A summary of the Consultee Response submitted to Wealden District Council by East Sussex County Council’s Communities Economy and Transport section (ESCC Highways) on 15 November 2022

15 December 2022

Horstedpond Farm Action Group (HFAG) is yet to submit an objection to Wealden specifically on traffic matters as the ESCC Highways Consultee Response covers the issue so comprehensively. The ESCC Highways Consultee Response highlights many inaccuracies and shortcomings with regard to traffic levels, traffic infrastructure, services, travel plans, traffic impact modelling, distances and access arrangements in the Castlefort Homes planning application for 400 homes at Horstedpond Farm. The following paragraphs summarise this Consultee Response and include some of HFAG’s own findings and observations in the appropriate sections to reinforce points made by ESCC Highways.

GENERAL OBSERVATIONS

The Horstedpond Farm development, if it proceeds, would generate a high proportion of private car-based journeys, due primarily to the site’s distance from the town centre. The annual average daily traffic (AADT) volume on Lewes Road past Horstedpond Farm in 2021, a year punctuated by Covid lockdowns, was 4,810 vehicles, of which 1% per cent were HGVs. Many of the Ridgewood homes on Lewes Road have no offroad parking and thus park their vehicles on the southbound side of Lewes Road. This requires southbound vehicles on Lewes Road to pause and tuck in behind parked vehicles to enable northbound vehicles with right-of-way to proceed up the road’s only available lane.

The substantial distance of Horstedpond Farm from Uckfield, plus the lack of footpath facilities on the alternative routes into the town centre, make the pedestrian option challenging to all but the most resolute walker. That distance, plus the lack of cycling infrastructure on the alternative routes into town and the topography of the land, with its long, sustained incline up Lewes Road and the long, sustained, steep descent from the Highlands roundabout down New Road, with its many parked cars and busy traffic, into town, make the cycling option viable only for the most experienced and confident cyclist. The need to complete the homeward journey in the opposite direction, complete with purchases, ensures that a cycle is most unlikely to be used for a shopping expedition.

The provision of public transport, i.e. a bus service, to the proposed Horstedpond Farm housing development, poses major logistics and cost challenges, as will be described in the PUBLIC TRANSPORT section below.

The design arrangements for the main access onto the proposed site, via a planned roundabout on Lewes Road, have not been developed to the extent necessary. They do not adequately consider the topography of the site, not least the height disparity between Lewes Road and the much lower adjacent field that the roundabout will access. Therefore, the design arrangements will need further consideration, not least in terms of the safety features required. Similarly, the proposed arrangements for the site’s emergency access point off the A22, as submitted, do not adequately accommodate the approach routes and physical requirements of the emergency vehicles.

ESCC Highways points out, in its Consultee Response, that the developer has not as yet been provided a Travel Plan for the scheme. In addition, the modelling of the traffic impact that has been submitted for the project is incomplete. What has been provided has not considered the town centre highway network, which is already at capacity, and not just during peak periods.

MAIN ACCESS

As mentioned, the Castlefort Homes planning application proposes the construction of a roundabout on Lewes Road to provide the only public and private vehicular access to the site. It would also be an entry and exit point for pedestrians and cyclists. As submitted, the application does not adequately address a number of roundabout-related problems to enable the deliverability of the design to be demonstrated. Not only would this proposed main access roundabout require a realignment of Lewes Road but also robust structural features, such as a retaining wall, would have to be introduced to ensure that the significant height differential between the roundabout and the lower Horstedpond Farm field immediately adjacent could be safely accommodated.

The lack of suitable solutions for overcoming these physical constraints at the site’s entrance represents an important gap in the application. Also, the developer needs to disclose details of how the surface should also be treated so that the ESCC Road Safety team are able to consider all the problems associated with the issue.

EMERGENCY ACCESS

An emergency vehicle access entry point for the site has been proposed for a location on the A22 a few hundred metres east of the Little Horsted Roundabout. The arrangement here would require a new section of road off the A22 long enough to accommodate a fire tender safely while the access gate is opened. As submitted, the Castlefort Homes site plan does not show this required length of road at the access point. Also, the access arrangement would need to accommodate a left-in entry and left-out exit procedure for emergency vehicles.

PEDESTRIAN AND CYCLE ROUTES

The distance from the proposed main Horstedpond Farm site access roundabout on Lewes Road to the Bell Lane junction in central Uckfield is 1.8 km, stated to be the equivalent of a 25-minute walk. This would increase to 2.3 km for those living at the far eastern end of the proposed development.

If the Lewes Road route was chosen for the walk into Uckfield (the only realistic alternative), the estimated 25 minutes for the walk into Uckfield does not consider either the incline of the Ridgewood section of Lewes Road or the fact that there would be a need for several crossings of the road to reach the available stretches of footpath. Lewes Road in Ridgewood has pavement on one side of the road only and the available stretches alternate from one side to the other. Most of the footpaths are narrow, often significantly less than 2 metres in width, and the opportunities for widening are minimal, due to the presence of retaining walls. When pedestrians pass wheelchairs, prams and buggies on the footpath, it would be necessary for them to step into the carriageway.

When making the return journey from Uckfield, pedestrians would similarly encounter a long stretch of steep uphill incline on New Road between the railway station and the Highlands Inn roundabout.

There are no dedicated cycle lanes on the Lewes Road route between the Horstedpond Farm site and Uckfield town centre. Several of the same Lewes Road restrictions that impact pedestrian journeys into Uckfield would also challenge cyclists. Most notably, the long, sustained uphill incline on Lewes Road in Ridgewood means that northbound journeys will test the fitness of cyclists that do not cycle regularly. The steep New Road uphill incline, stretching from the railway station up to the Highlands Inn roundabout, will similarly strain amateur cyclists making the southbound run from town to the proposed Horstedpond Farm site.

The combination of these long inclines and the route’s narrow roads, with their profusion of parked vehicles and vehicular traffic to negotiate, with ensure that cycling is not a journey option that will viewed with enthusiasm. If considering it as an alternative for a shopping expedition into Uckfield, cycling would certainly pose many more challenges than attractions.

PUBLIC TRANSPORT

For those without a private car and not up for a long, troublesome walk or cycle ride, a bus service is a cheaper option than a taxi. However, arranging a bus service for residents of the proposed Horstedpond Farm housing development is not without major logistics difficulties. There are two primary alternatives for such a service, i.e. either diverting a bus on an existing route onto the proposed site or organising a dedicated shuttle bus that links Uckfield with Horstedpond Farm and a limited number of nearby stops.

Buses on the Brighton & Hove Buses Route 29 link Brighton with Tunbridge Wells and stop in various Uckfield locations. The developer of the proposed Horstedpond Farm project has stated that it will provide a new bus stop within the site to obviate the need for residents to make a long walk to the nearest existing Lewes Road bus stop. This new pick-up point could serve either a diverted Route 29 bus or a bespoke shuttle bus.

Unfortunately, Castlefort Homes has proposed a location for this new stop close to the new Lewes Road roundabout which would be the site’s main access route in and out. Such a location would be well away from the zones where the bulk of the proposed new homes would be built and, again, would necessitate a lengthy walk from people’s homes. A much more sensible location for a site bus stop would be near the project’s geographical centre. Such a positioning would provide more space for vehicle turning circles and avoid the challenge of manoeuvring full-size buses in restricted space near the proposed site’s entrance roundabout.

Any final arrangement for public transport would also need to take into account the requirements of schoolchildren. The considerable distance of the town’s schools from the proposed Horstedpond Farm site and the fact that only one of these is on a bus route would combine to ensure that the vast majority of school runs would involve private cars.

Ideally, passenger transport demands should be identified through a Local Plan so that the assessment of bus routes, both existing and prospective, can be made holistically to provide sustainable travel choices and financially viable services to serve the town and external key destinations.

THE RIDGEWOOD PLACE FACTOR

The proposed Horstedpond Farm housing development is just across Lewes Road from Ridgewood Place where permission was granted for the construction of 1,000 new homes six years ago. The Ridgewood Place project is being developed in five stages. Construction work on Stage 1, comprising 250 homes, is still underway, and none of the further stages have been embarked upon as yet. As of late 2022, Stage 1 was 72% complete. Although foundations were being laid for some of the remaining 28% of the Stage 1 dwellings, no erection work on these homes had commenced. Covid, inflation and the current parlous state of the UK economy have adversely impacted the originally anticipated pace of house sales, and hence construction work, at Ridgewood Place.

The planning application for 400 homes at Horstedpond Farm includes provisions that put forward the possibility of residents of the new housing development making use of proposed Ridgewood Place pedestrian and cycling links for journeys into Uckfield. However, use of such links, if and when they become available, would entail journeys every bit as long and challenging as the Lewes Road alternative. Also, although the Ridgewood Place outline proposal laid down cycling routes, the project is still stuck in its Stage 1 construction phase and, as yet, no detailed plans for the routes have been submitted. As no further reserved matters applications for Ridgewood Place Stages 2-5 have been received, no timescale is available as to when such routes may become available.

PRIVATE CAR TRANSPORT

Private car ownership is greater in the peripheral areas of Uckfield than it is in the town centre. For example, each residence in Ridgewood village at the southern end of Uckfield has 1.8 private vehicles per household while the figure for the town centre is 1.4. In light of the fact that the proposed Horstedpond Farm site is farther away from Uckfield town centre than Ridgewood, each planned dwelling on the site would likely have an average of at least 1.8 cars. Furthermore, because of the difficulties that the site poses for the alternative modes of transport, as outlined above, the Horstedpond Farm project, if it goes ahead, would likely generate a large number of private car journeys.

The ESCC Highways Consultee Response points out that the private car traffic level information given in the Castlefort Homes planning application is incomplete. Furthermore, the traffic level figures given in the NTS Trend Analysis consultation commissioned by Castlefort Homes state that the proposed Horstedpond Farm project would have only marginal impact on the likely number of private car journeys from the site into Uckfield. Considering the difficulties with using the alternative modes of transport to and from the site, this is simply an inaccurate conclusion.

“It is clear that there will be significant (private car) transportation demand generated by the proposed development,” states ESCC Highways. “This would be directed to access the town and town centre along roads currently experiencing long queues and congestion.” The agency goes on to point out that in view of the planning applications currently outstanding for two other major Uckfield housing developments – Downlands Farm and Bird in Eye South – and the imminent consultation on Regulation 18 for the future Local Plan, “it is considered that progression is needed in terms of the Local Plan development process and decisions on the submitted major housing proposals in Uckfield so that the transport considerations can be assessed strategically and not in a piecemeal way”.