Angmering Parish Councils Response to A/50/24/ESO
With assistance from our planning consultant - the following was written and submitted to Arun District Council on 10 April 2024 via email, as the ability to add comments was no longer available. This application did not need to involve public consultation and this is why the ability to comment is no longer available on 10 April 2024, when the due date for a decision was not until 12 April 2024.
Town Country Planning (Environmental Impact Assessment) Regulation 2017 – Request for Screening Opinion of proposed development at ‘Land West of Bewley Road, Angmering’ – Nexus Planning on behalf of Gleeson Land – A/50/24/ESO
The Parish Council notes the request for an Environmental Impact Assessment (EIA) screening opinion submitted on behalf of Gleeson Land by Nexus Planning in their letter of the 13 March 2024.
Whilst the Parish Council acknowledges that it is not the intention of national planning policy that an EIA should routinely be required from qualifying Schedule 2 development, we do ask you to consider the following points before reaching your decision.
The proposed development of 212 dwellings is not ‘marginally’ in excess of the Schedule 2 threshold set out in the EIA regulations as suggested by Nexus Planning. It is over 25% in excess of that threshold. Whilst it falls well below the level at which planning practice guidance suggests that an EIA is always required, it is entirely open to Arun to conclude that the proposed development is of a scale which justifies an EIA.
Nexus Planning correctly acknowledge that cumulative impacts are relevant to the decision making process. If Arun allows successive development proposals in Angmering to come forward without EIA then there is a risk that the relevant effects of that development will not have been properly assessed – which as planning practice guidance makes clear is the purpose of EIA:
The aim of Environmental Impact Assessment is to protect the environment by ensuring that a local planning authority when deciding whether to grant planning permission for a project, which is likely to have significant effects on the environment, does so in the full knowledge of the likely significant effects, and takes this into account in the decision making process.
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Arun must be mindful that simply accepting the applicant’s assertions that there are no relevant effects, especially on a cumulative basis, will mean that it does not have the information necessary to make a proper assessment of those significant effects.
Nexus Planning argue that the proposed development site has few, if any, characteristics that contribute to environmental sensitivity, but that does not mean that the project itself must inevitably be outside the scope of EIA. In particular, we draw attention to the following issues:
Trip Generation and Impact on Sensitive Receptors
Whilst traffic generation from the site will be a planning consideration under any circumstances the specific environmental impact of additional traffic entering the South Downs National Park (which Nexus Planning accept is in the ‘proximity’ of the site) may not be and should be assessed.
St Wilfrid’s Catholic Primary School lies in proximity of the site and is likely to be affected by additional traffic generation (as well as other environmental risks).
Flood Risk and Water Management
Recent events in Arun district have demonstrated that the impact of development on flood and drainage management constitutes a major threat to the environment and to human receptors. Speculative development always raises the possibility that it will increase that risk. Whilst Gleeson Land is no doubt anxious to avoid consideration of the development impact on the environment we believe it is essential to do so. It is not enough for Arun to be informed only by a limited and site specific assessment. The bland assertion in the screening request that there is ‘no potential for significant effects’ cannot be accepted at face value and must be tested.
Impact on Agricultural Land
Speculative development on the Sussex coastal plain (much of which meets the definition of ‘best and most versatile land’) is reducing the amount of land available for agricultural production. This is over and above the land allocated for development in local plans which will also, eventually, be lost to agricultural use. Whilst each loss is in itself small and often given relatively little weight in planning decisions, it is important that the environmental impact is properly assessed which can only be done through EIA.
For these reasons we ask you to consider very seriously the need for a full EIA to be submitted with any application on this site.
