These comments are submitted as a joint response from the Spindlewood Drive Action Group (SPINDAG) and thus represent the majority views of a large number of local residents (c 400) living in and around the Spindlewood Drive proposed development area.

As a group we are opposed to the proposed development BX116 of Policy BEX9 in its entirety.

We ask for it to be removed from the list of Preferred Sites and not be considered for any future development as part of the second DaSA consultation process.

* RDC have stated that they are not willing to take projected windfall properties into account when estimating their target figure of 3100 for Bexhill. This is plainly wrong. RDC have well documented history of an average of 70 small site windfalls per annum being achieved over the past 10 years. There is absolutely no reason to assume that this will not continue until 2028 and the windfalls have no direct bearing or association with the DaSA process and projected development sites. The two issues are separate. An allowance of at least 35-40 windfalls per annum should therefore be incorporated into the DaSA process and projected housing completions.

* We believe it to be superfluous: in the light of the capacity of other proposed sites to provide adequate development potential (for employment as well as residential properties) as well as the almost certain excess of windfall developments we feel that RDC can achieve, even exceed, its development targets without this development.

* We believe it to be totally undesirable. It is wholly impractical, likely to have a significant detrimental impact on west Bexhill, further burdens limited local infrastructure, is out of character with Little Common and based on highly suspect traffic predictions.

Is this development really necessary?

We consider the development to be superfluous to RDC requirements to meet its housing development targets. SPINDAG responses to other questions in this consultation, particularly Q27 show that other developments already at advanced planning stages or under consideration in the DaSA are already likely to enable RDC to exceed its development targets with no development necessary for BEX9/BEX116, especially if windfalls are taken into account by RDC.

There are already a number of advanced developments in the Little Common area, quite apart from the large development at Barnhorn Green. Residential development has been submitted for land near Ashridge Court at the west of Barnhorn Road (31), for the former Co-op building in Little Common (9 plus 3 shops), at 45-47 Barnhorn Road (8) and the former NatWest Bank building (8) in Little Common. These all add to the number of properties that RDC must see developed and their impact on local traffic levels and infrastructure demands should be considered in addition to the Barnhorn Green development.

There is credible evidence (based on RDC-supplied data) that far many more windfall properties will be developed in coming years than RDC supposes in the DaSA plan, easing and possibly exceeding the achievement of RDC's targets.

Furthermore, some slight increases in other more suitable sites will easily enable RDC to provide better located and better quality living environments for new residents than in BEX9/BX116 such as BX124 (Option 3).


Why is this development undesirable?

Local traffic problems

This is a high-density development being squeezed into a very small and environmentally-sensitive area with ridiculously constricted access.

As proposed, vehicular access to the site will be via Meads Road and Spindlewood Drive. Meads Road is already used as an all-day car park by residents, visitors and tradesmen and is effectively a single lane road. Passing traffic has to negotiate a right of way with opposing vehicles. Furthermore, the condition of the road surface in Meads Road is very poor and does not seem to be a priority for repair, or even routine maintenance, by the local authorities. The concrete surface is breaking up and residents report being aware of moving slabs as heavy vehicles pass their properties.

At present the small Spindlewood Drive estate serves about forty five properties. The initial length of Spindlewood Drive is also used as a car/van park by Meads Road residents and visitors, since Meads Road parking is usually at its capacity. These parked vehicles have nowhere else to go in the whole area. Vehicles entering Spindlewood Drive via Maple Walk west are thus made to approach a blind bend into Spindlewood Drive forcing vehicles to the right hand side of the road, risking running into vehicles leaving the estate.

Increasing the traffic flows into and out of Spindlewood Drive from that associated with forty five properties to in excess of two hundred is absolute madness, especially considering that this traffic is not only private cars but delivery vans, utilities vehicles, emergency services, heavy goods vehicles and others. Not to mention the fact that there is very limited visibility for traffic on Meads Road to see into Spindlewood Drive and vice versa due to the tightness and narrowness of the junction and the afore-mentioned parked cars and vans on both roads.

It is proposed that the former Co-op building at the end of Meads Road could be developed for shopping and residential properties, significantly increasing vehicle density and traffic flows into and out of the east end of Meads Road. This will undoubtedly see delivery vehicles parking at the very entrance to Meads Road, as well as shoppers who will not use the (Pay & Display) car park behind Tesco but prefer to park on double-yellow lines. The junction of Meads Road and Cooden Sea Road will become itself a log-jam even before the Little Common roundabout and A259 come under consideration. This junction is already dangerous, vision towards the south for traffic emerging from Meads Road is severely restricted by vehicles parked outside the former Co-op building, and restricted to the north by vehicles illegally (but with impunity) parked on the pavement to the north.

Meads Road and Spindlewood Drive are wholly unsuited to the level of traffic such a development would generate.

The would-be developer of BX116 has provided a barely credible "Technical Note" predicting an "immaterial" impact from increased BEX116 traffic on the Little Common roundabout (available on the DaSA web site, presumably with RDC's endorsement). It studiously avoids addressing traffic flows along Spindlewood Drive and Meads Road. This self-serving document seems to have been accepted at face value by RDC but should be re-assessed on a more realistic and analytical basis in terms of the impact on Meads Road, Maple Walk and Spindlewood Drive.

For example, the Transport Statement for the proposed development of only thirty one properties near Ashridge Court (RR/2016/3206/P) offers a far more thorough analysis of traffic flows into and out of that site and the impact that these will have on the A259. This document and its underlying model and assumptions would seem to be acceptable to the relevant transport authorities. Therefore, it would be entirely reasonable and enlightening to use the same models and assumptions to extrapolate the potential traffic flows for the 160 houses of BX116.

On this basis the following will be seen on Meads Road:

* Peak traffic flow (08:00 - 09:00 & 17:00 - 18:00) of between 90-100 vehicles each hour along Meads Road & Spindlewood Drive

* Total traffic movements of c 850 per day

RDC planners should view the BEX9/BX116 Transport Note with some scepticism and should seek a rigorous revision by an uninterested party.

There is a real risk, therefore, that some traffic for the BX116 housing estate will use Maple Walk as a rat-run alternative to Meads Road. Maple Walk is an unadopted road, much of it very narrow, effectively single lane, like Meads Road. The increased traffic flow along Maple Walk and Maple Avenue would be unbearable for their residents, not to mention the added wear & tear on roads which they must maintain at their own expense.

It should be noted that RDC's own Adopted Core Strategy (Sept 2014) states in para 8.56 that "access (to the west of Little Common both north and south of Barnhorn Road) would need to be created directly off the A259". This alone would seem to prohibit the proposed access to BX116 from using Meads Road and Spindlewood Drive.

Despite our outright objection to this development it is also worthy of note that the would-be developer, Mr Ellis, stated to SPINDAG representatives in a meeting on 2nd Dec ember 2016 that if the development were to go ahead all construction traffic would access the site via an entrance on the A259. If that were to be possible for an extended period for heavy goods vehicles, cranes, diggers and other traffic, why could it not form the permanent access point for the estate? Serious commitment by the developer or pillow talk? We have seen no credible Transport Management Plan from the developer which addresses the serious impact any means of development of BX116 would have on the surrounding area, whatever the access. RDC must insist therefore on a Transport Management Plan irrespective of the access point.


Density of proposed development

The housing estate proposed is far too high a density for the area surrounding it. This area of Little Common consists predominantly of mature detached houses. It has already been noted that the Spindlewood Drive estate has only about forty five houses. It is proposed to pack 160 into an area not much larger than that original development (allowing for trees, play areas, ponds, etc.). This near-quadrupling of housing density is entirely out of keeping with the local area and even residents of the proposed estate would find themselves with very a cramped environment with certain problems for parking multiple vehicles per household, probably including vans, caravans and camper vans.

Environmental Concerns

Although the would-be developer has provided an Ecological Appraisal for BX116 many issues remain to be carefully considered and studied further. There are valid questions to be raised about the ease with which their suggested mitigations can be implemented and their likely effectiveness. This site lies adjacent to areas which are designated SSSI and/or Ramsar sites, deserving of especially rigorous protection. These observations and re-assurances do not seem to have been studied and approved by the relevant utilities, environmental protection and wildlife authorities. The study was commissioned by and paid for by the developer with a commercial interest in this site, hardly an uninterested party. Not least are the issues surrounds drainage and flooding risks, SUDS designs and expectations. Nor is it clear who would be held responsible for any future flooding or environmental damage and how they might be sanctioned in the event of any failure of these measures.

One can foresee major disturbance to the land under development during the construction phase before these mitigating facilities can be put in place. There is, therefore, a serious risk of permanent environmental damage and wildlife disturbance not only on this site but the surrounding sensitive areas. These could never be corrected and the developer would have built his houses anyway. It is especially concerning that certain sections of the Ecological Appraisal have been redacted - why? By whom? With what objective in mind? This should be investigated and the public made aware of the reasons for this.


Wider local impact:

The road system, local services and infrastructure around Little Common are already due to be overloaded without the added burden which BEX9/BX116 would bring. The doctors' surgery is always packed (the new one proposed for Barnhorn Green having been abandoned), the school is over-subscribed and there are no secondary schools nearby.

It is a widely held view across the whole Bexhill district that the A259 is wholly unsuitable for the traffic levels passing through Little Common and Bexhill overall. Much of it is through traffic which must use the A259 as the only major east-west route along England's south coast. If anything, the new Bexhill-Hastings Link Road has added to traffic pouring through Little Common as it provides an improved route for traffic aiming to bypass St. Leonards and Hastings (partially). The much talked about Bexhill bypass comes to mind in this context - linking the NBAR to the A259 west of Bexhill would alleviate some of this traffic, not to mention bringing a huge area for further housing and business development into play.

There are few local (in Little Common) employment opportunities for the envisaged residents of Barnhorn Green, not to mention BX116, so it can be certainly assumed that these working residents will use their cars to go to/from work and that parents will drive their children to the (overloaded) Little Common school or elsewhere. Surveys have shown that the A259 is already carrying traffic levels which were forecast not to be reached until 2028.

We have learnt that no recent air pollution monitoring has been taking place along the A259 in Little Common (though a lamp-post mounted unit is soon to be installed). The lack of any current knowledge of existing air pollution levels is disturbing, given that RDC has already approved substantial new development projects in the area and is anticipating even more - without apparent regard for this serious, health-related issue, and doubly serious considering the increased proportion of children these proposed developments might bring to the area. It is already planned that traffic lights be installed on the A259 for an entrance serving Barnhorn Green which will create yet more standing traffic along that busy road.

The northern end of Cooden Sea Road is currently a free-for-all illegal car park, while the Pay & Display car park behind St Martha's church stands mostly empty, and this is before Barnhorn Green comes into being. Even more housing development in this very congested area will make life insufferable for residents, both current and future. Enough is enough.

Development creep

We have concerns about the longer-term risk of "development creep". BX116 lies adjacent to other sites which were considered for development (BX51, BX109, BX115 & BX61). These have been ruled unsuitable, often due to recognised flood risk (uncontrolled drainage from BX116?) and for the sake of views from elsewhere in the area, mainly from the west and so judged to be "out of character" with the local area. We believe that the current assignment of these sites to the unsuitable category would be put in jeopardy if the BX116 development took place. There would certainly be further pressure from land-owners and developers keen to cash in on the sprawl that an extended development south of Barnhorn Road would facilitate. If BX115 and BX108 are precious and worthy of protection to preserve the area's "character", then so too should be BX116. As they say in the sales: When it's gone, it's gone.

The Spindlewood Action Group - SPINDAG - has conducted extensive research, held public meetings and surgeries amongst local residents and found the vast majority of respondents to believe this proposed development to be wholly unnecessary and undesirable. We ask that it be removed from the second DaSA consultation process and not to be considered for any future development.