MOD 8.1

I object to the proposal to remove the provision for a new train station next to Ravenside for the following reasons:

1. It conflicts with RDC policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport;

2. It conflicts with RDC policy TR2 which commits the council to making 'Improvements in the availability, quality and efficiency of sustainable transport';

3. It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions

I object in the strongest possible terms to the I object to the deletion of 8.1 para Vb

DELETED: provision for a new railway station adjacent to Ravenside Retail Park;

The Council have made this decision based on a short-sighted and limited report from consultants. The consultants have not assessed the importance of this infrastructure in helping residents in Rother to reduce their future dependence on their cars.

A train station at Glyne Gap would help alleviate road traffic congestion in the area by allowing shoppers at Glyne Gap to use train instead of road transport.

The revised feasibility study conducted by Mott MacDonald seems to me to be seriously flawed; the study is based on 1 train per hour compared with the 2004 study that was based on a service of two or four trains an hour. Obviously a 1 train per hour service is much less attractive for shopping trips. It seems to me that what is needed is a turn-up-and-go, cheap, efficient, accessible, 'metro' service, but the study didn't look into that possibility.

Removal of plans for the new station conflicts with RDC's responsibilities under the Climate Change Act 2008

This railway station was promised as part of a 'String of Pearls' light rail network to connect Ore with Bexhill, including another station where Poundstretcher etc is on Bexhill Road, with, as far as I remember, abuot 4 trains an hour. This was during the redevelopment plan of the region, consulted with Seaspace at a large amount of government funding, to devise a sustainable and ecological way forward for the region. To now denounce this and in effect 'pretend it never happened' by removing it from the local plan, is an absolute disgrace and flies in the face of all the promises, made with the local population, shops and ecology in mind, which, at the time attracted a lot of local support and goodwill. Now it is obvious that these promises were made simply to justify all the consultancy fees, that Rother/HBC never had any intention of building this much needed light rail network which, apart form anything, would have helped the people living on Bexhill Road by reducing local traffic - something which no link road will ever do. It is also denying suitable and what hopefully would have been cheap and frequent transport to good shopping areas for people who don't have cars apart from encouraging people with cars not to use them. Not only should this clause not be removed from the local plan but Rother should be made to stick to their original plan and build this station along with the light rail network as originally devised.

Deleting this modification is contrary to RDC's responsibilities under the Climate Change Act 2008, in which it commits to "promoting more sustainable transport patterns in accordance with transport policy TR2."

Removal of plans for the new station conflicts with RDC's responsibilities under the Climate Change Act 2008 (which aims to reduce greenhouse gas emissions by at least 80% by 2050) and also with its own policies on carbon reduction and sustainable transport:

Policy SRM1: Towards a low carbon future

'The strategy to mitigate and adapt to the impacts of climate change is to:

vii. Promoting [sic] more sustainable travel patterns in accordance with transport policy TR2, and through widespread fast broadband coverage.'

Policy TR2:

'All development shall, wherever reasonably practicable, be carried out in a location and manner which will promote more sustainable travel choice. Applications for planning permission may be required to demonstrate how the proposed development will promote sustainable travel choice.

Improvements in the availability, quality and efficiency of sustainable transport opportunities including quality bus routes, cycle networks, priority for pedestrians and related facilities will be sought, including through supplementary guidance and in the determination of planning applications.'

The building of this proposed new railway station has long been seen as essential to easing traffic congestion at Glyne Gap (all the more so with the building of a major new M&S store at Ravenside) and is also consistent with the council's responsibilities under the Climate Change Act 2008, regarding sustainable transport.

8.1 (v) (b) Keep the Glyne Gap station. I want more sustainable travel. I also want better provisions for cycle and pedestrians and better bus routes. I want carbon emissions reduced and especially I want car use reduced (cars are the bane of my life!)

I object strongly to the deletion of a provision of a station at Glyne Gap. It is much needed. I don't have a car and the bus stops are inconvenient, quite a long walk from the centre, if one is carrying heavy items (such as a printer) whereas the rail line is just behind. To delete such a provision is an outrage when you are supposed to be mitigating the effects of greenhouse gases. The Link Road and more car dependent housing will exceed carbon emissions. This proposal runs contrary to your own policies towards a low carbon future.

This is a backward step. For a relatively small sum of money RDC should be investing in this station to cater for the ever-growing retail park at Ravenside and the residential developments that will come about in this area as a result of the link road.

I object to the deletion of a provision for a new railway station adjacent to Ravenside Retail Park.
This is because the study concluding there was poor value for money in the scheme was based on one train per hour in either direction serving the station whereas there are actually three trains per hour currently passing through the Ravenside Retail Park area.

I object to the deletion of the proposed mainline station at Glyne Gap. The people of East Sussex, particularly those who travel along the coast, are concerned about the increase in road traffic. The deletion of a station a Glyne Gap will result in time in increased road traffic travelling along the coast to the shopping area and an alternative travel option of rail will no longer be available. I am disappointed at the shortsightedness of Rother District Council by deleting this important facility. The linked rail travel 'the string of pearls' is long overdue.

I wish to object to deletion of the rail station adjacent to Ravenside Retail Park. This development is long overdue - the string of pearls rail link. The rail station will increase connectivity between the towns along the coastal route of East Sussex and alleviate road traffic on this route. Rother DC and the County have a responsibility to ensure that the traffic needs of the County and the area along our South Coast are taken account of and that from an environmental point of view we decrease as far as possible the numbers of cars on our roads.

Comment on Rother District Local Plan: Main Modifications to the Proposed Submission Core Strategy. Chapter 8: Bexhill modification 8.1: Delete part (v) (b) of Policy BX1: 'remove provision for a new railway station adjacent to Ravenside Retail Park'.

I object to this modification for the following reasons:
1. It conflicts with RDC policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport.
2. It conflicts with policy TR1 which commits the council to making 'improvements in the availability, quality and efficiency of sustainable transport'
3. It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions.
Proposed change to the plan: Rother District Council should reinstate the policy and continue to pursue the objective of building a new station at Ravenside Retail Park.

I also note that a station at Glyne Gap is an aspiration specified in the East Sussex County Council Local Transport Plan 3 (LTP3) - 4.18 and 4.52.

A new station would also strongly enforce an be highly compatible with all the 'Transport Specific Objectives' and 'High Level LTP Objectives' described in Table 1 of 2.6 of LTP3.

The 'Transport Specific Objective' with the highest score in the table 'Acces to jobs, services and lesiure' - would be strongly reinforced by a new station: it would be available to all, including 'persuadable' car drivers - those willing to consider a mode shift to a high quality available alternative. The station would therefore have a high 'social equity' component.

The study used by RDC assumes that only 1 train per hour would stop at the proposed new station, whereas new signaling currently installed would, in fact, allow an increase to 2 trains per hour to stop, which increases the viability of the proposition.

I wish to see the Core Strategy retain provision for a new railway station adjacent to Ravenside Retail Park.

Mod 8.1 Policy BX1 (v) (b)
The decision to delete the provision for a station at Glyne Gap adjacent to Ravenside is unsound and unjustified. Sustainable transport links must be included in any long term plan, particularly to lock in the benefits of the link road.
Ravenside is shortly to see the opening of a new Marks & Spencers attracting more visitors. Not all have cars. The study which came to this conclusion was not made public and ignored the fact that new signalling is being installed before the end of the year allowing more trains per hour.

1. It conflicts with RDC policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport;
2. It conflicts with RDC policy TR2 which commits the council to making 'Improvements in the availability, quality and efficiency of sustainable transport';
3. It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions.

1. It conflicts with RDC policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport;
2. It conflicts with RDC policy TR2 which commits the council to making 'Improvements in the availability, quality and efficiency of sustainable transport';
3. It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions.

1. It conflicts with RDC policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport;
2. It conflicts with RDC policy TR2 which commits the council to making 'Improvements in the availability, quality and efficiency of sustainable transport';
3. It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions.

We object to this modification for the following reasons:
1. It conflicts with RDC policy SRM1which seeks to mitigate the effects of climate change by promoting sustainable transport;
2. It conflicts with RDC policy TR2 which commits the council to making
'Improvements in the availability, quality and efficiency of sustainable transport';
3. It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions.

Further reasons for objection:
We note that a station at Glyne Gap is an aspiration specified in the East Sussex County Council LocalTransport Plan 3 (LTP3) - 4.18 and 4.52.
A new station would also strongly reinforce and be highly compatible with all the Transport Specific Objectives' and 'High Level LTP Objectives' described in Table 1 of 2.6 of LTP3 (Below).
The 'Transport Specific Objective' with the highest score in the table - 'Access to jobs, services and leisure' - would be strongly reinforced by a new station: it would be available to all, including 'persuadable' car drivers - those willing to consider a mode shift to a high quality available alternative. The station would therefore have a high 'social equity' component.
The study used by RDC assumes that only 1 train per hour would stop at the proposed new station, whereas new signaling currently being installed would, in fact, allow an increase to 2 trains per hour to stop, which increases the viability of the proposition.

We object to this modification for the following reasons:
1. It conflicts with RDC policy SRM1which seeks to mitigate the effects of climate change by promoting sustainable transport;
2. It conflicts with RDC policy TR2 which commits the council to making
'Improvements in the availability, quality and efficiency of sustainable transport';
3. It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions.

Further reasons for objection:
We note that a station at Glyne Gap is an aspiration specified in the East Sussex County Council LocalTransport Plan 3 (LTP3) - 4.18 and 4.52.
A new station would also strongly reinforce and be highly compatible with all the Transport Specific Objectives' and 'High Level LTP Objectives' described in Table 1 of 2.6 of LTP3 (Below).
The 'Transport Specific Objective' with the highest score in the table - 'Access to jobs, services and leisure' - would be strongly reinforced by a new station: it would be available to all, including 'persuadable' car drivers - those willing to consider a mode shift to a high quality available alternative. The station would therefore have a high 'social equity' component.
The study used by RDC assumes that only 1 train per hour would stop at the proposed new station, whereas new signaling currently being installed would, in fact, allow an increase to 2 trains per hour to stop, which increases the viability of the proposition.

We object to this modification for the following reasons:
1. lt conflicts with RDC policy SRM1which seeks to mitigate the effects
of climate change by promoting sustainable transport;
2. lt conflicts with RDC policy TR2 which commits the council to making
'Improvements in the availability, quality and efficiency of sustainable transport';
3. lt conflicts with RDC's responsibilities under the Climate Change Act
2008 to take action to reduce carbon emissions

Further reasons for objection:
We note that a station at Glyne Gap is an aspiration specified in the East Sussex County Council
Local Transport Plan 3 (LTP3) - 4.18 and 4.52.
A new station would also strongly reinforce and be highly compatible with all the 'Transport Specific Objectives' and 'High Level LTP Objectives' described in Table 1 of 2.6 of LTP3 (Below). The 'Transport Specific Objective' with the highest score in the table- 'Access to jobs, services and leisure'- would be strongly reinforced by a new station: it would be available to all, including
'persuadable' car drivers- those willing to consider a mode shift to a high quality available alternative. The station would therefore have a high 'social equity' component.

A Table submitted with the representation can be found here: http://www.rother.gov.uk/CHttpHandler.ashx?id=20674

Additional comments on the recent study by Mott McDonald:
A new station serving this busy and growing shopping and leisure centre on the A259 has always been a popular idea: we have been campaigning for the station since 1986 and at that time, had the support of several businesses on the site. This is an incomplete study that despite its popularity has not engaged with the public at all, and has been carried out with an air of secrecy: the study brief was only obtained through a Freedom of Information Act request. We note that the study:
* Worked on a 'one train per hour in each direction' assumption, so was set to fail;
* Failed to take into account increased passenger numbers arising from enhanced and complementary bus and cycle links;
* Over emphasized the importance of small time penalties against better reliability;
* Includes extra parking as a necessity where none is needed: it would undermine the bus and rail market;
* Didn't include consideration of prospective benefits or opportunities for a reduction in congestion;
* Failed to address the increased attractiveness of 'workplace travel plans' for local workers­
including those at Ravenside itself;
* Ignores the needs of all those seeking high quality alternatives to the car and attractive ticket offers, especially the young;
* Ignores the station's contribution to the ESCC Local Transport Plan objectives in respect of short car trips transferring to public transport;
* Doesn't examine possible alternative patterns of service or future infrastructure improvements that would be the determinants of success for Glyne Gap station; it fails to take account of the signalling upgrade operative from November 2013;
* Doesn't take a strategic view of the transport needs of Bexhill and Hastings- always considered together as a whole - and ignores potential demand management measures that would raise the 'value for money' performance of the station;
* Acknowledges the acute overcrowding on the 2 car Brighton- Ashford service but doesn't offer any solution;
* Leaves a question mark over whether all potential sources of funding have been explored.
At just 3% of the cost of the Bexhill to Hastings Link Road, Glyne Gap station would offer sustainable travel opportunities to a growing number of people- especially the young- who are declining the 'car habit'.
We urge you to reject proposals to adopt the above modification 8.1, policy BX1, in respect of a new station at Glyne Gap.

I wish to oppose the deletion of the new railway station at Glyne Gap from the planning for Bexhill, as this station would cost a fraction of the cost of the Bexhill link road and almost zero destruction of the environment. It would bring a much needed link for people to visit the shop at Ravenside too, particularly as the new Marks and Spencer store will attract more shoppers and money to the area.
The link road will not lessen the traffic to Ravenside but a station would.

MOD 8.: I object to this modification for the following reasons:
It conflicts with RDC policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport
It conflicts with RDC policy TR2 which commits the council to making 'Improvements in the availability, quality and efficiency of sustainable transport';
It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions.

I write to object this modification for the following reasons:

1. A railway station at this location is urgently needed to provide access for shoppers to the retail park, especially in view of the current significant expansion of retail outlets at the centre
2. A station at this location will provide easier and cheaper access for students at Bexhill College
3. Establishment of a railway station at this location will generally reduce the need for road traffic in this area
4. Such a modification conflicts with RDC policy SRM1 which seeks to mitigate the effects of climate change by promoting more carbon efficient transport options
5. Such a modification conflicts with RDC policy TR2 which commits the Council to making "Improvements in the availability, quality and efficiency of sustainable transport"
6. This modification conflicts with the RDC's responsibilities under the Climate Change Act 2008 to take all possible actions to reduce carbon emissions.

I write to OBJECT to the removal of plan for Glyne Gap station on the following grounds :

1. This station plan was identified in East Sussex County Council's LTP
2. The station would assist the important modal shift to public transport from cars
3. To remove this provision conflicts with RDC's responsibilities under Climate Change Act 2008 and its policies on carbon reduction and sustainable transport (see Policy SRM 1 and TR2)
4. What is needed is an accessible, turn-up-and-go, affordable, efficient 'metro' service
5. A previous study (2004) showed a 'strong economic case' for the station (based on two - four trains an hour)

Modification 8.1: Delete part (v)(b) of Policy BX1: 'remove provision for a new railway station adjacent to Ravenside Retail Park'.

We object to this modification for the following reasons:
1. It conflicts with RDC policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport;
2. It conflicts with RDC policy TR2 which commits the council to making 'Improvements in the availability, quality and efficiency of sustainable transport';
3. It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions.

Proposed change to the plan:
Rother District Council should reinstate the policy and continue to pursue the objective of building a new station next to Ravenside Retail Park.

Further reasons for objection:
A station at Glyne Gap is an aspiration specified in the East Sussex County Council Local Transport Plan 3 (LTP3) - 4.18 and 4.52.
A new station would also strongly reinforce and be highly compatible with all the 'Transport Specific Objectives' and 'High Level LTP Objectives' described in Table 1 of 2.6 of LTP3.
The 'Transport Specific Objective' with the highest score in the table - 'Access to jobs, services and leisure' - would be strongly reinforced by a new station: it would be available to all, including 'persuadable' car drivers - those willing to consider a mode shift to a high quality available alternative. The station would therefore have a high 'social equity' component.

The recent study by Mott McDonald on the proposed station was inadequate. Amongst many points, it failed to take into account increased passenger numbers from enhanced and complementary bus and cycle links. Glyne Gap station would offer sustainable travel opportunities to a far wider range of people than the ruinous Bexhill to Hastings Link Road link road, and at a small fraction of the cost.

We support the stance taken by the Campaign for Better Transport.

I object to this modification because the justification provided for it is unsound and it would conflict with national legislation and other policies in the local plan.

1. Unsound justification

1.1 The justification provided for removing provision for a new passenger rail station at Glyne Gap (the location of Ravenside Retail Park) from the Rother District Local Plan (RDLP) is that the most recent analysis suggests that the scheme offers poor value for money (Executive summary, Proposed New Passenger Station at Glyne Gap, Bexhill, Final Report, August 2013 - http://www.rother.gov.uk/media.cfm?mediaid=20676). This analysis is based on the assumption that it would only be possible for one train per hour to stop at a Glyne Gap station due to operating constraints.

1.2 According to the above report, operating constraints mean that westbound trains stopping at Glyne Gap would have to be integrated into the East Coastway service (Hastings to Brighton via Eastbourne) while eastbound trains stopping at Glyne Gap would have to be integrated into the service that runs from London Victoria via East Croydon, Lewes and Eastbourne to Hastings. Operational constraints are said to include interaction with other services at Bo Peep Junction (to the east of Glyne Gap) and on the Brighton Main Line. In particular, the report claims that while the eastbound service could accommodate two trains per hour stopping at Glyne Gap, the westbound service could only accommodate one train per hour within current timetables.

1.3 By default, the above report assumes that operational constraints will not change in the future. However changes to the signalling system between Eastbourne and Bo-Peep junction are currently being implemented. The Network Rail document "Network Rail Route Specifications 2011 - Sussex" (attached - http://www.rother.gov.uk/CHttpHandler.ashx?id=20676) states on page 30 that signalling improvements between Eastbourne and Bo-peep junction are planned for 2012-13. That these improvements seem to be coming in on schedule is obvious to train travellers, who can see new signalling equipment waiting by the track. The aim of the new signalling is to improve performance and journey times. More trains will be able to run on the track between Bo Peep Junction and Eastbourne. So these improvements will make it easier to accommodate more than one train per hour on the eastbound service stopping at Glyne Gap.

1.4 With two or more trains per hour stopping at Glyne Gap value for money would markedly improve, as previous analyses have shown. These are listed in table 1.1 of the document Proposed New Passenger Station at Glyne Gap, Bexhill, Final Report, August 2013.

1. 5 Moreover it must be recognised that it is inclusion in a plan which is being considered here, not a decision whether or not to build a station. Some operational constraints are already changing, and it is quite possible that other constraints may also change in the future. Therefore the correct way for Rother District Council to treat this matter is in terms of a range of scenarios. It is already admitted that under different assumptions (that is, a different scenario) a station at Glyne Gap could be viable (para 1.4). As long as this is the case provision for this station should remain in the Rother District local plan.

2. Conflict with national legislation

2.1 Under the Climate Change Act 2008 Rother District Council has a responsibility to take action to reduce carbon dioxide emissions. Provision of a station at Glyne Gap has the potential to reduce carbon dioxide emissions by enabling people to travel by train rather than by car, and so enabling such provision by including it in the Local Plan is an action that Rother District Council ought to take.

3. Conflict with other Rother District Council policies

3.1 This modification conflicts with Rother District Council policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport, and with Rother District Council policy TR2 which commits the council to making 'Improvements in the availability, quality and efficiency of sustainable transport'. Trains use fossil fuels more efficiently than cars, and so train travel is more sustainable than car travel. By removing provision for a station at Glyne Gap Rother District Council would be taking an action that conflicts with both these policies.

The deletion of this provision flies in the face of evidence which has been made available in relation to the BHLR. Stopping trains will not harm timetabling. There will be a clear need for such given the growth in shopping provision at the site and evidence from rail use in a similar situation at Meadowhall would suggest it is a valuable public utility and extremely sustainable.

MOD 8.: I object to this modification for the following reasons:
It conflicts with RDC policy SRM1 which seeks to mitigate the effects of climate change by promoting sustainable transport
It conflicts with RDC policy TR2 which commits the council to making 'Improvements in the availability, quality and efficiency of sustainable transport';
It conflicts with RDC's responsibilities under the Climate Change Act 2008 to take action to reduce carbon emissions.