Page 27 - MJC submissions

STEPS TOWARDS AN AGREED STATEMENT OF FACTS
And stipulations

5 Documents Supporting the Application (Continued)
5.5 The West Sussex County Council Highways Consultation
On 4 July 2018, Jamie Brown, a Planner with WSCC Highways team, submitted an
th
incredible report on a consultation in which he enthusiastically supported the development. It
states:
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 The EDF site is currently occupied as an office building. FACT: It is unoccupied with a
zero-traffic flow;

 The application is supported by a revised transport statement. FACT: What may be a
revised statement on the MSDC website would not load;

 Access will be via the existing access arrangements--- which benefits from a Right Turn
Lane (RTL). FACT: For reasons explained in paragraph 7.4 the WORT lane is already
extremely dangerous and congested;
 There are no visibility issues from the existing site access. FACT: Not correct;

 There have been no recorded injury accidents near the site access. FACT: Not correct;

 There is no suggestion that that the proposed development would exacerbate an existing
safety concern. FACT: There is no mention in the report of any “existing safety concern”:
 An internal footpath is provided within the current site. This should be 1.8 metres in
width. FACT: There is no indication in the Design and Access Statement of any internal
footpaths;

 Parking provision is stated as meeting the requirements of the WSCC Parking Demand
Calculator—the car parking provision is anticipated to satisfy the likely demands’. FACT:
The WSCC Parking Demand Calculator has questionable authority because it appears to
rely on MSDC’s Local Policy 2004 (T4) which was inoperative. The prevailing parking
specification derives from AWNP Policy 21 which requires two spaces per dwelling. The
application development is at least 50 parking spaces short;

 The development is estimated to generate a decrease in vehicular trips. FACT: This is
nonsense (See Figure 14:page 27);
 The LHA acknowledges that the TRICs outputs [are relevant and are] in accordance with
TRICS Best Practice Guidance – of the trip rate from the new dwellings in comparison
with the existing use. FACT: this is nonsense (See paragraph 7.5);

 While the proposal does exceed the 30-vehicle movement threshold, the existing use of
the site and less intensive nature does not warrant a formal junction assessment. FACT: It
does exceed the WSCC threshold and a formal assessment is essential;
 It is recognised that this proposal would give rise to a less intensive use of the existing
access onto London Road {sic}. This proposal is not anticipated to result in a severe
cumulative impact on the operation of the local network in accordance with paragraph
32 of the National Planning Policy Framework. FACT: The evidence is counterfactual.

Mr Brown classifies the development “as a small scale to be provided for local housing
needs”. It is, in fact, admitted by MSDC as a “major development”.