I object strongly to the inclusion of site BX116 (Land at Spindlewood Drive) in the allocation of preferred sites for housing development Policy BEX9. I believe the inclusion of this site is ill conceived, ill considered, I'll prepared and inappropriate.
Reasons underpinning my objection include:

* Town and Country Planning principles: Inclusion of this site BX116 will lead to a further unstructured and discontinuous extension of Little Common towards the west. Such an extension of the urban landscape at the expense of the rural backdrop to Little Common will further intrude visually into the adjacent Sites of Special Scientific Interest and RAMSARS, would generate additional and unwelcome artificial lighting in an otherwise "dark space" (telescopes were installed nearby because of this "Dark Space). Further, the extension of large volume ribbon development along rural areas alongside or close to the A259 major roadway would be representative of urban development format discredited in the 1960s and has no place in desired urban planning for the 21st century when, as the Secretary of State for the Environment has made clear in policy statements, preference and priority should be given to the allocation of Brownfield Sites for new housing development.

* Site Allocation rationale: Sites have been included in the Options and Preferred Options documentation relating to the Core Strategy and Local Plan on the basis of an analysis of data prepared by the Rother Council Planning Department. It is submitted that this analysis is flawed. A more thorough assessment of the data published by the Council makes it clear that the need for site BX116 in Policy BEX9 (and other sites such as policies BEX6, BEX7 and BEX10-BX101) to be included in the ten year plan as proposed is quite unnecessary. The Council documentation ignores the significant and well established trend of so called Windfall Developments, which, as Rother data shows (Housing Land Supply and Housing Trajectory at 1st April 2016 document dated August 2016) considerably exceeds over an aggregate 10 year period the figure for such Windfall Developments included in the proposed plan. The scope and scale of such Windfall Developments is exampled in the Council's own data and can be seen recently in planning decisions and in new, but yet to be decided, applications since the consultation documents were released. It is submitted that the Council should take a realistic view of the impact on housing numbers over the plan period when assessing the need for site allocation and that if it does so then site BX116 can be eliminated from the list of possible sites.

* Transport: The Council cannot be serious in asserting, as it does in its consultation documentation, that site BX116 becomes viable for large scale housing development with a vehicular access solely from Spindlewood Drive. That road is already a narrow neighbourhood access road, leading to main transport routes via Meads Road - a narrow, poorly designed and inappropriate public highway - or via the even less appropriate unadopted private road that is Maple Walk. Maple Walk, in particular, is a "village lane" with varying widths, no footpaths, and no road substructure. It is maintained through the goodwill and expense of most local householders and it would be quite wrong for a development site to be allocated at BX116 when traffic serving such a development would impose a financial and maintenance burden of those fronting the nearby private road. The alternative of accessing the site from A259 Barnhorn Road is similarly flawed since that road is already at maximum capacity with further already approved housing developments certain to exacerbate the frequent long tailbacks and delays seen at and leading up to the junction of the A259 with Little Common roundabout. To have further large scale housing development along the A259 axis is symptomatic of a naïve and unstructured approach to planning designed to achieve one goal (housing numbers) at the expense of a range of other critical factors and to do so by inclusion of site BX116 will simply lead to bad urban planning in its wider and desirable sense.

* Little Common Environment: Site BX116 currently provides a visual green space buffer zone between the vital and important Sites of Special Scientific Interest and RAMSAR sites in and bordering Pevensey Levels. Already there has been erosion of that buffer zone and it is submitted that such erosion should be no longer tolerated. To omit development on Site BX116 and other nearby option sites would be an act of visible and practical support for the important local physical environment, and would be a testimony to a declared value for that extensive site, its ecology, its landscape and its flora and fauna (including a range of protected species including badgers and great crested newts). Allocation of site BX116 for housing would be an unnecessary and unwarranted intrusion into a very special area the progressive loss of which must be stopped. It was for such a reason that an Inspector previously removed site BX116 from a site allocation plan and it must be inconceivable that the conditions and arguments that led to that earlier decision should now be overturned by a decision to now allocate the site for housing development. It is submitted that, if anything, the previous reasons for removing the site from allocation have become even more significant. Moreover, Site BX116 is poorly located in terms of drainage. Current surface water drainage in the area - and in particular some properties fronting Maple Walk - uses an existing surface water stream. There is already evidence of polluted water entering that watercourse and thence reaching the SSSI and RAMSAR sites. Petroleum or oil based film can be seen on the surface of stream water. Local topography would result if Site BX116 surface water adding both volume and pollution to the existing system. Additional water volume would result in high flood risk and extra pollution would increase an already unwanted danger to protected sites and their ecology.

* Alternative sites: Policy BEX9 and site BX116 should not be an Option or a Preferred Option. Government policy directs that Brown Field sites should be the preferable choice for housing development. Even if such sites are unavailable - which cannot be plausible - and/or the current extremely low numbers of Windfall houses were to be accepted in the plan then the Site BX124 -the NBAR Site- offers significant and attractive scope to be developed larger than currently envisaged in the Council documentation. Site BX124 should be enlarged by the 215 houses as envisaged in BX124 Option3 , which would add to critical mass to become a viable local community within the broader boundary of Bexhill on Sea., This would be done in the context of pre-existing transport routes, local and sub-regional shopping ( e.g Tesco, Dunelm, garage showrooms etc, etc),and the new Primary School and large hospital in the nearby area. Further the inclusion of an enlarged BX124 would avoid making significantly worse the already overstretched east/west road access routes through Bexhill and Little Common. The additional integration into Bexhill of the northern developments around the Link Road should be welcomed and encouraged though the inclusion of the enlarged Site BX124. Site BX116 can then be eliminated from the site allocation programme.

Site BX116 should be removed from the Options and Preferred Options plan and Site BX124 enlarged with adoption of its Option3.