I do not agree with the preferred sites for housing development. The BX116 site should be removed from the list.

Overall Comment
Although some reference is made to traffic no solution is offered nor attempt made to quantify the impact of the development proposed sites. Based on the figures published in 2011 for the link road submission this overall level of development is likely to increase the traffic of the A259 by between 14000 and 20000 vehicles per day. Current levels of traffic measured on the A259 provided by Highways England show a figure of 21500 vehicles per day. Based on the figures given in TA79/99 Part 3 the A259 through Little Common can be classed as Road Type UAP3 with a capacity limit of 900 vehicles per hour. Measured (by Highways England) peak traffic is recorded at 869 vehicles per hour and the total proposed new build will add at least 171 vehicles/hr, more likely a total of up to 1200 vehicles per hour will be reached, leading to gross overloading of the road and roundabout at Little Common. As regular drivers along this route will know the eastbound flow in 2015 often has mile long queues and the westbound flow queues can be in the order of 0.5 miles.

A late appearance of a note about the impact of the traffic generated by the proposed developments does little to relieve the concern. (This document does not meet the full requirements of Guidance on TransportAssessment - DoT 2007.) There are a number of reasons for this. The housing data does not reflect that current figures used elsewhere in the DaSA documentation and there is no reference to any industrial development that is considered so important to the mix. The traffic is assumed to be all cars whereas the road carries a significant portion of HGVs and regular buses that add to the volume and delays experienced by users at present.

No effort has been made to consider the combined impact of the new junction/lights required to provide access to and egress from Barnhorn Green (already granted planning permission) nor the pedestrian crossings before and after the roundabout and that a primary school is also situated close to the roundabout. Surprisingly all the data used assumes that all approach roads to the roundabout have a 99999 vehicle per hour capacity. This is clearly incorrect as the A259 has a capacity limit of 900 vehicles per hour and the minor road much less.

To show traffic exceeding a realistic limit makes the results of this study count for little. As is already experienced by A259 users queue lengths can be long without the impact of the new road junction and traffic lights west of the Little
Common roundabout.

Please see more detailed comment and analysis in the submitted appendix - http://www.rother.gov.uk/CHttpHandler.ashx?id=27252.

Making provision for Population Movements

If the presumption is now in favour of (housing) development then it is illogical and inconsistent not to have a presumption in favour of infrastructure development also. In particular the need to enhance road capacity to meet the expected demand new development generates.

The only sensible way to improve capacity for viable longer term traffic flow across Bexhill is to provide a new northern bypass between, say, the Lamb Inn and the Ninfield Road so linking with the new western extension from the Link Road. Undoubtedly such new construction of this nature should be part funded by the CIL raised from developers. This would be easier if the developments permitted were to follow round the north along the route of such a new road and make sites such as BX101 and BX 80 more accessible.

This approach has already been outlined in the adopted Core Strategy that states:

8.12 Growth also provides an opportunity for the town. Development has been focused on urban redevelopment in recent years, as limited transport capacity on the A259 to Hastings has frustrated new sites being developed. A high proportion of this has been flatted schemes, often for older people. However, there is the potential for sustainable urban extensions, subject to additional traffic capacity.

8.47 Housing growth may both stimulate business development as well as help otherwise achieve the vision for the town. However, large-scale growth would not be consistent with the objective of retaining its essential character, nor with the commercial property market. Even within these other sustainability parameters, the very limited highway capacity, primarily along the A259 trunk road towards Hastings but extending through the town, is a real constraint upon development at present.

8.56 Development to the west of Little Common, both north and south of Barnhorn Road (A259), will also be considered. Again, the area enjoys an attractive pastoral character, but without impacting on the wider landscape for the greater part. It also benefits from reasonable access to shops and services at the Little Common district centre.

Access would need to be created directly off the A259, supplemented by existing estate roads. Whydown Road and Sandhurst Lane are unsuitable access roads.
There appears to be little point in having a strategy published and approved if some of its fundamental points are to be ignored.