to keep stopping at pedestrian lights Create an attractive addition to the streetscape: Welcome to Shoreham and a potential site for events banners. Shoreham is an attractive town for pedestrians but there are some weak spots that need addressing. Paramount among these is un-necessary waits at Buckingham Road level crossing when there is an existing Subway. New and improved foot and cycle routes mentioned should therefore include, in conjunction with Network Rail, re-opening the pedestrian subway under the crossing; this would also improve safety and station access. The NPPF paragraph 75 states that Planning policies should protect and enhance public rights of way and access. Local authorities should seek opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails. Dolphin Road Industrial Estate. Members have suggested making Dolphin Road a through route to Kingston Lane. This improves access for vehicles and could well reduce congestion at the Eastern Avenue level crossing (although a left-turning lane might be required here). Importantly however it takes traffic off part of the over-congested A259. Policy 14 Quality of the Built Environment and Public Realm We support this policy. It appears to be general good practice for any town. Policy 18 Sustainable design We encourage the council s policy on this. We also feel that, due to the high demand for houses in our area we should be able to insist on high standards of sustainable design and ADC should encourage developers to a higher level where possible. Build costs may be higher but they would be cheaper to live in. Policy 20 Housing Mix and Quality We support this policy as it seems appropriate for the desirable make-up of the town and area. Policy 22 Density We support this policy. The densities proposed seem to be sufficient but with the requirement to supply some green space (Policy 32) as well we wonder if
there will be pressure to go upwards and a thus a maximum height limit may be required in some areas to prevent adverse impact on the character of the town. Areas such as Shoreham Beach which are outside the conservation area may require special mention in the Local Plan with regard to a lower density (bungalows) to retain character. Policy 26 The Visitor Economy We support the need for a hotel in Shoreham. Published plans for the North Ropetackle development seem to include a hotel and we hope it happens. Members have also suggested that the Civic Centre would make a very attractive gateway hotel site. The highest bidder, however, may simply want to build flats and we are unsure as to how ADC could encourage a hotel here. To add to the visitor economy the hotel should be able to cope with small conferences and conventions. Flats with a hotel below can be combined successfully and could be encouraged if a hotel alone was unviable (eg on Civic Centre site) Evening car parking is a factor for the visitor economy. We note that some towns charge 24-hours for car parks. This should be resisted to assist our arts venues, restaurants and festival events. The Civic Centre ex-staff Car Park, if competitively priced, could be a valuable visitor asset. Policy 27 Retail, Town Centres and Local Parades We support this policy in particular paragraph 4.71 decreasing the threshold limit for a retail impact statement. The protection of town centre and local parades and car parking to encourage the visitor economy will help the town centre to look and feel vibrant and resist stiff competition from edge-of-town stores such as Morrisons, Lidl and whatever the Parcelforce site produces. Pedestrian routeways such as re-opening the level crossing subway and a footbridge to riverside and Morrisons across the A259 would make the town a more attractive place to shop. Policy 28 Transport & Connectivity including Transport Assessment Report (Appendix RD 10) We have already commented on measures to address on- and off-street parking. While we recognise that Policy 28 addresses the outlined transport and connectivity issues, quite frankly we fail to see how some of it will be achieved. The draft Plan puts the onus on new development to improve public transport, mitigate air pollution and minimise the need for travel. Surely new development will increase the need to travel, increase air pollution and public transport is already quite good although, in spite of that, many prefer their cars. Without a more proactive approach in the Plan (and we suggest a few) we believe things will just get worse and the Plan will have done a great disservice to Shoreham. For example, to alleviate traffic congestion on the A259 members have suggested a parallel route along Dolphin Road. Also a footbridge would be preferable to stop-start pelican crossings to Morrisons; this would be an
exciting new pedestrian route linking town/station and harbourside developments (i.e. key sites ). The Transport Assessment: Appendix RD 10 The Parsons Brinckerhoff study assesses thirteen junctions of which three are of particular interest to Shoreham, so we have commented on their proposals. Others outside our area may, of course, be important in bringing in and clearing traffic from Shoreham. A27 Sussex Pad (and Ricardos) The highway mitigation proposal is to allow ahead vehicles to use the nearside lane of the A27 in both directions; cost 11,000. But then it will have to merge again to the existing highway so what will be achieved? We suggest the roundabout on Map 7 Option 1 is superior and this can serve the New Monks Farm Estate. It then supports an enhanced road south to the Saltings Roundabout, serving the new industrial development plus new public transport links to the Airport. A27/A283 Steyning Road junction (Flyover roundabout) The highway mitigation proposal is basically traffic lights; cost 2.6m. Unless part-time signals are employed this will be completely unnecessary most of the time and a source of annoyance (expensive, and cause massive traffic delays during installation?) We think that the Airport road suggested above will relieve this roundabout and be a better use of the money. A283/A259 Shoreham High Street Junction (Ropetackle roundabout) The highway mitigation proposal is to expand the roundabout somehow and widen the approach by the Tanning Shop; cost 15,534. We really doubt that this will achieve much, although it s cheap. The required significant reduction in anticipated traffic demand will make a difference and is effectively achieved by the aforementioned road through the Airport. Policy 32 -Infrastructure delivery plan We would like to see this and to be able to comment on it as soon as it is available as we think it is integral to the Local Plan. It is somewhat disappointing to see it kept separate or lagging behind the Local Plan, as surely they are interrelated. Checklist of Main Suggestions made by Shoreham Society Members: Civic Centre ex-staff car park retained Dolphin Road becomes through road New Airport road: Sussex Pad to Saltings Subway opened under level crossing Foot & cycle bridge over A259
On a more general note a significant amount of Society members expressed concern over infrastructure: local health provision for an increasingly ageing population and schools air quality and traffic maintaining the community and character of Shoreham centre Thank you for considering Shoreham Society s comments. Committee Members look forward to being updated on progress on this matter and would welcome being consulted in the future on any similar matters. Although we realise that some of our suggestions may not be possible to implement we would appreciate being told the specific reasons why and the preferred ADC alternative. Yours sincerely, Gerard Rosenberg, Chairman On behalf of the Shoreham Society Committee Copy for information to: All Shoreham Society Committee