Page 292 - All files for Planning Inspectorate

Statement of Case
EDF Energy, Wealden House, Lewes Road, Ashurst Wood

6.18 Rather oddly, the Council’s refusal reason in asserting that the level of car parking is

insufficient, does not allege that there would be any adverse impacts in relation to

highway safety or to the surrounding highway network as a consequence of the level
of car parking that is proposed. The allegation of harm appears to be that the

inadequate level of car parking is an indicator of overdevelopment.

6.19 This assertion appears to be based solely on the fact that there is a shortfall when

measured against the District Council standards and a larger shortfall against the
Neighbourhood Plans parking standards. Yet if there are no severe impacts on

highway safety or the road network (as per paragraph 109 of the Framework) and the
scheme is acceptable in design terms in meeting the requirements regarding separation

distances, provision of amenity space, providing good living conditions for future and

neighbouring residents etc (all the normal measures of overdevelopment), I cannot
see how this refusal reason translates into demonstrable harm.

6.20 In order further to assess this issue, the appellant’s Highway Consultants, Motion,

have produced a further assessment and this statement is attached as a separate
document as part of the submission. The assessment concludes that there is no

evidence to support the contention that there is insufficient car parking to meet the

needs/demands of the development.

6.21 In addition, to assess the design aspect of this refusal reason, a statement has been

prepared by the appellant’s Architects and this is also included as a separate document
in this submission. This reviews the normal indicators of overdevelopment in relation

to scheme design concludes that there is no tangible manifestation in design terms of
the Council’s assertion of insufficient car parking.

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10 December, 2019 Page 22

Bates No 000291