Re: Rother Development and Site Allocations (DaSA) Local Plan

As residents of Fairlight Cove we wish to make the following comments on the unsoundness of the DaSA Local Plan in so far as it relates to Fairlight and Fairlight Cove, East Sussex. We have answered the consultation online but yet again the amount of space provided for comments is grossly inadequate (only 200 words!) - hence this letter. We object to the DaSA Local Plan in so far as it impacts upon Fairlight and Fairlight Cove.

1. Our key objection is the inconsistency of the policies set out in this document, which on the one hand recognises the unique character of this locality and the fact that it is within the designated High Weald AONB, while recommending the construction of 30 new houses within that same AONB area.

2. Section 6 Environment Policy DEN 1 states that new development m the High Weald AONB must make a positive contribution to the landscape character of the area in which it is located. DEN 2 says that development should be small scale, in keeping with the landscape and settlement pattern. Major development will be inappropriate except in exceptional circumstances. DEN 3 states that any development must be unobtrusive and not detract from the openness of the area.

3. All these are sensible and reasonable considerations against which to judge the proposals for Fairlight Cove.

4. However, the plans for Fairlight Cove in Section 1 1 do not meet these tests and are not in keeping with the landscape and settlement pattern:

(1) The Core Strategy from 2014 suggests that 37 new dwellings should be built in Fairlight "from large sites".

(2) The first site identified in the DaSA is the Market Garden site where outline planning consent, subject to conditions , has been granted by Rother DC for the construction of 16 dwellings. That site is at least within the village settlement area and close to local facilities. It does not impact on the surrounding countryside, (see 11. 108)

(3) The second site now identified at 11. 109 is the East Field for the remaining 21 new dwellings. It is acknowledged that this site is not within the existing settlement area and encroaches on the AONB land. Construction will also lead to the loss of good agricultural land. The proposed development threatens the beauty of the area and the loss of invaluable country views, flora and fauna. It will certainly not conserve and enhance the AONB landscape.

(4) The use of this site totally contradicts each of the Rother Environment policies DEN 1, DEN 2 and DEN 3.

(5) Paragraph 11. 109 of the report goes even further in disregard of these policies by stating that the site can accommodate some 30 dwellings - nine more than even the Core Strategy suggested. This is misconceived. The report lacks robust and credible evidence to justify this conclusion. No substantial reasoning is set out for this expansion in the number of proposed dwellings.

(6) The actual facts are as follows:

(a) There is no shortage of housing in Fairlight. By reason of the age of much of the population (many of whom are retired and elderly) there is a constant turnover of housing. There is therefore no development or infrastructure requirement.

(b) There can be no justification for building outside the existing settlement boundaries in the AONB land as that will unquestionably detract from the views and openness of the area and cause serious damage to the local environment. Paragraph 11. 121 recognises that the development of this site "will need to conserve and enhance this designated landscape". But there is no way that that can be done.

(c) Surface water drainage is a major problem throughout Fairlight - as acknowledged in Paragraph 11. 126. The East Field site is subject to flooding.

(d) There is very serious lack of capacity in the existing drainage and sewerage system in and around Fairlight Cove. This is very well known to Rother DC and Southern Water. The system at present cannot cope with large volumes of water generated by rainfall. The DaSA does not hide this but does not explain how these problems will be overcome. Indeed, Paragraph 6.59 states that the Fairlight /Pett Level area has been recognised as an area of drainage concern. The report acknowledges the wider drainage capacity concern. Further it recognises that East Sussex County Council has even been considering identifying the village as an Area of Critical Drainage Concern in East Sussex.

(e) These drainage and sewerage issues are not addressed properly in Section 11 of the DaSA in the plans for new dwellings in Fairlight Cove on the East Field site. There is no explanation or consideration as to when and how the sewerage system and local plant will be expanded and upgraded to take account of the increased usage, There is no analysis of how this cost will be met. Building on agricultural land in an AONB is not consistent with national planning policies.

(f) Transport difficulties have also been overlooked to a large extent. The East Field site is located off the Battery Hill/Pett Level Road, a narrow C class road which has "tight bends, steep gradients and poor visibility in places" - see paragraph 11. 101. That is a considerable understatement. The site would have only a single access near a blind comer on to the Pett Level Road. The new homes will generate even more congestion than exists at present. There are no plans to improve the roads or the bus services. Dangers to existing road users, including pedestrians and cyclists, are already an issue in the local community.

(g) The suggestion that the development is necessary to accommodate a new doctors' surgery is again flawed. Why cannot a surgery be located within the existing village? A surgery is already held at the Village Hall. You do not need to expand a village in order to build a new surgery.

(h) There is no logical basis for building outside the boundaries of an existing village, where there is no actual demand for new housing, where there are no employment opportunities and where the drainage facilities and sewerage system can barely cope with the existing population. The fact that the area also has very poor communications reinforces these points.

(i) No account has been taken in the DaSA of how the children living in the expanded village are to be educated. There is no spare capacity in the local junior schools, which are already over-subscribed.

(j) Logically, new housing developments within Rother should be close to population centres and in areas which have good communications, job opportunities and adequate education facilities. That must be the rational way to proceed. Expanding Fairlight by cutting into the East Field is not the answer the local authority's housing needs.

We object strongly to these plans for development in Fairlight Cove. In this respect the DaSA is unsound and deeply flawed on each of the four grounds of soundness.

We would be happy to elaborate on these objection at any public inquiry or investigation by the Planning Inspectorate.

Yours sincerely
Dr Ruth Kosmin
Leslie Kosmin