MATTER 3 SUBMISSION BY THE CAMPAIGN TO SAVE TOAD'S HOLE VALLEY CONSISTENCY WITH NATIONAL POLICY - HAZEL I. MCKAY 12 MAY 2015 REP/29 CAMPAIGN TO ...

Submission by the Campaign to Save Toad’s Hole Valley

                                  MATTER 3

                    Consistency with National Policy

Hazel I. McKay 12 May 2015

REP/29 Campaign to Save Toad’s Hole Valley – Matter 3        1

1. Matter 3 (b) - concerning Policy CP8 and proposed
   modifications PM085-PM087 and PM107.
   1.1. The proposed modification PM085 to policy CP8 concerns the
        sustainability standards that would apply to new buildings and
        residential conversions.

   1.2. The general thrust of policy CP8 is to require standards in excess of
        the Buildings Regulations. The proposed modification PM045, to
        which the Campaign objected, would require developments in Toads
        Hole Valley to comply with policy CP8, instead of the higher standards
        required by policy DA7 in the original version of the city plan submitted
        in spring 2013.

   1.3. The Campaign has always argued that it was unrealistic for the city
        council to require the environmental performance of buildings
        proposed for Toads Hole Valley to be exemplary. But the Campaign
        also objected to that requirement being diluted, because the public
        was assured any development of Toads Hole Valley would be an
        exemplar of sustainability and for that reason a number of amenity
        societies did not object to the valley being developed.

   1.4. PM045 lowered the required standards from Code for Sustainable
        Homes (COSH) level 6, BREEAM Outstanding and zero carbon,
        (specified in policy DA7), to COSH level 5 and BREEAM Excellent
        (prior to 2019) specified in policy CP8. The WMS by the Secretary of
        State has withdrawn the Code for Sustainable Homes and
        precludes local authorities from including local plans policies
        specifying any environmental standards in excess of the Building
        Regulations or an energy performance superior to the Building
        Regulations. [The latter provision will apply after the commencement
        of the Planning and Energy Act 2008, which it is anticipated will be late
        2016. It is expected that by late 2016 the Building Regulations will
        require environmental standards equivalent to COSH level 4 and that
        there will be a Government policy for zero carbon homes.]

   1.5. In the circumstances, it would appear that policy CP8 must be
        modified to delete all references to the Code for Sustainable Homes,
        and any requirements for the energy performance of residential
        buildings to be superior to the Building Regulations after 2016. As a
        consequence of PM045, this modification to policy CP8 would apply to
        Toads Hole Valley.

   1.6. Given that the case for developing Toads Hole Valley was predicated
        on it being an exemplar of sustainability, the Campaign believes the
        council’s justification for releasing the site for development is further
        undermined by this change in Government policy.

REP/29 Campaign to Save Toad’s Hole Valley – Matter 3                               2

2. Matter 3 (b) concerning paragraph 4.126 of the draft City
   Plan
   2.1. Paragraph 4.126 states: ‘Car parking standards will be based on
        maximum standards, and cycle and disabled driver parking will be
        minimum standards.’

   2.2. This statement in the draft city plan is at odds with the WMS, which
        states that the Government has ‘changed planning policy to
        actively encourage the provision of more parking spaces, to help
        local shops suffering from aggressive parking enforcement, and
        remove planning restrictions which discourage the sharing of under-
        used parking spaces.’

   2.3. The Campaign argued at the public inquiry that the proposed
        maximum parking standards would create problems in and around
        Toads Hole Valley, with inadequate levels of parking giving rise to a
        sense of deprivation, stress between residents, and overspill parking
        in adjacent areas.

   2.4. In response to the council’s recent consultation on draft
        supplementary planning guidance, which proposed parking standards
        in accordance with para 4.126, the Campaign supported the proposed
        tiered approach to parking standards but objected to the maximum
        standards proposed for the outer areas, including Toads Hole Valley.
        The Campaign’s detailed comments are annexed below.

   2.5. In place of the council’s proposal for 1 space per dwelling plus 0.5 per
        dwelling for visitors, the Campaign recommended 2 spaces per
        dwelling plus 0.5 for visitors.

   2.6. Whilst the Campaign has no desire to generate unnecessary journeys
        by car within the City, it believes that insufficient parking provision in
        suburban areas causes unnecessary problems and conflicts.

   2.7. Thus, in order to comply with Government policy, it is recommended
        that policy CP9 sustainable transport, and its supporting text, be
        modified to delete any provision for the specification of maximum car
        parking standards in the outer/ suburban areas.

   2.8. Furthermore, the Campaign considers that the provision for maximum
        car parking standards should be strictly limited to the central area of
        the city and those movement corridors that have very frequent public
        transport services, such as Lewes Road and London Road. In those
        very limited areas demand management can still be justified under the
        latest Government policy.

REP/29 Campaign to Save Toad’s Hole Valley – Matter 3                            3

3. Annex to representation: Comments recently submitted to the
   council by the Campaign in respect of the council’s draft parking
   standards SPD 13

These comments focus upon how the proposed standards would impact on
the development of Toads Hole Valley.

We support the zonal approach to parking standards, with minimal parking
standards in the central area, but believe the proposed detailed application of
the approach would not be successful for the following reasons:

1. The zones are not based on a consistent standard of public transport
   service. Some of the key public transport corridors have excellent public
   transport services, whilst others have sparse services, giving rise to quite
   different demands for transportation by private modes.

   It is correct that London Road, Lewes Road and Western Road/ Church
   Road, highlighted in page 5, are public transport corridors with good bus
   services.

   In contrast, the bus services along Dyke Road Avenue (particularly at its
   northern end) and Old Shoreham Road (for most of its length) are very
   poor, but these corridors are inappropriately shown as key public transport
   corridors in the zonal map.

   On page 6 in respect of the railways, Aldrington is reported as comparable
   to London Road, but Aldrington only has a half-hourly service, whilst
   London Road has 4 trains per hour.

2. For the residents of the outer area, private transport is a necessity, not a
   luxury. As a consequence, the typical family home needs parking for at
   least two vehicles, plus parking for visitors.

   In the outer area, the mix of vehicles requiring parking spaces will include
   residents’ commercial vans, caravans, trailers, and motorbikes (of all
   sizes), as well as private cars.

   Visitors’ spaces will be utilised by tradesmen (some of whom use their
   vans as mobile workshops), delivery vehicles (which are increasing in
   number as Internet shopping grows), and the clients of home-based
   businesses, as well as friends and family.

   If sufficient parking spaces are not provided, it will cause stress between
   residents, and overspill into neighbouring areas.

3. In Toads Hole Valley, 1 space per dwelling plus 0.5 visitor space per
   dwelling would not be sufficient to satisfy the demand. We recommend 2
   spaces per dwelling, plus 0.5 per dwelling for visitors.

REP/29 Campaign to Save Toad’s Hole Valley – Matter 3                        4

Under-provision would inevitably lead to overspill parking in the Goldstone
   Valley, to the detriment of its existing residents. This could be controlled
   by a residents’ parking scheme but the associated yellow lines and street
   furniture would erode the quality of its suburban streets.

   In any event, such controls would leave the residents of Toads Hole Valley
   short of parking spaces, thereby causing a sense of deprivation and
   heightened stress between residents.

4. There is a theory that minimising parking provision in an area will, of itself,
   lead to the provision of good bus services in that area. There is, however,
   no evidence to support that theory.

   Furthermore, we have no confidence that any bus services introduced into
   Toads Hole Valley would be of a standard that would obviate the need for
   most adults to own or use a private vehicle.

   We say this because:

       (a) the service to the adjacent Goldstone Valley is a poor service, with
       evening and weekend services dependent on subsidy.
       (b) there are only two access points to Toads Hole Valley: at the
       bottom opposite Goldstone Crescent and at the top by way of the Dyke
       Road roundabout
       (c) the gradient of the valley is steep and inhospitable for public
       transport

5. The problems caused by under-provision may not be so acute, if taxis
   were more readily available at more competitive prices.

In summary, we consider that the parking standards proposed for the outer
area would lead to an under-provision of parking space in Toads Hole Valley,
giving rise to stress for residents and overspill parking in the Goldstone
Valley.

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REP/29 Campaign to Save Toad’s Hole Valley – Matter 3                           5