Page 4 - Microsoft Word - Letter to Steven King rev2

q) Ashurst Wood Policy ASW 10 relates to the WH:LIC site (14). Map 3 from the AWNP of
March 2016 [Attachment 8] shows that the policy would apply to the entire site of an
estimated 0.4 hectares even though only 0.08 hectares of the Northern car park were
qualified for allocation. The different boundaries of site 14 on Attachment 7a (identified
by site number) and on Attachment 8 (identified by policy reference) have led an
assumption that the entire WH:LIC was validly allocated in the AWNP. This does not
appear to be the case.
r) The “Report on the Assessment of Potential Housing Sites”, dated December 2014 states:
“There is little information about proposals for site 14. However, it is part of the overall
Wealden House site and access to the neighbouring site 13 is over this site. Therefore, it
should be included in the plan”.

This is not a valid reason or lawful justification for allocation, because (a) the WH:LIC site
was not agreed as available by the owner, (b) it was not assessed, nor subject to
consultation, and (c) there was no OAN in respect of it. However, its addition did have
potential Community Infrastructure Levy incentives for both MSDC and AWVC; as does
the out of character high density of the WH:EDF site; producing an increased Gross
Development Value;
s) The MSDC Brownfield Land Register [Attachment 9] shows a total of 50 dwellings on the
combined “Wealden House” sites of 1.6 hectares: that is a density of 32 DdHa. There is
no explanation of how this incorrect area was calculated, although it is likely to consist of
1.2 hectares of the WH:EDF site (Site 13) and 0.4 hectares of the WH:LIC site (Site 14). If
this is the case, it is again in error because the combined net developable area is 1.2
hectares (0.8 hectares of the WH:EDF site and 0.4 hectares for the WH:LIC site).

t) In any event, the brownfield report signals an integrated development of 50 units rather
than around 120 as implied in the Design and Access Statement of the original April 2018
application - DM/18/1548.
I acknowledge that all of the above – including any arithmetical and other errors - are moot
because ASW Policy 5 states that all estimates of capacity and all pre-application advice are
non-binding and that design and scale will be determined at the application stage. This must
be subject to the site being legitimately included in the Neighbourhood Plan, or a new, stand-
alone application.

The developers seem to accept that Ashurst Wood Village Council and MSDC are under no
obligation to approve the estimated numbers or densities:

• The supporting statement on the MSD website – dated 6 April 2018 - by Frank
th
Taylor its town planning adviser states:
“4.6 The Neighbourhood Plan does not specify the capacity of the site in
terms of number of residential units, instead quoting an "approximate
capacity" of 50+; which is indicative of an acceptance that capacity is
substantial and greater number of units can be produced here, subject to
design.”
The plan is not “indicative” of any such thing. On the contrary, I believe it is clear
from the Sustainability Appraisal {Attachment 5b} that the scaling of the WH:EDF site
should be the same as Ashbourne Park at around 28DdHa. Thus, the number of units
should be reduced to 22 rather than increased to 71 as proposed by Mr Taylor;

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