Master Horstedpond Farm Action Group Objection
Submitted to Wealden District Council by Horstedpond Farm Action Group (HFAG)
7 October 2022
Horstedpond Farm Action Group (HFAG) is a newly established community group (https://horstedpondfarm.org) with its core of the four residences that would be surrounded by the 400 properties that Castlefort Homes proposes to build as part of the eight-field, 27.2-hectare Horstedpond Farm development project (WD/2022/2216/MAO). The four HFAG founder members are supported by like-minded residents of Uckfield and the surrounding parishes as well as others. HFAG strongly objects to the Castlefort Homes proposal on the following grounds:
- Horstedpond Farm heritage
Horstedpond Farm is located at the southern edge of Uckfield, 2.1 km from the town centre, and is adjacent to the Little Horsted roundabout where the A22 and A26 intersect. One-half of the southern boundary of the proposed housing development site is adjacent to Horstedpond Wood, an area of ancient, semi-natural woodland once known as the Great Wood. The northern boundary of the development follows the course of Ridgewood Stream, an east-to-west flowing tributary of the River Uck. Horstedpond Farm was once the manorial seat of the village of Little Horsted and earthwork anomalies in the area of Field 5 of the proposed development site indicate that they could be the remains of the early manor house.
The enclave that HFAG represents comprises four residences, i.e. Horstedpond House, a Grade II listed building, and three converted farm buildings built in the 17th, 18th and 19th centuries. Wealden District Council (WDC) placed an Article 4 order on the Horstedpond Farm site in 2006, stating that development of this site would “seriously damage the rural character of the rural area” and that “it would seriously be detrimental to the considerable visual amenity of the area”. Furthermore, “the setting of Horstedpond House makes a moderate to high contribution to the heritage significance of the site”. In addition, Archaeology South-East (ASE) states that some or all of the converted farm building residences could possibly be considered to be curtilage listed.
The UK government’s National Planning Policy Framework (NPPF) recognises that “heritage assets are an irreplaceable resource” and should be conserved “in a manner appropriate to their significance”, and requires that planning applicants should “describe the significance of any heritage assets affected” by their application, “including any contribution made by their setting”. HFAG believes that Castlefort Homes have not met their obligations in respect of these NPPF provisions.
- Local planning policies
The proposed Horstedpond Farm housing development site is directly across Lewes Road from Ridgewood Farm (Ridgewood Place) where Taylor Wimpey has permission to build 1,000 new homes. Construction work on the first tranche, of 250 new homes, is currently underway. In addition to Ridgewood Farm a total of five other housing development projects, have been proposed for Uckfield. The five other Uckfield projects that have been tabled comprise Downlands Farm, Bird in Eye Hill, Ridgewood House, Gladmans Eastbourne Rd and our Horstedpond Farm scheme.
If all the Ridgewood Farm homes and all the homes under the five proposals were to be built, the number of homes in Uckfield would increase by 50 per cent, or close to 2,500 homes. Over 80 per cent of these new homes would be located in South Uckfield. The town’s available transport and amenities infrastructure, already under considerable strain, would be unable to cope with such an influx of new residents. The layout of the town would require a complete redesign and much building work to accommodate the additional business, infrastructure and amenity loads imposed on Uckfield by the new homes.
- Strategic, regional and national planning policies
There is uncertainty over the number of new homes Wealden is required to deliver due to the delayed status of the new Draft Local Plan and the new National Planning Policy Framework (NPPF) due to current deliberations at UK central government level and the final form of the new Levelling Up and Regeneration Bill (LURB) legislation.
Under the latest regime WDC had been required to provide 1,212 newbuild houses per year, or three times the number required by its predecessor regime. The total of 1,212 new homes is also well in excess of the estimated number of new homes needed for South East England (and by inference Wealden) region specified by the Office for National Statistics (ONS) based on the latest census. ONS has calculated that only 25,700 new homes per annum will be needed for the entire South East England through 2028. In other words, Wealden would be called upon to provide 5 per cent of South East England’s required new homes even though the district accounts for only 1.7 per cent of the region’s population.
- Transport/road access
The Ridgewood Farm project that is underway and the five proposed Uckfield housing developments would bring an estimated additional 4,000 cars to Uckfield. Over one-half of these extra vehicles would be due to the Ridgewood Farm development and, if it goes ahead, the adjacent Horstedpond Farm development.
Uckfield was already suffering from congestion prior to the completion of any new homes due to its historic road layout. Accidents on the single-lane A22 bypass are a frequent occurrence, necessitating highway closure and bringing complete gridlock to the very limited number of alternative routes through the centre of Uckfield. Roadworks are another inescapable feature of driving on Uckfield’s restricted network of roads, due not least to the development of new homes, viz the current five-month closure of Lewes Road due to the laying of a couple of hundred metres of water pipe. Virtually every resident of Uckfield can provide innumerable examples of missed appointments, late arrivals, long detours and the negative impact on struggling businesses due to the knock-on effects of roadworks.
The user-unfriendly Stantec Traffic Assessment, laden with mysterious acronyms and questionable numbers, carried out for Castlefort Homes improbably predicts only the slightest marginal increase in traffic due to the Horstedpond Farm development. What are the criteria for this assessment, which is claimed to be a desk-based survey of existing information? What is needed are onsite measurement of traffic flows backed by rigorous analyses, with special regard for extra vehicular traffic required for deliveries and runs to schools, doctors, hospitals, shops and places of work.
The lack of off-road parking for the Edwardian houses on Lewes Road and New Road means that only one vehicle at a time can proceed in the north-south direction of these roads. This disruptive situation has prompted occasional road-rage incidents in the past. The new homes at Ridgewood Farm and as a result of any further new homes that are built will exacerbate the situation.
The proposed Horstedpond Farm housing development would have only one access point, on Lewes Road. Homes in the far reaches of the Horstedpond Farm development would be 2.6 km from the centre of Uckfield and the town’s railway station, necessitating not only numerous car journeys but also the provision of a dedicated bus service.
The access road from Lewes Road to the proposed 400 new homes would intersect with the existing lane to the present Horstedpond Farm buildings. There are no indications in the Castlefort proposal as to the right-of-way arrangements at this crossroads. HFAG has major concerns about the potential for accidents at this proposed intersection.
- Deficiencies in community/social facilities and infrastructure
In Uckfield Town Council’s consultation responses to the direction the new Wealden District Council might take, the councillors have pointed to the lack of adequate infrastructure planning required to accommodate the half dozen housing developments underway and proposed for Uckfield. The infrastructure required covers not only roads but also rail, public transport, education, community and social facilities, utilities and gas, water and electricity supplies, water waste, communications, health, including medical centres and emergency services, shops and employment. Existing amenities, not least schools, health centres and supermarkets, are already stretched. The number of general practitioners currently opting for early retirement is just one particular cause for concern.
- Flood plain and flooding risk
Horstedpond Farm is firmly in the middle of a clay-rich area of negligible permeability. A groundwater vulnerability study carried out by Envirocheck in May 2006 categorised all the land comprising the Horstedpond Farm site to be “Non Aquifer (Negligibly Permeable)”. The report also notes the potential for landslide ground stability hazards and for shrinking or swelling ground stability hazards. Ridgewood Stream, a major tributary to the River Uck, runs adjacent to the northern side of the site and sits within Flood Zones 2 and 3.
Uckfield’s main river flood risks are concentrated along the River Uck, the Framfield Stream and the Ridgewood Stream, as all are prone to flooding, especially in the heavy rains now becoming more prevalent. During periods of heavy rain overflows from the Ridgewood Stream currently result in significant flooding of Lewes Road.
- Sewage treatment
Southern Water has undertaken a desktop study of the impact that the additional foul sewerage flows from the proposed Horstedpond Farm development will have on the existing public sewer network. This initial study indicates that these additional flows may lead to an increased risk of foul flooding from the sewer network, and that additional reinforcements will be required to handle the increased foul flows.
Southern Water reports that it will endeavour to provide reinforcement within 24 months of planning consent being granted but for more complex applications its assessment of the timescales needed will require an allowance for the following which may result in an extension of the 24-month period.
Southern Water requests that, should this planning application receive planning approval, the following informative is attached to the consent: “Construction of the development shall not commence until details of the proposed means of foul sewerage and surface water disposal have been submitted to, and approved in writing by, the Local Planning Authority in consultation with Southern Water.”
- Environmental impact
Some 48 metres of Hedgerow H13 (one of 13 hedgerows at the Horstedpond Farm site) would need to be removed to accommodate the proposed entrance and access arrangements to the site. Hedgerows are classified as a Priority Habitat and constitute one of the most botanically diverse habitats within the site. They potentially provide commuting and dispersing corridors for species including bats, dormice, great crested newts and reptiles as well as a nesting habitat for birds and dormice. An ecological impact assessment carried out by Hone Ecology on the Horstedpond Farm site states that Hedgerow H13 has been assessed as “important” and, as such, a Hedgerow Removal Notice will be required for the removal of the 48m of this hedge.
There is a pinch point, between a veteran tree and Horstedpond Woods, an ancient and semi-natural woodland, also known as priority woodland, where access is provided between Field 1 and Field 6, as denoted in the Castlefort proposal. The Forestry Commission and Natural England have standing advice on protecting the root structure of these trees, and hard surfacing would be required at this point.
The Horstedpond Farm housing development project proposed by Castlefort Homes represents yet another piecemeal, opportunistic initiative of a type currently plaguing Uckfield. It pays no heed to either the actual housing needs of the town or the negative impact it would have on Uckfield’s infrastructure, amenities, services, biodiversity, green spaces and social fabric.
The Castlefort project also does not adequately take into account the Ridgewood Farm housing development currently underway immediately adjacent to Horstedpond Farm and the fact that Ridgewood Farm’s permitted 1,000 homes would more than meet any conceivable requirement for new housing in Uckfield. The additional fact that the builder of the Ridgewood Farm homes, Taylor Wimpey, is currently struggling to find buyers for the first tranche of 250 homes it is constructing is an indication of the present parlous state of the housing market. These 250 homes represent only the first of five building stages planned for Ridgewood Farm and details of the sale of the sites and the construction of the amenities promised for Stages 2-5 have yet to emerge.