I do not agree with Policy BEX9 (land off Spindlewood Drive) on the following grounds. The policy should be amended to include a much smaller developable area and far fewer dwellings, with access off Barnhorn road.

The physical and social infrastructure in Little Common is not adequate to accept development on the scale proposed.

The proposed development is too dense and would put a greatly increased burden on the surface water drainage system by virtue of the roofs, roadways and hard standing areas, increasing the immediacy of run-off at times of high rainfall and exacerbating flooding in the Cole Stream basin affecting existing properties in Hazelwood Close and Old Harrier Kennels as well as potentially the SSSI and Ramsar Site on the Pevensey Levels. It would not be possible to contain the peak run-off rates to anything like the existing site run-off rate of the present field which acts as a 'sponge'. At least three quarters of the site drains naturally through ground water percolation to the Cole Stream.

The proposed number of dwellings is also too large for highway access to be obtained from Meads Road which has insufficient width for additional two-way traffic taking account of the existing residential and visitor parking and the number of existing properties served. The carriageway of Meads Road is only 5.4 metres wide for a substantial length at its northern end between Meads Avenue and Cooden Sea Road. Taking into account existing residential and visitor parking the free road width is in many places reduced to 3.4 metres. Meads Road is presently providing a principal link to the local shopping centre and main road network for some 190 houses, several of them in multiple occupation on a net width of 3.4 metres. Over the majority of Meads Road the existing traffic has to adopt an informal alternate direction of traffic flow as the only way for traffic to pass.

If the BEX9 development is allowed to proceed in effect Meads Road would become the Residential Distributer road for the development. Such a road would normally be required a minimum width of 6 metres and preferably 6.2 metres width. Several Highway Authorities in England require major access roads for development to be between 6 metres and 6.75 metres wide. Meads road is completely built up on both sides and the opportunity for any widening does not exist. Even with parking completely banned on both sides of Meads Road the width would be insufficient.

The junction of Meads Road and Cooden Sea Road is inadequate for the additional traffic from the development proposed.

The scale of the proposed development requires a direct vehicular access off the main road network which in this case can only be provided off Barnhorn Road. Barnhorn Road should be the principal access for all vehicles with the access off Spindlewood Drive for pedestrians and cycles only.

In the Core Strategy Rother District Council also says that Further development west of Little Common roundabout should have its access off Barnhorn Road.

The Bexhill to Hastings Link Road has drawn a considerable increase in traffic onto the Little Common Roundabout. Traffic from Cooden Sea Road at Little Common Roundabout was expected to average 10,000 vehicles per day in 2010 according to ESCC traffic modelling. Traffic on Barnhorn road was expected to be 22, 600 per day in the same model. This has already been exceeded. At flows above 13,000 vehicles per day a ghost island is required to allow right turning traffic to wait for a gap in the oncoming flow without delaying the traffic behind but there is no opportunity for this to be provided at Meads Road.

Irrespective of what the landowner's surveyor may have persuaded someone in the Highway Authority of, the proposed access off Spindlewood Drive is inadequate and dangerous in that sight lines from this access would not be adequate particularly to the north where the pumping station fence comes right to the back of the footway but also towards Meads Road. The addition of substantial numbers of large flat-bed lorries delivering all sorts of building equipment and materials to the site would be impossible to manage on Meads road. It is also highly unlikely that refuse vehicles in excess of 10 metres in length could safely use such an access.

If the principal highway access was from Spindlewood Drive there is a considerable risk that traffic from the development would seek to access the main road network using Maple Walk southwards as an alternative to Meads Road.

Maple Walk to the south of Spindlewood Drive is extremely narrow between the property Carisbrooke on Maple Walk and Little Twitten a distance of more than 150 metres over which the roadway is not more than 3.4 metres total width and an informal alternate direction of traffic flow is the only way for traffic to pass. In this section of Maple Walk there is no footway and the roadway has to accommodate pedestrian traffic as well as vehicle and this causes hazard to pedestrians many of whom are elderly and also children.

In the 2005 Inspectors Report on the Public Inquiry into the Local Plan and the development of the Old Harrier Kennels site to the west of Maple Walk, the Inspector considered that "20 or more dwellings would generate an amount of pedestrian and vehicular traffic on Maple Walk (the narrow section) such as to necessitate significant improvements to that private road". The same thing
applies today with respect to BEX9 to the west of Maple Walk.

I think East Sussex County Council Highways Department were trivialising these issues when they stated to the developer that Meads road could accommodate the traffic from the development.

Even with access for this development directly off Barnhorn Road the Local Planning Authority must obtain a full Construction Management Plan from the developers and enforce this management plan. The Management plan should stipulate that all deliveries should be from Barnhorn Road during restricted hours only. The power to require a Construction Management Plan is set out in Section 106 of the Town and Country Planning Act 1990.

The Construction Management Plan may contain inter alia specifications on:

* Measures to mitigate the effect of a development on its surroundings;
* Site access and parking of delivery vehicles and loading of Waste disposal vehicles;
* The size of vehicles to be used for deliveries etc;
* The routes to be used for heavy vehicles accessing the site;
* The locations and access of any cranes;
* The storage of materials and waste off the surrounding roads;
* Off road parking arrangements for staff and sub-contractors working on the site
* Specify the hours when construction vehicles may arrive and depart;
* Noise and air pollution abatement measures;
* Control of highway works connected with the site development, such as manholes etc;
* Making good any damage to surrounding roads caused by heavy construction traffic.

In the Council's own words the land off Spindlewood drive is one of two significant areas of residential expansion and is the second largest expansion in the Local Plan.

As such the proposed Development would require a much more extensive Transport Assessment than merely stating that according to the Local Highway authority the local roads could accept the traffic associated with the development. The Transport Assessment would need to be done on a much more robust basis than merely an out of date April 2015 traffic count at Little Common roundabout, before the Link road was complete and open. The opening of the Bexhill to Hastings link road did not occur until December 2015. A wide-ranging transport assessment including the effect on Cooden Sea Road and its feeder roads and the effect on Little Common roundabout and Barnhorn Road should be included. Barnhorn Road carries the A259 Trunk road traffic.

The assessment by EXIGO using ARCADY shows that there would be considerable congestion at Little Common roundabout with queues of more than 1 Km in peak hours. This is already occurring in 2016/2017 before the new housing at Barnhorn Green or Spindlewood Drive is developed. To plan for such a congested junction on a Trunk Road would be an abrogation of the Planning Authority's duty. The East Sussex SATURN model appears to "wish the excess traffic away' on to other
non-defined but less suitable routes.

It is quite clear that irrespective of the Spindlewood drive development a Little Common bypass is necessary to take traffic off the A259 west of Northeye and join up with the Ninfield road in the general vicinity of Lunsford Cross and thence to the NBAR.

Infrastructure should proceed in step with development. Any amount of housing on the Spindlewood Drive site should not be occupied until a Little Common bypass is open to traffic. This would be commensurate with the provisions of conditions proposed for BEX3 in (xi) on page 149 of the Council's present document.

I do not believe it is for me to suggest alternative locations for Development. That is for Rother District Planners to come up with sensible solutions that can stand testing at Public hearings and Inquiry.