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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 a report on
                    th
               a (non-binding) consultation enthusiastically supporting the development. It states:
               •  The EDF site is currently occupied as an office building. FACT: It is unoccupied with a   Page | 17
                   zero-traffic flow;

               •  The application is supported by a revised transport statement. FACT: What may be a
                   revised statement on the MSDC website does 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 it is 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.  There is no mention in the report analysis 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 footpath;

               •  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 is inoperative.  The prevailing parking
                   specification derives from AWNP Policy 21 and requires two spaces per unit.  The
                   application development is at least 50 parking spaces short and over 90 short in the
                   integrated development;

               •  The development is estimated to generate a decrease in vehicular trips.  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 table 8 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.  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”.
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