SDNPA Planning response
Published: 19 March 2025
SDNP LOCAL PLAN REVIEW - LAND AVAILABILITY ASSESSMENT (LAA)
PUBLIC CONSULTATION (REGULATION 18)
Policy SDXX: East Street Farm, Amberley
LAA Reference HO037-038
Background information
Amberley Parish Council (APC) is responding to the SDNP request to consult on the identification of land within the Parish for inclusion into the Land Availability Assessment (LAA) for potential housing development The site reference within the plan is HO37 – East Street Farm (top field) and HO38 - East Street Farm (middle field). See maps within Appendix B, page 17.
NOTE – An earlier draft of the LAA included site H039 – East Street Farm (bottom field) but this was subsequently removed as it was deemed by SDNP as the least favourable location out of the 3 fields for development and a potential open green site for ‘biodiversity’. For the purposes of this response, APC are still considering the bottom field as the future of the entire site needs to be addressed in totality for the community.
Executive Summary
This APC response is evidence based. It is also informed by the survey completed by parishioners and through examination of the SDNP policies in reference to the site in Amberley proposed within the LAA.
The data collected in the survey, see table on page 2 for a summary, shows that the community is strongly against the use of the top and middle fields for housing; 94% of respondents were against a development of 45 houses and 87% were against a development of 25 houses. To the question of “what the land should be used for” nearly 95% of responses want the land to be used as green communal space. The proposed road access via Hurst Cottages is also fiercely opposed, with over 90% of respondents against it. The resulting risk to the infrastructure from a relatively large development proposal is also a major concern for over 90% or responses.
There are also a number of objections from a policy perspective (see the following pages). Chief amongst these are SD17 –Protection of the water environment due to the presence of a now recognised chalk stream on the land which is a protected habitat, SD49 – Flood risk management and SD4 – Landscape character.
APC does not support the inclusion into the LAA of the site in its current form - East Street Farm top and middle fields. This decision is based on the views expressed by the community, both via the survey and directly, and the analysis of the policies which apply to the site, which are detailed in the following pages.
Amberly Parish Council Community engagement
The council became aware of the LAA draft inclusion on the 17th of October 2024 and were asked to keep this information confidential by SDNP until the 14th November, at which point we informed the community the same evening at the APC meeting. Since that time, the council has run several community engagement meetings to ensure everyone is aware of the LAA, what it means and the associated consultation process. APC also attended the West Sussex councillors’ briefing in Midhurst and the LAA exhibition run by SDNP in Amberley, at which there was a large community turnout.
A meeting has taken place on site between APC councillors and Claire Tester the SDNP Planning Officer to review the fields and initial concerns. A local traffic survey has been undertaken by villagers to highlight the issues already being experienced in the village.
Another local group has also worked with the Western Sussex Rivers Trust to confirm that the stream running through the site is a Chalk Stream which, even in its current form, is an important and protected characteristic. A plan has been formed to re-naturalise the stream, providing both wildlife habitat and restoring its function in managing the flooding of the local area, particularly the centre of the village.
As the subject of development was prominent in the Amberley Neighbourhood Plan (ANP) and the feedback to that plan was excellent, APC decided to organise another survey to canvass the view of the community. This would provide an evidence base for APC’s submission to SDNP.
The surveys were distributed by hand and collected at several points in the village. 410 surveys were distributed, with 180 returned, representing a 44% return rate, which is above average.
The survey questions, response figures and comments are attached to this submission as Appendix B for review in full, but the key findings are summarised here as follows:
| Question | Agree | Disagree |
| Should SDNP keep to the previously allocated 6 houses | 81% | 19% |
| A development of 15-25 houses is suitable | 13% | 87% |
| A development of up to 45 houses is suitable | 6% | 94% |
| Does the site’s potential justify the increase from 6 to 25/45 houses | 8% | 92% |
| Is there a risk to infrastructure – power, water, sewerage, flood | 91% | 9% |
| Environment risks? – dark skies, landscape, character, tranquillity | 87% | 13% |
| Will the proposed road access through Hurst Cottages work? | 10% | 90% |
| Use of the site as green accessible space for the community | 94% | 6% |
| If Dev, only part of the site to be developed | 77% | 23% |
| If Dev were to take place – the top field? | 15% | 85% |
| If Dev were to take place – the middle field? | 16% | 84% |
| If Dev were to take place – the bottom field? | 59% | 41% |
| | | |
| Support for a community centre next to the car park | 75% | 25% |
| Relocating village shop to the community centre | 73% | 27% |
From the survey results we can establish:
· High support for SDNP keeping to their original housing allocation >80%.
· The community is strongly against the use of the top and middle fields for housing, with 94% of respondents against a development of 45 houses and 87% against 25 houses.
· The proposed road access via Hurst Cottages was almost universally seen as highly problematic, with 90% of respondents against this proposal.
· Infrastructure risks to power, water and sewerage was also flagged as a high concern by over 90% of respondents.
· 94% support for use of the site as green accessible space for the community, with 153 responses to this question.
· High support for the nature reserve proposal, 94% although a smaller response rate to this question (75 respondents).
· With respect to the use of the lower field, which SDNP removed from the LAA, 59% of the responses to this question agreed to a level of development there.
· Good support for the community centre next to the car park and relocating the shop, agreed by more than 70% of people responding to these questions.
Proposed Vehicle Access via Hurst Cottages
The Parish Council asked an independent traffic surveyor to assess the impact of proposed vehicle access to an East Street farm site development. The aim was to assess the impact to the village and the viability of the route as there are several concerns. The full traffic survey report is included as Appendix A. The summary and findings are as follows:
The current proposal for vehicle access to the proposed development via Hurst Cottages is not viable as construction traffic and residents of the new development would need to access the site by driving through Amberley.
Key findings:
1. The junction of the B2139 and School Road is classified as unsafe as it doesn’t meet the minimum sight line requirements. Any proposal to increase traffic through this junction would increase the risk of accidents.
2. There is a width restriction warning of 6’ 6” on School Road.
3. For much of School Road, High Street and East Street there is either no footpath or the footpath is less than 2m wide.
4. There is a pinch point in High Street just south of the Village Shop which is 4.39m at its narrowest, there are often cars parked there to access the shop.
5. At the corner of the Black Horse Pub, where East Steet meets High Street, there is a 90-degree blind corner with lack of forward visibility.
6. Hurst Cottages approach has cars parked on one side of the road which will be a problem for increased traffic going two ways.
Amberley Neighbourhood Plan
APC created a neighbourhood plan (NP) in 2016 which was formerly adopted by SDNP in June 2017. Within the plan are policies that reference both the National Planning Policy Framework Principles of Sustainable Development and the polices of the SDNP.
One of the guiding principles is to ensure that the natural environment, natural resources, landscape and tranquillity within the parish as a whole will be conserved, protected and enhanced.
Previous Housing Allocation
The SDNP previously allocated up to 6 additional homes for the Parish of Amberley in the time frame 2016 to 2032. In the intervening time 14 were built, exceeding the allocation by 8. The new housing was part of the Amberley Neighbourhood Plan consultation conducted in 2016/17. The survey proposed a number of sites: Parham Estate; all 3 of the East Street Farm fields; and a site adjacent to Newland Gardens. The survey response to these sites provided a clear mandate from the community in favour of the site next to Newland Gardens, with an equally clear directive against any development in the East Street Farm fields. Development on the chosen site was favoured as the location was not adversely affecting the historic, rural and agricultural setting of the Village and surrounding landscape. The acceptance and success of housing on this site demonstrates that the Amberley community is not against to development that is in the right location and sized correctly for the village.
New Housing Allocation
The SDNP LAA for Amberley at the East Street Farm sites proposes a housing density of between 25 and 45 Houses. As previously mentioned, this site was not supported by the community during the NP survey and is in the middle of the village adjacent to the conservation area and outside the current settlement boundary.
Amberley Neighbourhood Plan Policy references with regards to site
The Amberley NP created and adopted by SDNP in 2017 is going to undergo a review during 2025 but the policies regarding development are still valid. Key policies in this regard are as follows:
AP Policy EN1 – Natural environment
Development in the Parish will only be permitted where it contributes to the special qualities of the SDNP, safeguards the natural beauty of the area and does not detract from the National Park’s visual qualities and essential characteristics.
A development of up to 45 houses in the middle of the village, effectively overwhelming the adjacent conservation area, will not contribute or safeguard its visual qualities.
AP Policy EN12 - Landscape character and open views
All development should maintain the local character of the landscape and special qualities of the SDNP and should not have an adverse impact on significant views that currently provide open field aspects or views from the village centre and other open spaces. Including views from Amberley Mount and the South Downs way to Amberley.
Any development in the middle and top fields will impact views from and to heritage buildings in the conservation area and will be highly visible from Amberley mount.
AP Policy HD1 Settlement Boundary
Proposals outside the settlement boundary will only be supported in the exceptional circumstances set out in the national guidance and the development plan. HD 1.1 The boundary sets the distinction between the built form of Amberley and the surrounding countryside and will protect the countryside from unnecessary
development.
The site is outside of the settlement boundary and development in this area is not an exceptional circumstance by any measure. There is no demonstratable local need.
AP Policy HD4 Housing density
The density of new developments should be appropriate to its location by virtue
of size, siting and relationship to existing properties. HD 4.1 To ensure that new development does not harm the established character
Development of up to 45 houses will be dense on this site, especially in relation to the surrounding buildings in the conservation area. Visually, this will have an adverse effect upon the character at the very heart of the community, forever changing it.
AP Policy FI1 Create a car park
The Parish Council will work to secure funding for and develop a car park.
The car park will be:
· designed and landscaped to cause minimum intrusion into the surrounding countryside and views from the South Downs Way.
· provide a safe off-road route from the car park into the school for school children and parents.
NOTE - The car park has been built on the bottom field H039 – East Street Farm bottom field, currently owned by Horsham District Council (HDC), and is widely used by the community, local businesses and visitors. The car park is also connected to the second Policy F1 2 to build a Community Centre.
The car park lease is scheduled for renewal in 2027, and APC are in discussion with HDC to secure the future and to enable the completion of the EV charging points that are currently on hold due to lease agreements that are with HDC to resolve.
AP Policy FI2 Build a joint-use school/community hall
The land shown on the Proposals Map is allocated for a new school/community
hall. The development will provide a new hall, the use of which will be shared
between the Amberley School (during school hours) and the community
(outside of school hours).
FI 2.3 Amberley Parish does not currently have a Parish Hall. It does have a much loved and frequently used church hall, which is the best meeting space currently available in the Parish. The church hall, however, suffers from several limitations: it is quite small, it belongs to St Michael’s Church which has first call on its use, and it has very limited car parking. A larger facility with more extensive car parking would provide the Parish with a larger meeting space which could provide for a more extensive range of activities – e.g. youth club, indoor sports (e.g. table tennis, badminton), amateur dramatics.
FI 2.5 It has been estimated that the village of Amberley gets more than 10,000
visitors annually – many to the village itself, and many others accessing the nearby South Downs. Many visitors arrive by car, but there are also many cyclists, walkers and bird watchers, and many people arriving by train at Amberley railway station.
There are currently no public toilet facilities in the Parish. Visitors tend to ask to use facilities in the various businesses (e.g. the tea rooms, the pottery, the pubs, and the church hall when it is open), none of these are normally available for public use. Availability of a public toilet in the new hall, adjacent to and accessible from the proposed School Road car park (see Policy FI1), would contribute significantly to the welcome afforded to visitors, and would be an amenity available to visitors, school parents and children and local residents.
FI 3.1 The buildings listed in Schedule A have been listed by Horsham DC on the
Register of Assets of Community Value.
NOTE - Since the neighbourhood plan was created in 2017, the views of both APC and the School Governers/Directors have changed from the original plan as follows:
· The school’s Year 6 classroom requirement has now been resolved onsite by the expansion of an existing building, so the community hall space is not required for this purpose.
· The school would still view the close proximity of a community hall a vital asset for occasional use as a sports hall and arts venue and potential pre-school in a shared space. These facilities would help secure the future of the school.
· The original proposal for locating the community centre on the school land, playing filed is strongly rejected.
· APC’s preferred location for a new community centre is an area within the H039 – East Street Farm bottom field, adjacent to the car park.
· APC has been working closely with the team who manage the local community shop/post office and to safeguard the future this valuable and much-loved asset. A plan has been formed to integrate the shop within the new community centre plan. There are several local examples where this is working successfully, and this proposal has a majority of support as demonstrated in the APC LAA survey.
Review of applicable SDNP polices within the Local Review
SD1 - Sustainable development – No change from previous local plan
Local Plan
Clause 2 of the policy states that the primary purpose of the SDNP is to "conserve and enhance ....... " This appears to conflict with the proposal if the development is unsustainable and does not enhance the environment.
Evidence Objection Comment: We question that the proposed development of up to 45 houses is 'sustainable' given the identified systemic infrastructure problems in Amberley - power, traffic, sewerage, surface water removal and flooding.
The infrastructure is in high deficit. Power resilience is weak in Amberley, because the village falls between two power grids, neither of which accord priority to this community which already experiences frequent power cuts. It is becoming worse with the slow but necessary transition from oil-fired domestic heating to heat pumps, and other shifts to electricity use. The addition of up to 45 houses would pose unsustainable strains on the power supply, with new heat pumps and EV charging points mandated by building regulation and increased load on sewage pumping. Amberley needs a new supply of renewable power, but none is on offer.
Sewage capacity is already an issue, and the system would be overwhelmed by this development. An inadequate and poorly designed surface water systems at the Newland Gardens development extension in Amberley completed in the last 2 years has resulted in local flooding of the land. The new development site in question floods and development in this zone of the size indicated would exacerbate the existing problems being experienced. A tipping point would inevitably be exceeded which will have significant impact to both new and existing residents and the fabric/landscape at the centre of the community.
SD2 - Ecosystem services – Substantial changes from previous local plan
Local Plan
1.Development proposals will be permitted where the use regenerative design to restore ecosystem services and have an overall positive impact on biodiversity and the environment.
b) Contribute to nature recovery by protecting, restoring and providing more, better and joined up natura habitats including through biodiversity net-gain where applicable.
Evidence Objection Comment: The Amberley site is former farmland so it is difficult to understand how any development on the site would not be at odds with this core policy. It refers to a net gain for biodiversity and supporting development that will bring wider environmental improvement. How does building 45 houses in this context achieve that?
SD3 - Major development – Minor changes
Local Plan
Planning permission will be refused for major development in the NP except in exceptional circumstances and which it can be demonstrated that they are in the public interest.
Evidence Objection Comment: Although a development of up to 45 houses could not be described as 'major development', in the context of a smaller community such as Amberley this represents a significant increase. (Existing population of 600; increase in population 135, assuming 45 new houses with an average of say 3 people per house = 135 / 600 = 22% increase). (Existing 400 houses, number of new house in proposed development 45, 45 / 400 = 11%). This should be regarded as a major development in the context of Amberley with the corresponding potential to have significant adverse impacts to the community, the existing overstretched infrastructure and flood risk management.
SD4 - Landscape Character – Minor changes
Local Plan
‘Development proposals will only be permitted where they conserve and enhance landscape character.’
3 The settlement pattern and individual identity of settlements and the integrity of predominantly open and undeveloped land between settlements will not be undermined.
5.17 The gaps between settlements protect the individual character and identity of towns and villages. They retain the open nature and the physical and, either real or perceived, visual separation between settlements. The land at the edge of settlements often forms part of the historic setting of the settlement and can include areas which have cultural importance.
Online search: ‘Landscape Character’. Definition given as ‘the distinct, recognisable and consistent pattern of elements in the landscape. It is these patterns that give each locality its 'sense of place', making one landscape different from another, rather than better or worse.’
Evidence Objection Comment: At the current time, the fields act as a green buffer area between the historic part of the village and the newer development of Hurst Cottages. None of the 6 farms that used to be in the village remain. Housing has been built on all the farmland other than these fields. They are the only historic farmland left.
SD6 – Safeguarding views – Minor changes from previous local plan
Local Plan
2. Development proposals will be permitted that conserve and enhance the following view type and patterns identified in the viewshed characterisation and Analysis study.
b) views from publicly accessible areas which are within, to and from settlements which contribute to the viewers enjoyment of the national park.
Evidence Objection Comment: The proposed development in the top and middle fields appears to contravene every clause of this policy. It would affect the view of the village from Amberley Mount, South Downs public right of way which is listed in the Viewshed list on the SDNP website and is a protected view. It also conflicts with Amberley Neighbourhood plan policy - EN12, Landscape character and open views.
SD7 – Relative Tranquillity, 1.b – No changes from previous local plan.
Local Plan
1. Development proposals will only be permitted where they conserve and enhance relative tranquillity.
Evidence Objection Comment: Elevated traffic levels from the proposed development would have a number of impacts that would significantly affect the tranquillity of the village centre together with the visual and aural tranquillity that will come with additional traffic.
There are no parking restrictions in the village, so the entire route along East Street from the development into the village Centre is often lined with parked cars leaving just a single lane for traffic. There are also no passing places, verges or pavements along most of the route over which a recent traffic survey revealed a surprising number of pedestrians.
Opposing vehicles in this part of the village can cause gridlock, not to mention the delivery of shopping, heating oil and the challenge all this represents to emergency vehicles.
SD8 Dark skies – No changes from previous local plan
Evidence Objection Comment: While the policy calls for lighting to be minimised, additional lighting from such a large number of new houses in the centre of the village will not be in keeping with the aims of this policy.
Strategic Policy SD12: Historic Environment – substantial changes
Amberley Neighbourhood Development Plan 2016-32: The Parish of Amberley, located entirely within the South Downs National Park, has around 400 households and a population of approximately 600. It has 4 settlements linked by stretches of country road. Amberley village, the largest settlement, is often described as the ‘Pearl of Sussex’. The old part of Amberley village is a Conservation Area, with more than 60 listed buildings.
Local Plan:
1. Development proposals will only be permitted where they conserve and enhance the historic environment (review adds and cultural heritage,) including through the safeguarding of heritage assets and their setting.
Online search: ‘setting of a listed building.’ Definition given as ‘Setting refers to the surroundings in which your historic asset is understood, experienced and appreciated, including present and past relationships to the surrounding landscape. The importance of setting lies in what it contributes to the significance of your historic asset.’
Evidence Objection Comment: The proposed fields for development immediately back on to the gardens of several historic (Grade II) buildings. There are uninterrupted views across these fields to Amberley Mount with the South Downs Way path. At the current time, these fields are full of wildlife and have horses grazing on them. It is a peaceful and natural habitat where nature thrives and views to the south can be enjoyed. Many of the historic houses are built on lower-level ground to that of the fields. This means that any houses built on that land will impact negatively by affecting views from those properties.
SD17 – Protection of the water environment – Substantial change / full review of previous local plan
Key policy issues:
· Habitat loss
This policy covers within it the importance of Chalk Streams, such as the one recently identified on the site and confirmed by the Western Sussex Rivers Trust.
The importance of a catchment approach for development and protecting the water environment means understanding the role the site currently has within the catchment, e.g. providing flood storage, how the water moves in through and out. Other considerations are how water can be managed onsite to avoid negative impacts and taking opportunities to positively impact upstream and downstream of the site.
Local Plan
“The importance of Chalk Rovers and Streams at the Chalk Stream Restoration Strategy 2021 and Implementation Plan 2022. Chalk rivers and streams are rare, ecological diverse and vulnerable habitat.”
“2 Development proposals that affect groundwater, surface water features, and watercourse corridors will not be permitted unless they conserve, and enhance, and where possible, restore, the following:
c) Specifically for surface water features and watercourse corridors:
i) Habitat quality, biodiversity and contribution to nature recovery, including eradication and control of invasive non-native species. Special regard will be given to the conservation, enhancement and restoration of chalk stream priority habitat;…
5 Development proposals must provide adequate protection zones and buffers to watercourses. It must be demonstrated that the buffer is suitable to retain the natural function of the watercourse and its biodiversity and minimise direct and indirect impacts to the watercourse.
Evidence Objection Comment: A primary concern with this site is the impact upon and preservation/restoration of the newly recognised chalk stream, for which this policy provides specific protection and is an overarching landscape feature which has priority over development.
Southern Water have recently communicated that they will not accept surface run off into their foul water drains. This raises another potential issue for any development on this site, which currently already plays a large part in flood management at the centre of the village. This water course is already vulnerable to flooding and is at capacity.
SD19 Transport and Accessibility – Minor changes from previous local plan
Local Plan
The purpose of Policy SD19 is to encourage development towards the most sustainable locations in transport terms. All new development will be expected to be located and designed so as to minimise the need to travel, and to maximise the availability of relevant sustainable transport options, so that growth in private vehicle use is kept to a minimum.
1.Development proposals will be permitted provided that they are located and designed to minimise the need and/or distance to travel and promote facilitate the use of sustainable modes of transport, including active travel.
2.Development proposals that are likely to generate a significant number of journeys must be located near existing town and village centres, public transport routes, main roads, where relevant, the cycle network. Such development will be required to provide a transport assessment or transport statement.
Evidence Objection Comment: As has previously been stated, Amberley is a small rural village with no buses. There is a railway station that is a 25-minute walk from the proposed site. Train service is infrequent, and journeys often require a change of train. There is no taxi service operating out of the village. The B2139 which is the main road to Arundel and Storrington (the nearest towns, a 15/10-minute car drive, respectively) is a busy road used by drivers of cars, lorries and HGVs to avoid the traffic congestion through Arundel. This is a hazardous road for cyclists and for pedestrians. The pavement at the side of the B2139 is narrow at places between the village and the station. There are no streetlights in the village or the surrounding roads. The historic narrow roads in much of the village mean that there are no pavements. Amberley only has one small shop with limited opening times. Inside the shop is a post office which has even more restricted opening times. There are no medical services. The nearest hospital accident and emergency department is in Chichester which is 13 miles from Amberley – a car journey of 25 minutes in off-peak time. Amberley has a small primary school but no secondary school or activities for children. It is, therefore, really isolating to live in Amberley without a car.
The fields which are proposed for development have a public right of way which divides the middle field from the bottom field and continues outside the east boundary of the middle field into Amberley Millennium Green (a designated green space) which is adjacent to the top field. The PRoW has no street lighting and those walking along it can enjoy the tranquillity of the area.
SD25 Development strategy – Substantial changes from previous local plan
Local Plan
1. a) is a scale and nature appropriate to the character and function of the settlement in its landscape context.
2.Exceptionaly Development will be permitted outside the settlement boundaries where it complies with relevant policies in this local the development plan and responds to the context of the relevant broad area or river corridor, and or exceptionally.
Evidence Objection Comment: We strongly disagree with the changes in this policy that remove “exceptionally” from this policy. Removal or weakening of the safeguard of the settlement boundary would be a dangerous precedent in small heritage communities that could lead to developments that irretrievably change the character of the village in the landscape of the park and adversely impact the community.
SD49 Flood risk management – Substantial changes from previous local plan
Local Plan
1.Development proposals will be permitted that seek to avoid flood risk, reduce the impact and extent of all types of flooding , and utilis characteristic and effective flood management measures through:
a) Following a sequential approach to flood risk management, steering development away from areas of flood risk, including existing or future flood risk for the lifetime of the development, taking into account climate change.
b) Not increasing the risk of flooding elsewhere and, where possible reding the overall flood risk.
Evidence Objection Comment: Clause 1 speaks of avoiding, minimising and not increasing any flood risk. Given that the planning proposal would cause additional run off water into an area that already floods, the proposal for the Amberely site is at odds with the policy.
Southern Water have recently communicated that they will not accept surface run-off into their foul water drains raising another potential issue for any development on this site, especially which currently already plays a large part in flood management at the centre of the village. This water course is already vulnerable to flooding at several points, including the centre of the village, impacting several heritage buildings within the conservation area that are at the lowest point in the village. The stream in question is already at capacity and in its current form requires ongoing local stewardship to ensure it is keeping flooding in check. Additional development in this zone around the stream will increase the flood risk and instead a revised management plan needs to be instigated that will provide a long-term solution for the community.
SD50 Sustainable drainage systems – Substantial changes from previous local plan
Local Plan
1.Development proposals will be permitted where they ensure that there is no net increase in surface water run-off to existing surface waters, ditches or public sewers taking account of climate change.
All surface water management and drainage including SuDS should be designed to achieve the following criteria applied proportionally to the development proposals where feasible.
Evidence Objection Comment: Considering the existing issues with the stream and associated ditches as motioned within comment on SD49 above, any development on this site would be at odds with clause 1 which talks about development only being permitted where there is no net increase in run-off water into existing surface waters, ditches or public sewers. Given that Southern Water will not deal with the additional run off water as mentioned within SD49 comment above this is inevitable.
Conclusion
Amberley Parish Council strongly objects to the LAA proposal for 25-45 new homes on the East Street Farm top and middle fields for the reasons stated within this document. The LAA proposal does not meet with the criteria on numerous policies and appears to be at odds with the fundamental stated purposes of the SDNP to “further conserve and enhance” areas within the park.
For the record, Amberley is not against development, as can be seen from the community survey results and the building that has taken place over the last few years, Newlands Gardens, Drewitts Farm & others. However, it is the overwhelming view of the community, as seen from the evidence-based survey, that the proposed use of site on the top and middle fields for housing is strongly objected to. Fundamentally it will not conserve or enhance the community and surrounding landscape but would cause substantial and irrevocable risk and harm to the fabric of the village.
We would respectfully ask SDNP to re-think and to withdraw this proposal for Amberley in its current form. We would also refer the SDNPA to the recent Manning Tree case which has many parallels and similarities to the possible situation in Amberley, based upon this we are confident that if a legal challenge to the current proposal by the community of Amberley was necessary it would be successful.
Appendices on the following pages:
Appendix A – Report on Transport Planning issues for the proposed development
Appendix B – Amberly Parish Council Survey Results
Appendix C – Survey comments that were provided by the respondents alongside the question responses above.
Appendix A – Report on Transport Planning issues for the proposed development for Amberley Parish Council
Report on Transport Planning Issues – Proposed SDNP Development of Sites HO37 and HO38
Proposed Vehicle Access via Hurst Cottages
The current proposal for vehicle access to the proposed development via Hurst Cottages is not viable as construction traffic and residents of the new development would need to access the site by driving through Amberley.
1) The junction of the B2139 and School Road is classified as unsafe as it doesn’t meet the minimum sight line requirements of being able to see at least 90m (Y distance) in each direction from 2.4m (X distance) back from the junction[1]. Therefore, any proposal to increase traffic through this junction would increase the risk of accidents.
2) Additionally, there is a width restriction warning of 6’ 6” on School Road- the sign for this is located near the car park. This translates to 1.98m. A lorry, according to the Manual for Streets, is 2.5m wide, 3m including wing mirrors[2].
3) For much of School Road, High Street and East Street there is either no footpath or the footpath is less than 2m wide. Where no footpath is present it is advised that the road traffic is less than 100 vehicles per hour 2.
4) There is a pinch point in High Street just south of the Village Shop which is 4.39m at its narrowest. Additionally, there are often cars parking there for the shop and the village bus has had problems getting through.
5) At the corner of the Black Horse Pub, where East Steet meets High Street, there is a 90-degree blind corner with lack of forward visibility. According to the Manual for Streets, the visibility should be 25m minimum in 20 mph zone. Therefore, any proposal to increase traffic through this corner would increase the risk of accidents.
6) There may be air quality and noise concerns relating to increase traffic around the school and children’s play area in Hurst Cottages.
7) Hurst Cottages approach has cars parked on one side of the road which will be a problem for increased traffic going two ways. The kerb-to-kerb road width is 4.75m at its narrowest. This is an issue for waste collection vehicles where the minimum road width recommendation is 5m. 2
8) Given there is a stream between the middle field and the upper field a culvert would be required. It should be noted that West Sussex Local Authorities are in general opposed to the culverting of watercourses because of the potential for adverse effect on flood risk and ecology.
Appendix B – Amberly Parish Council Survey Results
| 1 | The fields on the proposed site are outside of the Amberley settlement boundary. SDNP policy for housing in the park states that houses should only be built outside the boundary in exceptional circumstances. |
| | | Agree | Disagree |
| a | Is this proposal for potential housing an exceptional circumstance? | 12 % | 88 % |
There are no circumstances that APC is aware of that would fulfil these criteria with regards to building on this site.
| 2 | The stated first purpose of the South Downs National Park is “to conserve and enhance the natural beauty, wildlife and cultural heritage of the area” |
| | | Agree | Disagree |
| a | Do you agree and support this | 91 % | 9 % |
There is good understanding and agreement on the SDNP purpose.
| 3 | What in your opinion would be the best use of the site? |
| | | Agree | Disagree |
| a | Green accessible space for the community | 94 % | 6 % |
| b | Housing | 8 % | 92 % |
| c | Mixed use – housing and green space | 31 % | 69 % |
| d | Community infrastructure – solar or heating | 39 % | 61% |
Clear that 94% or respondents feel the site should be left as green space, i.e. no housing.
| 4 | If the site was left as green communal space, what is its best use |
| | | Agree | Disagree |
| a | Nature Reserve – The Amberley “Showstopper” initiative for a re-naturalised community space. | 94 % | 6 % |
| b | Organic Allotments | 64 % | 36 % |
| c | Green energy for the community – solar | 41 % | 59 % |
| d | Recreation | 70 % | 30 % |
| e | Mixed use of the above | 62 % | 38 % |
Only 75 respondents to 4a, vs 153 for question 3a on green space – but nevertheless a majority support for a green space use of the site.
| 5 | The current South Down National Park plan allocated 6 new houses in Amberley between 2017 and 2030. The site at East Street Farm, if included in the new revised plan, allocates 25-45 Houses |
| | | Agree | Disagree |
| a | Should SDNP keep to the allocated 6 houses | 81 % | 19 % |
| b | How do you feel about the possibility of 25 houses on the site. | 10 % | 90 % |
| c | How do you feel about the possibility of 45 houses on the site. | 7 % | 93 % |
| d | Does the sites potential (size) for more housing justify the increase from 6 to 45 houses. | 8 % | 92 % |
Overall feeling here is that the community want SDNP to keep to the previously allocated number of 6 dwellings and that larger housing numbers are not supported.
| 6 | The road access proposal for any potential development on the site is via Hurst Cottages, through East Street and into the village centre, to the B2139 |
| | | Agree | Disagree |
| a | Proposed access road into Hurst cottages will work | 10 % | 90 % |
| b | The proposed access road will not work | 86 % | 14 % |
| c | If a development takes place, access should be via a new road from the B2139 | 78 % | 22 % |
High number of people feel the road access will not work; much greater support for access via the B2139.
| 7 | A proposed development of this size would increase the Amberley population by 10% (25 houses) to 18% (45 houses) |
| | | Agree | Disagree |
| a | Increase of 10% population would benefit Amberley | 20 % | 80 % |
| b | Increase of 18% population would benefit Amberley | 7 % | 93 % |
| c | This increase in population would be challenging for Amberley | 91 % | 9 % |
Clear indicator that that the proposed size of the potential site is too large for the community.
| 8 | If a development were to take place on the site |
| | | Agree | Disagree |
| a | I would prefer only part of the site to be developed | 77 % | 23 % |
| b | The Top field (HO37 in LAA) is best for development | 15 % | 85 % |
| c | The middle field is best for development (HO38) | 16 % | 84 % |
| d | The bottom field is best for development (HO39) | 59 % | 41 % |
Good support for part of the site to be developed, BUT clearly NOT the top or middle fields. Bottom field has the greatest support across the 3 fields.
| 9 | Infrastructure – any new housing will place new demands on infrastructure, are you concerned about any of the following? |
| | | Yes | No |
| a | Power, the electricity supply | 91 % | 9 % |
| b | Water and sewerage | 96 % | 4 % |
| c | Flooding protection, ditches | 95 % | 5 % |
Almost universal agreement that there are significant infrastructure challenges in Amberley with regards to additional housing.
| 10 | Environment – any new housing will impact the environment, are you concerned about any of the following? |
| | | Yes | No |
| a | Dark skies – impact to light pollution | 87 % | 13 % |
| b | Impact to the landscape | 87 % | 13 % |
| c | Impact to the character of the community | 86 % | 14 % |
| d | Tranquillity | 89 % | 11 % |
| e | Nature connectivity | 91 % | 9 % |
High level of concern with regards to environment impacts of this proposal.
| 11 | Housing allocation in Amberley |
| | | Agree | Disagree |
| a | No allocation for new housing is needed | 70 % | 30 % |
| b | Original SDNP allocation of 6 should be upheld | 77 % | 23 % |
| c | A development of 10 -15 houses | 25 % | 75 % |
| d | A development of 15-25 houses | 13 % | 87 % |
| e | A development of up to 45 houses | 6 % | 94 % |
High support for SDNP to stick to existing housing allocation figures and low level of support for any new allocation.
| 12 | If new homes were to be built, what type of dwellings are needed in Amberley? |
| | | Agree | Disagree |
| a | Affordable housing for those with local connection | 83 % | 17 % |
| b | Original SDNP allocation of 6 should be upheld | 74 % | 26 % |
| c | Small houses – 1-2 beds | 59 % | 41 % |
| d | Large houses 3+ beds | 22 % | 78 % |
| e | Flats | 22 % | 78 % |
Good indicator for affordable housing, 1-2 beds.
| 13 | Community infrastructure – there are agreed plans within the existing Amberley Neighbourhood plan to provide more facilities for the community. Some of these have developed further and we would be very interested in your views |
| | | Agree | Disagree |
| a | A combined community centre and shop, similar to Fittleworth or Thakeham | 70 % | 30 % |
| b | Locating the community centre next to the village car park | 75 % | 25 % |
| c | Relocating village shop next to car park to allow it to develop and thrive. | 73 % | 27 % |
High level of support for the community centre next to the car park and relocating the shop.
Appendix C – Survey comments that were provided by the respondents alongside the question responses above.
| 1 | The fields on the proposed site are outside of the Amberley settlement boundary. SDNP policy for housing in the park states that houses should only be built outside the boundary in exceptional circumstances. |
| | | Agree | Disagree |
| a | Is this proposal for potential housing an exceptional circumstance? | 12 % | 88 % |
Comments:
“Policy SD25 amended to a few developments outside the settlement boundary. But this amendment is also subject to consultation. Notes re justification offered by SDNPA for this change. APC should object.”
“Building a housing estate is not conservation or naturally beautiful”
“There is a settlement boundary for a reason. How is it the case? What reason is it for this to be undermined?”
“This is not an exceptional circumstance – the NP only includes additional houses – there is not a local need for this number in this location”
“Exceptional circumstance is undefined, but I am not aware of any exceptional need”
“Disturbing that SDNPA should consider development outside settlement boundary, adjacent to the historic part of the village.”
| 2 | The stated first purpose of the South Downs National Park is “to conserve and enhance the natural beauty, wildlife and cultural heritage of the area” |
| | | Agree | Disagree |
| a | Do you agree and support this | 91 % | 9 % |
Comments:
“This development is contrary to their clause as this will destroy the tranquillity of the village and detract from its beauty and heritage”
“It is important to maintain the natural heritage of this area for beauty and wildlife”
“The SDNPA have utterly failed in its duty of care to the South Downs if it goes ahead with this scheme.”
“This development proposes houses in excess of the number agreed in the neighbourhood plan”
“It is very sad and disheartening to see the SDNP doing the exact opposite of “conserve and enhance the natural beauty, wildlife and cultural heritage””
“The natural beauty, wildlife and cultural heritage of the area is what I moved here for last year. It is imperative it is conserved.”
“This proposal from SDNP flies in the face of everything they purport to protect and enhance”
“Cultural heritage should include building of a community – and that needs houses”
“Duty to foster social and economic wellbeing of the local communities”
“Development on these fields contravenes the new legal duty of SDNPA and HDC to conserve the national park and landscape”
“It is extremely important to uphold SDNPA’s conservation duty – allowing excessive development will cause irreparable damage, bio-diversity loss and loss of identity for the national park.”
“Development on these fields contravenes the new legal duty of SDNPA and HDC to conserve the national park and landscape.”
“The proposed housing plan seems to contradict the primary purpose of the SDNP in its current form”
“Don't know how SDNP is defining exceptional circumstances”
No exceptional circumstance has ever been asserted””
“Agree that there is a housing crisis”
“Proposing 25-45 houses seems opposite to SDNPAs remit to protect the landscape.”
“SDNPA will be failing in its duty to allow such a proposal.”
| 3 | What in your opinion would be the best use of the site? |
| | | Agree | Disagree |
| a | Green accessible space for the community | 94 % | 6 % |
| b | Housing | 8 % | 92 % |
| c | Mixed use – housing and green space | 31 % | 69 % |
| d | Community infrastructure – solar or heating | 39 % | 61% |
Comments:
“Any alternative plan for the site should protect the chalk stream and the environment around”.
“It is used for grazing of local horses. My daughter learned to ride on one of the ponies. I feel it should remain as pasture for local equestrians.”
“If houses required, only location should in in roadside field due to access, landscape, ecology issues. Middle and top fields are the wildlife corridor rather than roadside field”
“To protect the wildlife, nature and protect the chalk stream from pollution and environmental damage”
“Any housing should only be considered on roadside field by car park due to access and dark skies. In addition, it should also be considered that the field is continued to be used for horses or livestock”
“Current population of approx. 550 with an additional 18% will change character of village. Constant traffic via Hurst Cottages – impossible with narrow access roads”
“The land could be used as a reserve to educate people about the natural environment and compliment Amberley Museum”
“Green space proposal most viable for size/heritage of village – considering it is a national park”
“Preference for nature reserve for flood mitigation and environment benefit, or a small development of 1 or 2 bed homes, with infrastructure and nature facilities.”
“The fields border the Millenium Green and could provide a green accessible space in the center of the village”
“This would be a great project if it could be run and led by the community to deliver what the community wants for the long-term future for Amberley to grow and thrive”
“Cost of solar generation might be prohibitive”
“We are in the middle of hundreds of square miles of green accessible space”
“Limited housing, not more than 10 houses. All affordable”
“Ratio key. 70% green; 30% housing”
“Does ‘d’ mean something like wind turbines? Or field solar panels?”
“Accept small number of houses along with a village hall and shop.”
“Some housing could benefit young families, the school and the shop.”
“Should accept some housing to help housing crisis and build the community.”
“Preference for green space but not averse to genuinely affordable housing.”
“Nature reserve would benefit school and community, more appropriate for this space and would allow natural flood mitigation. Houses would increase risk”
| 4 | If the site was left as green communal space, what is its best use |
| | | Agree | Disagree |
| a | Nature Reserve – The Amberley “Showstopper” initiative for a re-naturalised community space. | 94 % | 6 % |
| b | Organic Allotments | 64 % | 36 % |
| c | Green energy for the community – solar | 41 % | 59 % |
| d | Recreation | 70 % | 30 % |
| e | Mixed use of the above | 62 % | 38 % |
Comments:
“Taking 25-45 house off the table, and redesigning the proposal to incorporate all of the above points in Q4, would be the best use of the space, in my opinion”
“Chalk stream needs to be conserved at all costs.”
“Support for the nature reserve and organic allotments, with recreation elsewhere.”
“Nature reserve and chalk stream protection best way to protect valuable habitat.”
“Nature reserve is best option, recreation catered for elsewhere.”
“Nature reserve best aligns with SDNPAs stated purposes.”
“Chalk stream needs protection and is of scientific interest.”
“Support some mixed uses of the fields, but prefer flood risk mitigation.”
“Nature reserve is best option, recreation catered for elsewhere.”
“Wildlife corridor through the fields including the existing grazing.”
“Only support allotments if there’s proven interest in the community.”
“All sound good use of area - note the Weald to Waves Initiative - and for the benefit of a community that has increased in size over last few years”
“Mixed use can’t work - uses incompatible”
“Strongly feel our responsibility to restore and protect the chalk steam - site could be used as an exciting nature and community space”
“Solar not possible - possibly wind power”
“The nature reserve proposal “would further conserve and enhance the natural beauty, wildlife and cultural heritage of the area” - Quote Purpose 1 of the SDNPA’s statutory duties”
“Dog exercise area or allotments although most people have gardens”
| 5 | The current South Down National Park plan allocated 6 new houses in Amberley between 2017 & 2030. The site at East Street Farm, if included in the new revised plan, allocates 25-45 Houses |
| | | Agree | Disagree |
| a | Should SDNP keep to the allocated 6 houses | 81 % | 19 % |
| b | How do you feel about the possibility of 25 houses on the site. | 10 % | 90 % |
| c | How do you feel about the possibility of 45 houses on the site. | 7 % | 93 % |
| d | Does the sites potential (size) for more housing justify the increase from 6 to 45 houses. | 8 % | 92 % |
Comments:
“These houses are not justified in a small historic village, we have no infrastructure support, eg frequent power cuts, flooding, old pipes and huge amounts of traffic already.”
“Already exceeded neighbourhood plan allocation by some way and need for further new houses is not confirmed”
“More than 6 houses built since 2017, must demonstrate need for any new houses and ensure they’re not second homes or holiday lets.”
“Bottom field could take 6-10 houses next to shop and existing car park.”
“Current SDNPA plan has been superseded.”
“We have had 4 housing developments in recent years, don’t see a further need.”
‘Should be no new houses in the East Street Farm site, should remain as grazing.”
|”Village has permitted small developments; this would have a devastating impact.”
“Access roads would be unable to cope with construction traffic, and additional use by new residents.”
“Amberley does not have infrastructure to support this, it would significantly and permanently damage the character of the village.”
“We have already exceeded our quota of new houses in the last 20years.”
“Size of plot and potential sale value to HDC shouldn’t determine size of development.”
“Calculation of housing need by SDNPA and planning authority need must be transparent, not sized to the available land.”
“Infill of top and middle fields will be unsightly and pose access and road safety issues.”
“A small development of houses that benefit the school and community is preferred.”
“Don’t support more housing and this space provides ‘buffer zone’ in the village.”
“Somewhere between 6 and 25 houses seems sensible, but should look to be within settlement boundary.”
40 houses have been built in the last 20years (Castle View, Drewitts, Newland Gardens, Swan Meadows) we have more than exceeded our plan and done our bit.
“These houses are not justified in a small historic village, we have no infrastructure support, eg frequent power cuts, flooding, old pipes and huge amounts of traffic already.”
“Will cause major traffic jams through the High Steet with the extra vehicles of the occupants of the new houses”
“The site is large enough for more than 6….”
“There have been several new build projects increasing the number of houses by 40 in the last 10 years. Any more is over building in a community that does not have the infrastructure to support it”
“Does this include flats and retirement homes in the total?”
“For houses on the site to be sensitive to the environment and the community they would need to be less densely packed than 45 would allow.””
“Any housing should be restricted to field alongside B2139 - already houses adjacent and on other side of the road”
“With development at Newland Gardens hasn’t SDNP already hit this allocation?”
“Decision to increase the population of a tiny rural village by 18% for no better reason than to pack in as many houses as possible is madness”
“Six houses have already been built”
“Not only would so large a development alters the environmental, cultural and historic profile of Amberley it would also negatively impact on infrastructure issues including (importantly) drainage”
“Recent developments have shown what an asset new residents with new ideas/energy etc are to the village. Recent work at the Millenium Green had a majority of new residents volunteering (i.e. from Swan Meadows)
“Proposed site is situated in the heart of the vilaage so a logical place for a development of around 25 houses”
“Village has already over-subscribed the “6 houses” - x10 were built - and over the last 2 decades there have been further developments on Drewitts Farm and Swan Meadows. No evidence to demonstrate up to 45 new dwellings in this village other than to fill the “land available” - it is not ‘need’ related”
“Just because the land it there does not mean it must be covered in housing or other public amenities”
“Amberley overdelivered the number of houses e.g. 14 properties in Newlands Gardens. The Pickwick site is ripe for (sympathetic) development. 25 - 45 houses on top of these is far too much.”
| 6 | The road access proposal for any potential development on the site is via Hurst Cottages, through East Street and into the village centre, to the B2139 |
| | | Agree | Disagree |
| a | Proposed access road into Hurst cottages will work | 10 % | 90 % |
| b | The proposed access road will not work | 86 % | 14 % |
| c | If a development takes place, access should be via a new road from the B2139 | 78 % | 22 % |
Comments:
“Access should not involve more traffic going through the village as it is quite dangerous at the moment”
“Amberley already has car problem, more vehicles would cause chaos and risk accidents with school children on the narrow road.”
“Traffic is a major issue in the village already, narrow streets and pinch points.”
“Access needs to be via the B21390 to mitigate impacts in the village.”
“Increased traffic on Black Horse corner would be dangerous, current parking makes only single-file traffic possible.”
“Access / traffic is a key factor and makes the SDNPA plan unworkable.”
“Access through village not viable, no footpaths for pedestrians and Hurst Cottages is a narrow road not to current specifications.”
“Proposed access though village and Hurst Cottages would be a disaster.”
“Increase on already difficult traffic and parking would be untenable.”
“Only safe / sensible access option is via B2139.”
“Impression that SDNPA have not properly considered the risks of the access proposed.”
“Access through village is not suitable and B2139 also a busy / dangerous road.”
“Adding access to the B2139 would compound already dangerous access.”
“Access should not involve more traffic going through the village as it is quite dangerous at the moment”
“Cause major traffic jams through the High Street with the extra vehicles of the occupants of the new houses”
“Do not consider the development should take place so cannot agree to alternative access”
“Access to B2139 only viable option. Lots of existing road safety issues currently: village already suffers traffic congestion: several pinch points in the village: route via Black Horse not viable for safety reasons: already congested with residential, building and visitor traffic - don’t need further disruption: access through Hurst Cottages destroy the amenity of the estate”
“Blind bend in Hurst cottages and cars park all down one side, it is effectively single file access only: delivery vans speed round as it is; footballers park on the blind corner”
“Frequently reverse back into the Square to allow traffic to come down past the village shop - a nightmare wth 25-45 more houses”
“Village infrastructure does not have capacity for many more people and cars”
“Construction traffic through the High Street and East Street will put pedestrians in danger. The road is narrow and there is no pavement on this route”
“Proposed access be totally impractical and would cause log-jam, damage and disruption in the centre of a beautiful village”
“Proposed access would completely alter the tranquillity of the village and be unworkable for residents. No matter the mitigations will also pollute the chalk stream especially if the access road brings surface water off the B2139. CaBA Chalk Stream Restoration Plan 2021 lists road run off as a major factor in the national pollution of chalk streams”
“From our cottage have to walk directly onto the High Street - already dangerous - more traffic would increase danger to myself and my dogs”
“As last resort housing could be positioned on lower field with road access directly onto B2139”
“Proposed road access through village and Hurst Cottages is one of the crazest ideas anyone has put forward regarding vehicular access in the village with narrow streets and already constant traffic flow”
“Ridiculous to send traffic in a circle when any access to new housing should be from B2139 - chaotic and potentially dangerous in an already heavily used area”
Most of Hurst Cottages have off-street parking - little traffic and not through traffic. new development may actuallyimprove access. East Street is only an issue because of Black Horse pub parking””
“Currently this road (Hurst Cottages) is underused, potentially a new development would mean access road could be improved”
“Village roads are inadequate for existing volumes of traffic - narrow, without pavements, bad camber and Victorian open water drainage as well as no street lighting. 2. Over past couple of years heavier use of B2139 and logjams in Storrington when accessing A24.“
“Exiting from School Road on B2139 is difficult now - another access road would increase difficulties. Already 2 roads coming onto a very busy B2139.”
| 7 | A proposed development of this size would increase the Amberley population by 10% (25 houses) to 18% (45 houses) |
| | | Agree | Disagree |
| a | Increase of 10% population would benefit Amberley | 20 % | 80 % |
| b | Increase of 18% population would benefit Amberley | 7 % | 93 % |
| c | This increase in population would be challenging for Amberley | 91 % | 9 % |
Comments:
“The current infrastructure for wastewater & electricity suppliers will be severely challenged if a drastic increase in population went ahead”
“Only beneficial if newcomers are full time residents “
“More families could be a benefit, but the increased traffic would be a problem.”
“Village could benefit for a larger, more diverse population to support school / shop.”
“10% increase could benefit village if targeted at young families.”
“Village struggles to accommodate current residents and visitors, leading to parking
problems and safety issues for walkers, cyclists and emergency vehicles, also infrastructure struggling to cope.”
“Keep Amberley as is – it has narrow roads, no pavements, no streetlights, on road parking, a small development could be beneficial, larger would change character.”
“Additional 45 houses would introduce at least 90 more cars into narrow streets.”
“Amberley doesn’t have the infrastructure or capacity – ref. Storrington air pollution.”
“Infrastructure inadequate with electricity outages during storms, local flooding and restricted fowl drainage. Further houses would make this worse.”
“Impact depends on where the houses are placed. Access through village detrimental.”
“Type of housing is key, not the numbers, village has aging demographic so would benefit from more affordable / houses for young families”
“Support for growth and benefits for the village offset by existing infrastructure issues and need to protect environment.”
“Recent developments haven’t increased school use – school performance is greater attraction than proximity (Storrington children come to Amberley)”
“Infrastructure esp. local roads not nearly suitable enough for this size development.”
“Only reason for LAA proposal is because HDC land available, doesn’t reflect need.”
“Risk houses would be second homes or holiday lets not solving housing crisis.”
“Wrong choice of site is key factor, not the development size.”
“A small number of new houses could bring some benefits to the village.
| 8 | If a development were to take place on the site |
| | | Agree | Disagree |
| a | I would prefer only part of the site to be developed | 77 % | 23 % |
| b | The Top field (HO37 in LAA) is best for development | 15 % | 85 % |
| c | The middle field is best for development (HO38) | 16 % | 84 % |
| d | The bottom field is best for development (HO39) | 59 % | 41 % |
Comments:
“It would be easier access to the B2139, building works would cause much less disruption to the village. Development next to the new community centre/shop in the lower field would leave the top two fields for nature. This would have less impact on the Downs/light pollution, no impact on the historic houses in school road/East Street”
“The two top fields are unsuitable because of impact on wild life and Chalk stream and danger of increased flooding. Although bottom field would have less impact on wild life it’s outside the settlement area.”
“Don’t think this should go ahead so no preference. The powers that be will go ahead anyway, look at the wasted consultation on Arundel bypass and dismissal of a better proposal”
“No Development”
“Bottom Field is the only viable option for housing development due to access issues, Middel and Top Fields have key environmental and landscape features that benefit the community and need protecting.”
“Road access manageable by the bottom field”
“The Bottom Field would have best access from the B2139”
“I want no development at all on these fields. It is unsuitable land for building on.”
“The development should not be overcrowded and should give new home recreational and private gardens”
“Because of the slope of the land, development of the top field would put the chalk stream at high risk, flood risk on Bottom Field.”
“The bottom field is already light and noise exposed. The Bottom Field could have access off the B2139 and not impact village traffic.”
“Bottom field least impactful and access from B2139.”
“There should be a green buffer between existing houses and any new development.
The Bottom Field, classed by SDNP as “green corridor” is the only suitable site for a small development and with access to the B2139”
“The bottom field can access the main road. The top 2 field will cause too much further congestion.”
“Proposed developments will completely change the landscape of the village and all its rich cultural and historical past of being a farming village. It is also so important for wildlife, which is increasingly under threat.”
“There should be no further development in Amberley as it would ruin the village.”
“I’d prefer no housing but if it was an obligation nearest access point to B2139 would be slightly better.”
“Best would be a cut from middle and bottom.”
“No idea where these are on the map provided – nearest the B2139 would be only option.”
“None is the best answer.”
“All three fields should be built on.”
“We don’t want to see housing development on any of this land. It would cause flooding and harm the chalk stream.”
“Construction vehicles using B2139 will exert positive effect of slowing speed of vehicles racing along this stretch. However, field prone to flooding.”
“Further development should only take place with the agreement of the village community and on a small scale that would not swamp Amberley’s rural character. If a new community hall and shop were approved, the bottom field is the best location by far.”
“Can’t answer this as do not know what H037 etc refer to. If HO39 is the field where car park is, this is best.”
“Any development should be sympathetically designed to include green spaces and accessed via the B2139 not Hurst Cottages.”
| 9 | Infrastructure – any new housing will place new demands on infrastructure, are you concerned about any of the following? |
| | | Yes | No |
| a | Power, the electricity supply | 91 % | 9 % |
| b | Water and sewerage | 96 % | 4 % |
| c | Flooding protection, ditches | 95 % | 5 % |
Comments:
“Discussion with professionals in their areas have warned about the SEVERE strain any new development would put on the current infrastructure”
Serious concerns about extra demands on infrastructure with examples of how services are severely stretched already with outings of power and water. The proposed development would make Amberley a worse place to live in as infrastructure would be even more stretched. The site should be used to manage flooding naturally
“Discussion with professionals in their areas have warned about the SEVERE strain any new development would put on the current infrastructure”
“We already suffer electrical outages regularly and sewage is an issue already in School Road.”
“Any new development would put our infrastructure at danger of being inadequate and therefore reducing our health, safety and quality of life, both metal and physical.”
“These all need thorough appraisal.”
“The pumping station for sewage already is over capacity. Flooding from the stream has happened recently and sewage has overflowed on the road by the school.”
“We already have frequent power cuts, electricity supply needs to be improved.”
“Infrastructure must be improved”
“Non available or suitable infrastructure is non-existent”
“Power is a serious issue in the village, how many places in the community suffer as many power cuts as Amberley. Sewage is also a major issue. Flood risk at land closer to the B2139 is real.”
“Already significant power and broadband constraints. Flooding already a problem in top and middle fields.”
“The fields are a natural water absorption area, protecting the heritage properties from flooding.”
“We already have issues with power, water and flooding.”
“Being very close to the flood plain, the village has already got problems and concerns with water and drainage. This development proposal will overload an existing overloaded system.”
“The fields should be kept house free to allow a soak point for excess water (flood potential).”
“To ignore existing issues with power supply, sewerage and flooding would be highly irresponsible and damaging to Amberley.”
“Flooding is the main concern.”
“Water quality for the chalk stream is vital. Sewerage system had been inadequate, spewing into School Road and polluting the chalk stream. Long history of flooding in these fields.”
“These are issues with enormous implications for the village’s safety and wellbeing.”
“Lots of houses have been built or developed since original sewer infrastructure was built – must be getting near max. We have several power cuts a year. “
“Particularly water, sewage and flooding.”
| 10 | Environment – any new housing will impact the environment, are you concerned about any of the following? |
| | | Yes | No |
| a | Dark skies – impact to light pollution | 87 % | 13 % |
| b | Impact to the landscape | 87 % | 13 % |
| c | Impact to the character of the community | 86 % | 14 % |
| d | Tranquillity | 89 % | 11 % |
| e | Nature connectivity | 91 % | 9 % |
Comments:
“All of the above environmental impacts are of major concern if any new development does not take them into consideration”
“SDNP mandatorily committed to protect and enhance natural beauty and wildlife. Small number of houses may not affect these aspects of the environment but there is a danger that this proposal would turn the heritage village into a housing estate with all of the above aspects of the environment adversely affected.”
“All of the above environmental impacts are of major concern if any new development does not take them into consideration”
“Amberley has already lost much of its rural character it had say 30 years ago. This proposal would push it further into an urbanisation.”
“This development is simply a bad idea. It is too large for the village and the access road to the B2139 is too narrow to accommodate the increase in traffic, this will impact the school too.”
“Development would enhance the community. B2139 already disrupts native connectivity as does the high incidence of dog ownership.”
“Extremely 100% concerned about the impact on the environment.”
“The village is surrounded by nature and natural spaces”
“If done well a development need not be disadvantage to the area, but how many developments are done well?”
“Top and Middel fields are key to nature connectivity and provide a landscape buffer in the heart of the village.”
“We are merely custodians of this village, our priority should be to protect its heritage and the unspoilt natural environment.”
“One of the things I love about living here is walking my daughter to school on quiet safe roads, through the Millennium Green listening to the song thrushes, watching the rabbits in the bottom fields, crossing the stream and saying hello to the horses – Fifi, Willow and Carrie. It will be so sad to walk through a housing estate instead! I chose Amberley to love in the countryside in a small rural village.”
“A housing development of this size is completely inappropriate for a small rural village. There’s no local demand or need, there aren’t many employment opportunities and the current transport system is limited and not reliable. A development of this size will not be good for Amberley and its community. “
“Amberley has already lost many fields to development, ie Hurst Cottages expansion, Strawberry Villas.”
“The SDNPA cannot choose to disregard its main purposes and duty as well as its core policies governing issues such as dark skies, tranquillity, environmental impact, in order to waive through damaging schemes such as this.”
“All good concerned but good development would not impact any more than existing.”
“My main concern is the wildlife.”
“All provided any development is small and designed sensitively.”
“We need housing.”
“Dark night skies is important not only for stargazing but also for wildlife. Tranquillity and character of the village would be seriously harmed by proposed access. Views would be impacted. Nature connectivity would be enhanced by showstopper nature reserve.”
“These are all issues which SDNPA are, according to their own principles, in existence to enhance not diminish!! “
“I live in Hurst Cottages and will be concerned about additional traffic and pollution. Commuters will be passing twice daily though narrow, winding roads with cars parked on both sides. Will the School Bus need to pick up children from the development? What about builders’ traffic at construction stage?”
“The increase in traffic on the narrow roads, already full of parked cars, will cause huge problems and potential danger to pedestrians including children going to and from school.”
| 11 | Housing allocation in Amberley |
| | | Agree | Disagree |
| a | No allocation for new housing is needed | 70 % | 30 % |
| b | Original SDNP allocation of 6 should be upheld | 77 % | 23 % |
| c | A development of 10 -15 houses | 25 % | 75 % |
| d | A development of 15-25 houses | 13 % | 87 % |
| e | A development of up to 45 houses | 6 % | 94 % |
Comments:
“Again, not being an expert, but in my opinion, there is room for lots of community benefits, if a new development were to proceed such as infrastructure upgrades – community heating & power generation, etc”
“Agreeing to move from 6 up to 10-15 houses could be a compromise, if and as long as it also allows for a new shop and community centre being built by the developer next to the existing car park.”
New development welcome in the right place.
“I believe the allocation of 6 houses within the current SDNP plan has already been met. Also building right up to conservation area boundary is not appropriate”
“Various views: Unsuitable site, a few houses decided by viability of site, allocation of 6 houses has already been exceeded, large number would have deleterious impact on dark skies, wildlife, tranquillity and chalk stream”
“The number of new housed built in Drewetts Farm and Swan Meadows in the last few hears is sufficient for he size of the community and for the physical size of the village.”
“6 properties have been constructed”
“10 to 15 houses is the maximum acceptable”
“Pickwick should be approved for development, rejected on a number of occasions this would provide the 6 dwellings without further development on the proposed site.”
“Maximum number needed in context of national housing”
“The development should not be over-crowded and should give new homes recreational and private gardens”
“Things from Central Government policy can’t be ignored. Weve already have 6 homes as detailed in the Neighbourhood Plan”
“Housing should be by local need, not by land availability”
“On an alternative site or bottom field only.”
“I haven’t lived in Amberley very long, but its main attraction and benefits are that it is still vert rural and beautiful and quiet.”
“There is no basis for this allocation. Amberley has more than met the agreed allocation.”
“Any allocation must be assumed to be refreshed every 5 years (plan review period).”
“Allocation for 6 new houses has already been exceeded by an additional 8 houses.”
| 12 | If new homes were to be built, what type of dwellings are needed in Amberley? |
| | | Agree | Disagree |
| a | Affordable housing for those with local connection | 83 % | 17 % |
| b | Original SDNP allocation of 6 should be upheld | 74 % | 26 % |
| c | Small houses – 1-2 beds | 59 % | 41 % |
| d | Large houses 3+ beds | 22 % | 78 % |
| e | Flats | 22 % | 78 % |
“Any new houses need to be designed to enhance the local character – no flats please (taller buildings)
“Smaller houses would benefit those wishing for first homes or to downsize as we get older. Drewitts Farm (smaller houses), rather than retirement homes.”
“Small affordable house for locals, in character with village, definitely not large houses.
Prefer no more houses”
“Local homes for local people, there is too much “we’d buy it an improve it” and then only wealthy people can afford it.”
“Many elderly people are forced to leave the village due to unsuitable housing stock and would otherwise remain.”
“We need a mix – but not flats”
“If the development was in keeping with the village the price range would not many young people form Amberley to purchase. They would be out of their price range for a mortgage, more likely to second homes.”
“Mixture needed to enhance social diversity. Potential for second homes to be avoided.”
“There is sufficient affordable housing at the moment.”
“We need a mix of houses, e.g. to allow young people to start with a small home, then to move to a larger and when they have a family – keep people in the community as their housing need changes”
“Need to encourage more young families to the village, with affordable options.”
“We believe it is important o have more affordable family homes to support our village school.”
“Probably a mix of all the above so there is something for everyone’s needs.”
“If anything is to be built, some eco housing development for affordable housing with local connection. If these houses could be designed so locals could feel proud and could help local needs.”
“Need a mixture to ensure a vibrant community.”
“Amberley is a jewel in West Sussex. Any more house building sites resulting in additional road traffic, utility project improvements, new householders, tourist traffic will help denigrate its timeless appeal.”
“This question is hypothetical so difficult to answer. However, if a modest number of houses were considered a quid pro quo for a community hall and shop complex, they should be suitable for families with young children to benefit our village school.”
“Bearing in mind housing for locals were not all issued to locals because there was not enough demand.”
“Transport is essential to anyone coming to live in Amberley. There is no public transport and the current facilities are small.”
| 13 | Community infrastructure – there are agreed plans within the existing Amberley Neighbourhood plan to provide more facilities for the community. Some of these have developed further and we would be very interested in your views |
| | | Agree | Disagree |
| a | A combined community centre & shop, similar to Fittleworth or Thakeham | 70 % | 30 % |
| b | Locating the community centre next to the village car park | 75 % | 25 % |
| c | Relocating village shop next to car park to allow it to develop and thrive. | 73 % | 27 % |
Comments:
“I previously suggested the ideas within this question to the Parish Council in my previous comments, so I am very happy to support them.”
“If the community centre is built in the lower field with easy access, there is still room for 6 new, small houses”
“
The village shop would benefit from visibility, a community centre would need to pay for itself, I fear what that would entrail.”
“Our church hall has been refurbished, so a community hall is not necessary.”
“I would accept 10 to 15 houses along with a village shop and community centre.”
“At present the shop has a 999 year lease held by Amberley Shop Proprietor. There is only a 5 year lease on the car park, what protection would there be? For long term tenants? Fittleworth, Thakenham and Slindon only have a small shop, 25% shop and 75% café. Is this what Amberley wants? “
“Community infrastructure would benefit from increased population.”
“New homes would feed into the community centre and shop thriving.”
“If investment is needed from the community the community centre should take precedence.”
“Strongly support this and should be a condition of any development plan.”
“Consider also a new school entrance direct from car park, shop, community centre. It would be much safer for small children to be able to enter school through the bottom field or proposed nature reserve.”
“We have a village hall/community centre. The current village shop could be renovated, and re-modelled to better provide to encourage greater spending.”
“The church hall seems to serve the community well but a shop more like Fittleworth or Slindon with a café and post office would be amazing! So not sure we need a community centre as church hall would be redundant.”
“I think any development in Amberley would be an issue and mistake. You only have to see what has happened to Southwater over the years.”
“The village shop needs car parking spaces to encourage more footfall and extra business to sustain and let it grow.”
“All will require substantial funding so could only be aspiration/reserve space for at this stage.”
“Shop needs to move as I believe it’s having problems with not many people using it. If near main road outside of village people will know the shop is there.”
“Protecting chalk stream should have a higher priority than a new community centre.”
“Any development could be made conditional on the developer having to provide also a shop and community centre, in keeping with the village, next to the car park and using solar energy.”
“The concept of vehicles leaving the B2139 race track to go shopping is almost impossible to imagine. The existing shop in centre of village fits in with village character.”
“At present, we don’t have a village hall, just a parish hall belonging to St Michael’s church. The shop, vital to a remote village like Amberley, would benefit from additional passing trade if relocated next to the car park.”
“Relocating the village shop to the car park may cause more traffic coming in and out of school road. The corner is already dangerous, and this would encourage more passing trade?”
“These are standalone projects and should not be piggy-backed on to a housing development. I would support them all if independent of housing plans. “
[1] Design Manual for Roads and Bridges (DMRB)/CD109 - Highway Link Design.
[2] Manual for Streets, Department for Transport