QUESTION 27: Do you agree with the preferred sites for housing development at Bexhill? If not, which site(s) should be preferred?

I am very disappointed to see the number of sites listed for Bexhill and the extent of the development. Little attention seems to have been given to the semi-rural nature of many parts of Bexhill - particularly on its northern and western fringes. There has been no attempt to protect the character of these areas - in particular, the former De La Warr Estate in Cooden - broadly to the north of the Cooden Beach Golf Course - should be formally designated as a conservation area.

In terms of the sites listed, it is difficult to argue against the use of BX101 (the former Northeye Prison), although it is moot whether this should be for housing or for other development. All the other sites that run close to Barnhorn Road involve urban sprawl over rural locations, causing significant loss of amenity.

No less importantly, it is already clear that the A259 in the mile or so to the east of the Little Common roundabout is at peak capacity. Nor is there the other infrastructure to support the significant additional housing capacity.

I have the strongest objection to the proposed development of BX116. Not only would it mean the loss of green fields, at a stroke it would move the urban boundary of Bexhill closer into the Pevensey Levels that the development plan says it wishes to protect.

Given the investment of so much Government money in the Bexhill-Hastings Link Road, and the existing commitments to mixed use development along the route, I believe that North Bexhill (BX124) represents the least worst of the sites, although even this presents challenges to the Little Common roundabout as considerable additional traffic can be anticipated along Pear Tree Lane and St Mary's Lane.

QUESTION 27: Do you agree with the preferred sites for housing development at Bexhill? If not, which site(s) should be preferred?

I do not agree with the proposal of Spindlewood Drive (BX116) as an option for potential housing development.
I believe there are more suitable areas in Bexhill that would cope better with a development of this size.
Any development around Spindlewood Drive should be on a much smaller scale and in keeping with the surrounding housing, similar to the developments that have taken place over the years, namely Hazelwood Close, Old Harrier Close and Spindlewood Drive itself. All these developments were very much in keeping with the surrounding area with housing that has been of high specification, and has also met the needs of the local population. Proof of this being that they have all been marketed, sold very easily, and continued to do so.

Another reason why I do not agree is because Barnhorn Green has been given approval for a development of 342 dwellings. Bexhill has not seen a development on such a scale for some years and the effects such a development would have on the surrounding area. To have another development within such close proximity to this, going ahead at the same time, would be a huge strain on both the main and access roads. This is not only at the time of commencement of the building development, it will continue until its completion. A massive upheaval for all local residents and general road users.

Since the new link road was built (Coombe Valley Way), Barnhorn Road has changed. The traffic has escalated and congestion at Little Common, where the A259 from Hastings meets the roundabout, is immense and not only at peak times. It will be interesting to see if the traffic lights proposed on the A259 at Barnhorn Road ease traffic flow, therefore allowing local residents to access the main road and travel around without issue.

Any further development would certainly over develop the area and there is not the infrastructure to cope with the high volume demands of all this. There is not the infrastructure of schools, or local doctors surgeries to cope with such a large dynamic change to Little Common. The schools and doctors surgeries are overflowing and are not coping with what they have in place at this time.

I would however, agree with the development of North Bexhill, BEX3. The proposal of the preferred Option 1, which includes plans for 450 dwellings, has the infrastructure. Some of this is already in place with the new link road, and the development plans include a school, a doctor's surgery and local shops. There is also the potential to develop this further in the future (Options 2 and 3).

David Poynter and Joan Pullen consider the proposed development at the rear of
Spindlewood Drive is unsuitable due to the lack of suitable infrastructure, which includes the lack of suitable local employment, the road network, the local education facilities and the doctors practise.

The site at North Bexhill Access Road (NBAR - BEX3) site ref BX124 would appear to be far more suitable as the infrastructure already in place for the new housing will lead to far less impact on the traffic on the A259, has employment areas much more easily accessible, has secondary education facilities much closer and 2 GP surgeries rather than just the one.

One recognises that Bexhill would benefit greatly from enhanced economic development. Whilst the sea front and areas of west Bexhill are quite delightful, the town centre and other areas are decidedly run-down. The town and whole Rother district needs significant investment especially in transport infrastructure if we are to attract new employers, and their employees, into the district.

But with roads and other essential infrastructure, RDC is putting the cart before the horse. Develop the infrastructure first, then housing and business development. Let's have it, bring it on, we need to revitalise Bexhill but get the planning in the right order, please.

With regard to the sites proposed for development at some stage in the future I have these comments:

It is appreciated that central government is placing local authorities under great pressure to meet remotely-set housing targets. Whilst RDC cannot ignore these mandates it must keep in mind that its foremost duty is to protect the interests of its local communities and their quality of life. We rightfully expect our councillors and their staffs to robustly defend local interests and not become the submissive servants of distant political masters (and mistresses).

With regard to housing targets is it essential that RDC is open and honest with its residents about the overall planning aims, numbers of properties demanded and proposed, and the rationale for site assessments. We all would like to be assured that RDC's arithmetic is correct and is openly presented to the public. I understand there are some concerns about the numbers presented as future requirements and their reconciliation with already permitted developments, windfall developments and so on. So, please ensure that the primary aim is to serve the interests of RDC residents whilst paying regard to government pressure.

There is great variation in the nature of some of the proposed sites. Some in Bexhill town look to be very well-suited to redevelopment: those on Terminus Road (BEX8), Drill Hall (BEX4), Gullivers Bowls Club (BEX5). Each of these could be low impact and highly beneficial for new residents coming to them.

Those for larger developments deserve more careful consideration.

The BX124 NBAR development has the scope to be an exciting and extensive new development where there is great scope for the proposed numbers of properties and more, in certain areas. See my comments on Q29 for some elaboration on this subject.

The same could be said for the BX101 Northeye brownfield site, which also offers open space and flexibility in its design, also offering scope for expansion. This derelict brownfield site is just the sort of place we should be seeking to redevelop, it would enhance the immediate local area and save green space where possible.

Overall though, the DaSA plan highlights need for a northern bypass for the Little Common area - linking the NBAR across to the west to join the A259 near the Lamb Inn. Some proposed developments, such as BEX9/BX116 only threaten to further overload the A259 and the limited local services of Little Common. I am, therefore, opposed to BEX9/BX116 in its entirety and state my reasons in depth in my answer to Question 35.

Whilst I do not doubt that Rother Council is under pressure from the Government to create additional housing in this area I do not believe that this should be implemented without at least a little common sense being used when proposing areas for development.

The Spindlewood Drive development is both inappropriate and unnecessary as there is already agreed substantial development in the area - more than the local infrastructure can sustain.

1: Little Common's infrastructure - roads, shops, parking, environment-already due to be increased due to the Barnhorn Green Development(BX120) simply could not cope with an additional 160 houses in Spindlewood Drive. (BEX09) and North Eye (BEX101).The additional traffic created on Barnhorn Road and surrounding roads would be unsustainable It is currently over stretched at bottle necks such as the Little Common roundabout, and will be made worse by additional traffic lights at Barnhorn Green despite the pathetic ally weak response from the Highways Agency and their feeble "improvements" suggested.

2: There is no employment in the area - anyone needing to work (most presumably) would have to travel by car or bus with the obvious detrimental effect on the local environment.

A more suitable site would appear to be The Bexhill North Access Road (NBAR BEX3) which would have better road access and would be closer to other facilities such as schools, G.P's , shops and rail transport. Further it would have far better access to major roads such as the A21 and would relieve pressure on the A259.

For these reasons (and a host of others) Spindlewood Drive should be excluded from the plans as it is both unnecessary and impractical.

Although I appreciate the need for additional homes in Bexhill and government pressure on RDC, any further development in Little Common would be entirely unsuitable for the following reasons:

1. The local infrastructure is already struggling to cope. The GP surgery is nearly full, there are apparently no vacancies at the primary school, there is limited room for car parking and traffic on the A259 is already running at close to capacity with frequent serious congestion.

2. The new development planned at Barnhorn Green and other potential developments will exacerbate this situation and make matters even more difficult for Little Common residents.

3. A further 160 home development at Spindlewood Drive BX116 would lead to an unmanageable increase in traffic along the A259 and through Little Common as a further 300 or so cars emerge at peak periods carrying people from this new development to work or school.

4. Access to BX116 would be down Meads Road and Spindlewood Drive. These are minor residential roads incapable of coping with a huge increase in traffic. Meads Road is already congested with parked cars which require drivers to negotiate their way up and down the road which is invariably just a single lane.

Given that more residential development has to take place, I urge RDC to look more closely at more suitable sites. The most appropriate would be BX124 on the NBAR. The advantages would include:

1. Far better access to schools, GP surgeries, Conquest Hospital, the A21, shopping facilities and more accessible railway services at Bexhill and St Leonards on Sea.

2. Easy access to and from BX124 via NBAR which would result in less traffic using the A259 to access the new link road from the west.

3. The site of BX124 would not impact on any existing residents nor detract from their overstretched infrastructure.

Conclusion

The proposed development at Spindlewood Drive BX116 would place an intolerable overload on all local services and amenities to the lasting detriment of current residents as well as new residents living in such a development. It would be far better to place this proposed development of 160 houses in BX124 where there is ample space, no strain on existing services and far better access via NBAR.

RE: BX116-LAND OFF SPINDLEWOOD DRIVE, BEXHILL - DEVELOPMENT AND SITE ALLOCATIONS PLAN

In response to the current consultation on the Rother Development and Site Allocations Plan (DaSA), please find below representations on behalf of the landowners of land off Spindlewood Drive, Bexhill, Rother District Council reference BX116.

We wish to commend the Council for the pro-active, collaborative and extensive amount of work which has been taken by Officers in respect of drafting this document and in particular the draft allocation put forward at the 'Land off Spindewood Drive'. A significant amount of survey work has been requested and reviewed by the Council, above and beyond the level of work often carried out in respect of site allocations documents.

Through the extensive pre-application discussions, advice and representations to the adopted Core Strategy Document, SHLAA and now the Development and Site Allocations Document it has been established that the proposals benefit from:

* An agreed access point into the site and all highways matters agreed with Highways England and East Sussex County Council;
* Natural screening provided by established boundary planting which will be maintained and enhanced by the scheme, ensuring that all views of the site and neighbouring amenity are maintained and protected, resulting in an attractive and aesthetically pleasing development;
* Nature enhancements including tree retention, additional planting and green areas which will improve upon the biodiversity and sustainability of the site;
* Situated wholly within flood zone 1 which provides the lowest risk from flooding;
* A natural extension to the established residential area of Little Common;
* Extremely well linked to Little Common and the wider Bexhill area, with a number of public transport options available to residents including Cooden Beach train station which is a short walk from the site;
* All matters identified for consideration at the site, during pre-application discussions and the previous Rother SHLAA assessment (access and retention of tourist facility) fully resolved and agreed with Officers; and,
* No outstanding matters which will prevent the submission of a planning application and delivery of development at the site within the next 12 months.

In addition to the consultation through the emerging Rother Local Plan, Highways England and East Sussex County Council have been consulted, along with the Local Resident's interest group and Ward Councillor. We have sought and we will continue to incorporate comments where feasible, in order to ensure that the best possible scheme can be achieved in this location.

Rather than leave detailed survey work to the planning application stage, the three pertinent areas to development coming forward at this site, namely transport, ecology and indicative layout have been fully addressed and agreed, and indeed detailed transport and ecology reports have been published alongside the DaSA in respect of this site.

This approach ensures that any uncertainty over the minimum number of units that can be delivered has been fully addressed and that there are no outstanding issues that would delay the site coming forward in the short term. It should be noted that the amount of survey work undertaken and published alongside the DaSA consultation for land off Spindlewood Drive exceeds the information published for the other sites in Bexhill, demonstrating the suitability of the site and the commitment to deliver much needed local housing in the near future.

The completed ecological survey work identified that the site is of low ecological value and is developable for residential development as set out on the indicative masterplan for the site. All recommended phase 2 work has been undertaken, this has all been acceptable and confirms the conclusion that the site is developable. All recommendations have been taken on board and have shaped the proposals. On this basis, the proposals are entirely acceptable and indeed beneficial, from an ecological and nature perspective.

The transport work undertaken has been fully signed off by Highways England and East Sussex County Council, demonstrating that the scheme, proposed access solution and local highways network are entirely suitable for accommodating the development.

This front-loaded approach to survey work, will enable a future planning application to run smoothly.

In conclusion, there is certainty that this site has no outstanding issues and sustainable and beneficial residential development can be delivered in the short term. Therefore, we fully concur with the draft allocation for some 160 dwellings and Policy BEX9, for this site as set out in DaSA document.

The allocation of this site as well as other suitable opportunities, will not only assist in meeting housing targets, but will enable Rother District Council to ensure that much needed housing comes forward in sustainable locations; enabling the Council to resist potentially unsuitable sites being pushed forward which could create unsustainable patterns of development to the detriment of local communities.

In addition to the preferred development sites, we submit on behalf of the proposer Mr P Rusted, a residential site of Cesar House Eastwood Road Bexhill on Sea East Sussex TN39 3PS. Please see location plan edged red.

Like many of the other sites proposed to be allocated the site is a small scale brownfield site. Within the site is Cesar House, the former business premises of Oliver's Printers. The site is situated within an established residential area of the town. It was vacated in 2004 and has remained vacant ever since.

Historic Planning Position

Historically, in 1955 permission was granted to Grobex Limited to erect a warehouse / store and the building company used it to store materials. In 1977 permission was granted to Gardners Books to demolish the existing buildings and erect a warehouse that was subsequently used 24 hours a day as a store and distribution centre for books. The warehouse was further extended in 1990 but then became too small for Gardners' requirements and was sold to the Rusted family in 1995. In 1995 permission was granted to Olivers Printers Limited (the Applicant's father's company) to use the premises as a commercial printing operation and a change of use
from B8 to B1 was approved. The company closed in November 2004 and the site has been empty since then.

Details of the Site

The site is 0.27 hectares in size. It is accessed directly from Eastwood Road between the semi-detached houses of 14 and 16 Eastwood Road. The site has an unusual shape. Approximately three quarters of the site is covered by office and warehouse buildings. This covers the full width of the northern boundary and portion of the site. The southern area comprises of the hardstanding forecourt, vehicle manoeuvring and parking area. Access is along a non-adopted
private driveway between the houses and curtilage of number 14 and 16 on the eastern portion of the site.

The site is adjoined to all boundaries by the rear residential gardens of houses on Eastwood Road, Chandler Road and Little Common Road. The streets have a variety of styles from the Edwardian period, interwar, post war and modern times. The scale and massing vary from two to two and a half storey to full three storey flatted developments. There is therefore no fixed grain and pattern to the character of the area and new buildings have been introduced to full three storey height.

Principle of Development

The location of the site in a residential area, in a sustainable location, within the development boundary of Bexhill on a brownfield site means that the presumption in favour of development is very strong. The site will contribute towards the supply of housing and fully accords with the objectives of the NPPF and the Government's objectives for the redevelopment of brownfield sites in sustainable locations for housing. The principle of redevelopment accords with the existing Development Plan.


Details of the Planning Permissions and their limitations

The original commercial approval in 1977 was for a 1002, square metre warehouse with office for storage and distribution. This included the existing service access, the forecourt to the building for the manoeuvring of commercial vehicles and the parking for 21 vehicles. In 1990 the building was extended by a further 400 square metres. This 'B8' book repository use was operating 24 hours a day and deliveries were made by 40 foot long articulated lorries. The primary effects upon residential amenity was noise from the vehicles starting and manoeuvring within the site, exhaust smoke and light pollution from the lorries and other vehicles and noise from machinery being used within the building. It is very surprising, today, to start to contemplate why such a planning permission was ever granted in this residential location, particularly as there were no limitations imposed on the buildings time of operation.

Closure of the Employment Use

The 1995 planning permission for 'B1' Business Use of the site for the printing business imposed new limitations on the development in terms of the size of vehicles entering the site to 10 tonnes and the opening hours to 7 am to 7pm weekdays, 7 am to 1 pm on a Saturday and no use on Sunday or Bank Holidays. However, it was untenable for the business to operate in this way and a temporary consent was granted to extend these hours in 1996. A further request by the owner in 2001to increase the hours was not supported by Officers in pre application correspondence, because of the likely impact upon neighbouring residential amenity. The business was required to revert to the permitted hours. The new limitation on vehicle size, imposed by the Council on the size of lorries delivering and picking up from the site, meant that Olivers Printers was forced to buy paper in smaller quantities which resulted in an increase in vehicle movements and adversely affected the company's profits. The business was no longer sustainable under these limitations and closed in 2004.

Recent Planning Applications to the Authority

Subsequent Applications followed. In determining a 2006 application for specialist residential accommodation reference RR/2006/2609 the proposal was considered against Local Plan policy EM2 - Retention of employment sites and buildings. In the Officer report it was put to Members that because of the past harm to the residential amenities of local residents from delivery vehicles and that the site is surrounded wholly by residential properties, the Council accepted that as an employment site, it has severe limitations and in the circumstances an alternative lower key use would be supported. Officer Report page 4, reference RR/2006/2609/P relates. It is considered that the submissions made in 2006 as set out above weighed heavily in the planning balance for the Authority, resulting in a positive decision to support the principle of redevelopment of the site with a revised application reference RR/2007/2669/P, with a predominantly residential scheme. The permission was renewed in 2010, reference RR/2010/2523/P. By then the market had changed for Residential Care accommodation and the purchase of the site by the interested party did not proceed.

As a result of the Council's restriction on hours and use, it is clear that the Council accepted the residential nature of the immediate area and has taken considerable steps to discourage any attempt to improve the viability of the site for employment purposes, ultimately making it uncompetitive and redundant. This has been subsequently borne out in the results of the marketing of the site undertaken by Tingley Commercial' property consultants, which I enclose.
A recent Outline planning application for 19, C3 dwellings, reference RR/2016/280/P was withdrawn in June 2016. The evidence of the past planning history was submitted with the application along with the Marketing report. Officers raised no objection to the principle of development, however matters of density and Development Control issues relating principally to overlooking and car parking needed to be re considered. I confirm that a revised application to the Council, again for C3 Housing, will be made shortly. No other issues were raised during the processing of the application.

Conclusion

The Council is therefore respectfully invited to allocate the site given that it is a redundant
brownfield site, falls above the Council threshold of 6 dwellings / 0.2 hectares. The site is in a highly sustainable location and surrounded by residential housing and flats, has previously been granted permission twice to remove the existing employment use, that a Marketing report demonstrates that it is no longer viable as an industrial site and Officers have raised no objection in principle to a planning application made last year for residential development.

I confirm that I am instructed by Mr Rusted Land owner of the site. We are of the opinion that the site can accommodate in the region of 19 dwellings. The site is suitable for residential use rather than any other commercial employment use. The site is within the Development Boundary. It has no Environmental or Heritage Constraints. No third party land is required to provide access. There are no drainage issues with the existing use and a residential use will reduce the level of surface water discharge. No hedgerows or trees of any importance will be removed as a result of this development. There may be a very small level of asbestos within the building but no other contamination. The development would not require a culvert or redirecting any watercourse. All utilities infrastructure are present at the site. There are no ownership constraints to prevent the site coming forward and there is no requirement to relocate a current use. We would expect the development to come forward in 2019 to 2021 and take one year to complete.
M S Jackson BSc [Hons] Environmental Planning MRTPI



An expired planning permission for the redevelopment of the site with four bungalows and associated administration to provide accommodation and support for people with learning disabilities was renewed as a planning permission on the 21st December 2010. Application reference RR/2010/2523/P.

Additional supporting information was supplied which can be viewed here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28033

I write in regard to the Council's consultation process of the above draft plan. I would like to suggest the use of a plot of land to the front of our proprtery in Sandhurst Lane, Bexhill - coloured red on the attached plan.

Our property is located just to the west of the proposed Barnhorn Green development and our site has previously been assessed as being suitable for development at some future date.

The section of our land coloured red measures approximately 0.6 acre and is situated within a developed area. It is bounded to the south by an existing house. The Haven, to the east by our property, Fantails, and to the north east by an existing vehicle repair yard. On the west side of Sandhurst Lane is a further existing property, Chelwood.

A plan of the site can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28030

Site at Spindlewood Drive (BX116/BEX9) is inappropriate for development because of poor access through small side roads (often used for parking by residents and for local businesses) and inadequate local infrastructure to support such a large scale development (schools, GPs etc.). It will also have a significant effect on local wildlife and could adversely affect adjacent important wildlife sites .

The transport assessments of Little Common Roundabout seem unrealistic. I am still waiting for a response from transport England about assumptions made in the SATURN modelling but the developer lead ARCADY assessment in the transport note is farcical (no HGVs, no pedestrian crossings - there are 2, road capacities set at 99999 vehicles per hour and a current queue of 12 on Barnhorn road at peak times (often actually between 0.5 and 1 mile).

Other sites particularly BX124 and BX101 seem much better supported/ more appropriate and BX124 could be further expanded

Spindlewood Drive development (BEX09/BX116) is UNSUITABLE :-

Lack of infrastructure
Doctors and Schools at capacity
Lack of Jobs
Lack of Car Parking

The area around Little Common would not cope with an increase in large numbers of people, properties and certainly not the vehicles on the roads - there is already a large amount of congestion at the Little Common roundabout.

My understanding is that the alternative site ref BX124/NBAR would be more appropriate.

It has far better local amenities
Better likelihood of jobs nearby with more businesses and shops
Easy access to schools/surgeries/shopping/train station
Also good access to A21 and Conquest Hospital

I also understand from well-attended local meetings I have been to that there are many 'small site windfalls' which need to be taken into account in the area which would therefore render Spindlewood (BX116) development unnecessary.

I am writing to express my wholehearted objection to the inclusion of BX116 amongst the possible sites for new housing development.

1. I am not opposed to the concept of residential development within the Bexhill area and am conscious of the pressures Rother Council are under to provide a suitable number of properties to meet their target of 3100 by 2028.

2. The Spindlewood Drive development proposal (BEX09/BX116) is unsuitable primarily on the grounds of the lack of suitable infrastructure around the Little Common area. This concern does not just apply to BEX9 but also and equally to BX101 (Northeye).

a. Little Common is an old village which has insufficient infrastructure to support further large scale residential developments on top of the other developments that are either currently under way or proposed and which in total could amount to some 465 houses. Current and agreed developments around Little Common Village include Barnhorn Green (BX120 - 342 properties), the former Nat West Bank in Cooden Sea Road (RR/2015/3103/P - 8 properties), 45/47 Barnhorn Road (RR/2016/2430/P - 8 dwellings); potential developments include land adjacent to Ashridge Court Care Home, Barnhorn Road (BX50 - (RR/2016/3206/P - 31 properties)), the former Co-Op site in Cooden Sea Road (RR/2016/3254/P - 9 properties) and Sidley Sports Ground Glovers Lane (RR/2016/3127/P) - 65 properties.

b. As a village, the current infrastructure of Little Common Village simply will not cope with additional large numbers of properties and people. Little Common doctors' surgery is already close to capacity, there are no vacancies at Little Common primary school and there are no local secondary schools. There are little or no prospects of anyone finding jobs around Little Common Village and train services are only available at Cooden Beach, Bexhill town centre, Hastings or Eastbourne. Shopping at Little Common Village is limited so larger shopping trips will need to be made elsewhere. In addition, the A259 is already close to capacity with 900 vehicles per hour in both directions throughout the day and this situation will be considerably exacerbated by the installation of traffic lights at the entrance to Barnhorn Green, the zebra crossing to be installed at Kite Nests Walk let alone the additional traffic generated by the residents of Barnhorn Green.

c. Due to the lack of suitable infrastructure, virtually all traffic resulting from the above mentioned developments will need to use their cars to go to work, take children to school and go to large shopping centres. This is harmful to the environment and will generate additional noise and air pollution especially around the A259.

d. Currently, there are serious car parking issues around Little Common Village with frequent and blatant breaches of parking laws as people double park, park on double yellow lines or even on the pavement or verges..

e. Any further large scale residential developments in or around Little Common Village will thus tip the local infrastructure into a further state of crisis and must not therefore be permitted.

3. More Suitable Sites

a. There are far more appropriate sites to develop the properties proposed for Spindlewood Drive and Northeye. The most appropriate by far would be off the North Bexhill Access Road (NBAR - BEX3) - site ref BX124. Options 2 and/or 3 would be suitable (in addition to Option 1) due to the far better infrastructure availability for the residents and without serious detriment to the environment.

These include
i. Access to local jobs especially BX113 (with access directly off the NBAR) and Enterprise Way. Other job opportunities are also possible at St Leonards, Hastings and Bexhill and can all be accessed easily via Coombe Valley Way.
ii. Easy access to local schools including the newly proposed nursery and junior school in North East Bexhill as well as secondary schools all accessed via Enterprise Way.
iii. 2 GP surgeries are within easy reach at Bexhill old town and Sidley
iv. Good shopping facilities are provided and easily accessed at Ravenside, St Leonards and Hastings.
v. A 24 hour pharmacy is provided at Ravenside and Tesco Extra at St Leonards is also available for long periods.
vi. Train services are easily available at Cooden Beach, Bexhill and St Leonards Warrior Square without having to access the A259 (already running at close to capacity).
vii. Car access to all local areas is readily available via the NBAR and Coombe Valley Way and without needing to access the A259.
viii. The A21 and the Conquest Hospital are just a few minutes' drive away.

b. A second but far less suitable site would be BX101 (Northeye). This is a brownfield site so should be preferred over any greenfield site. The downside to developing this site for residential properties however, is the impact that the additional housing would have on Little Common Village's infrastructure including the A259.

4. The Spindlewood Site development (and others around Little Common Village) is superfluous
a. RDC has stated that it is not willing to take projected small windfall properties into account when estimating its target figure of 3100 for Bexhill. This is plainly wrong. RDC has a 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. Without taking the windfalls into account, RDC run the real risk of making decisions on development sites that need not be developed (such as BX116) in order for RDC to meet (and perhaps) beat their target of 3100. Consequently peoples' lives and quality of life will be irrevocably damaged forever based on a false premise. That would be both tragic and unforgivable.
b. Using the figures contained in RDC's Housing Land Supply document dated April 2016 and making allowance for projected small and large site windfalls over the period 2016 - 2028 as well as the recently proposed developments in and around Little Common as detailed in 2 a. above it is estimated that Bexhill will be able to achieve approximately 3315 properties by the end of 2028. This exceeds by 215 the target set by RDC of 3100 and excludes the following sites

i. BEX6 - Turkey Road
ii. BEX7 - Fryatt's Way
iii. BEX9 - Spindlewood Drive
iv. BX101 - Northeye

c. Consequently, these 4 sites should be removed from the second DaSA consultation process.

5. Conclusion

a. The town of Bexhill, within Rother District Council, is being required to take on too many residential developments to satisfy the Governmental requirement. This requirement should be spread more evenly throughout RDC.

b. The proposed development off Spindlewood Drive (as well as others shown above) is superfluous and inappropriate and would be highly detrimental to Little Common village as a whole.

c. Alternative sites are far more appropriate in terms of access to local infrastructure facilities and minimal environmental damage, especially the NBAR site (BX124)

d. RDC must take small site windfalls into account when estimating the likely numbers of properties to be achieved up to 2028.

e. Spindlewood Drive (BX116) can then be removed from the second DaSA consultation process as it will have become superfluous.

QUESTION 27: Do you agree with the preferred sites for housing development at Bexhill? If not, which site(s) should be preferred?

1. THE GOVERNMENT'S EMPHASIS AND URGENCY FOR THE NEED OF A CONSIDERABLY ENHANCED HOUSING STOCK IS NOT DISPUTED. HOWEVER, I CONSIDER BEX9/BX116 UNSUITABLE BECAUSE:

a. LITTLE COMMON LACKS THE SUITABLE INFRASTRUCTURE. BOTH THE LITTLE COMMON SURGERY AND PRIMARY SCHOOL ARE CLOSE TO CAPACITY AND THERE ARE NO LOCAL SECONDARY SCHOOLS. THERE ARE FEW JOB PROSPECTS OR OPPORTUNITIES IN THE AREA. IT HAS INADEQUATE ACCESS TO/FROM COODEN SEA ROAD/MEADS ROAD/MAPLE WALK.

b. IT WILL INCREASE CONGESTION ON THE A259 PARTICULARLY ON THE APPROACHES TO AND AT THE LITTLE COMMON ROUNDABOUT. THIS IS EXACERBATED AS THIS IS ON THE MAIN EMERGENCY ROUTE BETWEEN THE CONQUEST HOSPITAL AND EASTBOURNE D.G.H. AND SO CONSISTENTLY USED BY AMBULANCES. IT WOULD BE FURTHER EXACERBATED BY THE PROPOSED BARNHORN ESTATE AND THE BARNHORN ROAD TRAFFIC LIGHTS.

c. THERE ARE SERIOUS CAR PARKING ISSUES AROUND LITTLE COMMON PRECINCT WITH FREQUENT AND BLATANT BREACHES OF PARKING LAWS - PEOPLE DOUBLE PARK OR PARK ON DOUBLE YELLOW LINES. THIS HAS BEEN AGGRAVATED BY LOCAL EMPLOYEES WHO WORK NEAR THE JUNCTION WITH COODEN SEA ROAD AND PARK AROUND THERE INSTEAD OF IN THE PREVIOUSLY FREE CAR PARK (BX10) BEHIND ST MARTHA'S CHURCH. SO REVERT THE CAR PARK TO FREE USE OR ENFORCE PARKING RESTRICTIONS.

d. THE INCREASE IN TRAFFIC BETWEEN THE PEVENSEY ROUNDABOUT AND BEXHILL/HASTINGS WILL INCREASE BOTH THE USE OF NORMANS BAY/SLUICE LANE/HERBRAND WALK AS A SHORT CUT/RAT RUN AND THE CONSEQUENT INHERENT DANGERS.

e. THE MAPLE ROAD/SPINDLEWOOD DRIVE JUNCTION IS VERY TIGHT, PARTICULARLY WITH THE QUANTITY OF VEHICLES THAT PARK ON IT. NEAR COLLISIONS ARE A DAILY AND FREQUENT OCCURRENCE. ANY EXTRA VEHICLE MOVEMENT WILL MAKE THIS WORSE.

f. THE INCREASE OF TRAFFIC IN AND AROUND THE LITTLE COMMON ROUNDABOUT AND COODEN SEA ROAD WILL ENCOURAGE THE USE OF MEADS ROAD AND UNADOPTED MAPLE WALK TO BE USED AS A SHORT CUT/RAT RUN. THIS WOULD BE AT EXTREME INCONVENIENCE AND COST TO THE LOCAL RESIDENTS.

2. 1.A TO 1.F WOULD BE PARTLY ALLEVIATED BY ACCESS ON TO BARNHORN ROAD AS OPPOSED TO SPINDLEWOOD DRIVE.

3. THERE IS INADEQUATE INFRASTRUCTURE, PARTICULARLY POWER, WATER AND DRAINS. THESE WOULD NEED TO BE CONSIDERABLY ENHANCED.

4. THERE ARE INADEQUATE FACILITIES, E.G. SCHOOLS, G.P.'s, SHOPS.


5. THE EXTRA TRAFFIC WILL REDUCE THE AIR QUALITY AND WILL INCREASE POLLUTION CONTRARY TO GOVT STANDARDS.

6. EITHER BX124 OR BX101 WOULD BE A MORE SUITABLE SITE BECAUSE IN EACH CASE THEIR INFRASTRUCTURE AND LOCAL FACILITIES ARE BETTER AND, FOR THE FORMER, ITS ROAD AND RAIL CONNECTIONS ARE MORE ACCESSIBLE AND CONVENIENT.

7. CONSIDERATION SHOULD ALSO BE GIVEN TO THE FACT THAT THIS SITE WILL ENCROACH ON THE RAMSAR SITE.

In relation to BX116, Spindlewood Drive site:- I do not agree with your proposal to consider housing development on this site mainly due to the inadequate infrastructure in the surrounding vicinity of Little Common including poor traffic access into and out of the local roads and environmental and pollution considerations.

Surely more consideration should be given to increasing housing development beyond numbers already published in the area surrounding Site BX124, NBAR.

Use the access the new road presents to develop new housing sites and not try to squeeze a development into an area such as Spindlewood Drive which has none of the benefits that I believe could be made available at other sites such as BX124, the NBAR site.

I trust my comments will be taken into consideration when your deliberations commence.

NO

* Lack of Infrastructure, which is not sufficient to support Barnhorn Green and therefore not any further development.
* Another 160 houses would increase the current traffic problems for all those living in Little Common and those having to drive through it.
* Congestion: the roundabout is an unavoidable bottleneck, with 5 roads radiating from it which includes the A259 trunk road. At busy times for much of a weekday, traffic tails back for at least a mile along Barnhorn Road towards Little Common, with long queues in the opposite direction. During peak hours (7.15-9.15am and 3.45-6.45pm) that traffic is almost stationary.
* Barnhorn Green traffic lights: on 06/02/17, temporary traffic lights were on operation for the installation of a pollution-measuring meter. The work took place between approximately 10.00am and 3.30pm, during which time the traffic queue stretched 2+ miles from the Hooe turn-off to Little Common and from past the Denbigh towards Little Common in the opposite direction. When those traffic lights are permanent, it is highly likely this will be the norm throughout the day.
* Pollution & noise: this is already considerable from the many diesel-powered vehicles (large lorries, trucks, vans, buses, coaches, cars) which use Barnhorn Road. On 06/02/17, it was dangerously unhealthy.
* Meads Road: this is not a suitable road for vehicles to enter and leave Cooden Sea Road. Visibility when driving out of Meads Road is limited and it is therefore difficult to drive out safely.
* The A259 through Little Common is not a highway through a large city, it is a road through a village.

BX101 Northeye POSSIBLE BUT ONLY WITH A NORTHERN ACCESS ROAD BUILT FIRST
* This is a brownfield site which would be suitable for additional development provided the additional traffic would not add to that already on the A259.

BX124 NABR YES
* This area already has some of the required infrastructure nearby and will not have a major effect on the A259.There is room for additional affordable housing and a new school.

BX60 NO for the reasons given above for BEX9
BX50 NO ditto
BX61 NO ditto
BX115 NO ditto
BX108 NO ditto
BX47 NO ditto
BX48 NO ditto
BX49 NO ditto
BX52 NO ditto
BX120 NO but if already agreed, the application should be reconsidered

The Client wishes to put forward the following for consideration:

TQ7008-4192 Development & site Allocations Plan, Pond Field

Supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28062

The Client wishes to put forward the following for consideration:

TQ7209-7196 Development & Site Allocations Plan, St Mary's Lane

Supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28063

We consider the proposed development of site BX116 (Spindlewood Drive) to be unsuitable because:-

* The road system around the area is unsuitable for the expected increase in traffic generated by the development. The area is already congested and the inclusion of a further 320 minimum residents vehicles (most households now run at least 2 vehicles) plus the attendant service vehicles, etc will make the surrounding roads incredibly dangerous due to the limited parking on most of the access roads. Most of the roads in the immediate vicinity of the proposed access road are single carriageways due the resident and visitors parking.

* The proposed entrance to the development is unsuitable because it is off an already narrow road (Spindlewood Drive), is on a blind corner to vehicles approaching from further up Spindlewood Drive.

* The main artery road, the A259, is already heavily congested at peak times and also at many off peak times as well. The ongoing development of Barnhorn Green will further worsen this situation as will all the other minor developments that are currently planned for the Little Common area. We have already seen an increasing number of vehicles using Sluice Lane/Herbrand Walk as an alternating route to the A259, a road that is totally unsuited to any increase in traffic flow. This will also put an extra strain on minor roads in the area such as Cooden Drive, Maple Walk, Meads Road, etc.

* Meads Road in an unadopted road which already suffers from excessive wear and tear as it is used as a "rat run" for vehicles trying to avoid areas of existing congestion.

I strongly disagree that BEX9 / BX116 Spindlewood Drive should be considered as a preferred site for the Bexhill West Housing Options. This area is nowhere near able to handle additional developments on the scale as those detailed on the DaSa Local Plan for numerous reasons;

* Transport infrastructure. Looking at the Spindlewood Drive Transport Note document on your www.rother.gov.uk/dasa Related Documents section, I notice that this was based on a survey done in April 2015. It is now February 2017. Everybody, but everybody, agrees that the volume of traffic has increased at Little Common Roundabout and its approach roads. These figures do not include the Barnhorne Green Development, which we are told is going ahead with over 340 new houses. The effect of this alone will be catastrophic on the area's roads and are obviously not taken into account on your Transport Note facts and figures. The queue on the eastbound A259 Barnhorn Road to Little Common Roundabout approach road, anytime after 2.30pm, is often half a mile long, sometimes more. Not 12 cars at peak time, as stipulated on your report. The westbound A259 approach road is not much better. This volume of traffic is consistent, every day, including weekends. To reiterate, we have yet to see the effects of the extra traffic caused by the new Barnhorn Green development. Also, to go ahead with BEX9/BEX116 development with no direct access to the A259 is lunacy. Most houses have 2 cars, so anywhere from 160 vehicles to possible 250+, making one or more journeys a day, via Spindlewood Drive, into Meads Road, then Cooden Sea Road, or Maple Walk/Maple Avenue into Cooden Sea Road, is madness. All of these roads already have problems through the current traffic volumes causing wear and tear. Some of these roads are unadopted, single lane, without pavements and adequate lighting - who will pay for maintenance of these unadopted roads?

* Schools and other social day to day requirements - I am led to believe that the new Barnhorn Green development will now not be getting its own school. This will mean that existing schools will be required to offer places to children moving into the area. These schools are already close to breaking point so additional housing will simply worsen an already bad situation. The same applies to doctors surgeries.

* Environment - The BEX9/BEX116 site is a popular area for many people walking dogs, children playing etc. It is also a site which is home to Gt Crested Newts, Badgers, Foxes, Bats. Herons have also been seen. Any development will cause major problems for the wildlife. Also, it is liable to flood in severe weather. Are there any plans to conduct a Flood Assessment Survey ?

* Pollution - Air pollution levels are currently close to breaking "safe" levels. The Barnhorn Green development will breach these levels, and BEX9/BEX116 will cause even more cause for concern. What does Rother District Council intend to do about this?

* RDC's figures for the amount of houses to be built do not take in account those that are already approved or going into the request for approval process. In Little Common alone we have 8 flats I believe being developed on the site of the old Natwest Bank in Cooden Sea Road. I'm also led to believe that the old Co-Op site on the corner of Cooden Sea Road and Meads Road may be converted into 7 or 8 flats. Rumour has it that a further 31 dwellings are in the pipeline for Barnhorn Road, near to Ashridge Court Care Home. This will affect traffic flow, parking etc. Little Common will be at breaking point.

In my opinion, BX124 is a much more suitable for new housing. 450 houses are currently proposed. Why not increase it by even more? It has a new road in the area, already being used. In my opinion, this road is underused. It has direct links to Sidley, which has better infrastructure than Little Common, Ravenside shopping Centre, Hastings,St Leonards. It is also a brownfield site, as opposed to Spindlewood.

We do understand development and additional housing within the Bexhill area is needed but believe that the proposed development of the site Spindlewood/Maple Walk (BEX09/BX116) to be unsuitable for the proposed 160 dwellings This is a large number of properties to be sited in the area of Little Common, given Little Common does not have the infrastructure to accommodate that number of new houses/dwellings and families.

There are already proposed additional new developments in and around Little Common, which could add up to 465 dwellings. This includes Barnhorn Green (BX120 - 342 properties ), the old NatWest Bank in Cooden Sea Road - 8 properties, potentially the closed Co-Op also Cooden Sea Road - 9 properties, 45 & 47 Barnhorn Road - 8 dwellings. Other proposed areas are, land next to Ashridge Court Care Home in Barnhorn Road - 32 properties & Sidley Sports ground in Glovers Lane - 65 proposed properties.

Little Common will simple not be able to cope with this high level of additional properties/people/cars. There are few jobs in and around Little Common, people with jobs outside the area will need to drive towards Eastbourne, Bexhill or Hastings at the very nearest. This will put increase level of transport already on our immediate roads with noise and air pollution increasing. The queue of traffic along the Barnhorn road at peak times is already extremely busy and the line of traffic queuing to pass through Little Common can be outside of the Bexhill boundary. Little Common surgery is near to full and already under pressure with appointments at times to obtain. Little Common School is full all the time and with no secondary school. There is limited shopping with in area, All the additional journeys to work, schools & shopping will put increase pressure on the roads. The new developments will increase traffic considerably. The increase in traffic will be harmful with additional air and noise pollution to the environment and people living within this area,

The access road into the proposed development BEX09/BX116, Meads Road is a narrow road made up of large concrete slabs already beginning to show some disrepair. Meads Road is not suitable for not only the prospect of large industrial lorries but the increase in traffic from the proposed BEX116 site, With an increase of 160 dwellings this could increase the traffic to 700 plus journeys through Meads Road. Maple Walk going South out of Spindlewwod Drive is as the title says " WALK" There is no path for the safety of the pedestrians, many people use Maple Walk to walk with some safety down the Cooden Beach onwards to the seafront and station. Maple Walk is an un-adopted road, it is not fair to expect the residents of Maple Walk to incur the additional traffic use and the costs of repairs to the road surface.

There are more appropriate sites to consider for development. The North Bexhill Access Road the site ref BX124 this will provide better access to St. Leonards, Hastings and Bexhill. There would be better access to Schools, shopping at Ravenside and a choice of doctors surgeries and within easy reach of Conquest Hospital. Trains from Bexhill & Hastings give a better service than from Cooden Beach.

Alternative sites - brown sites, projected small and large developments and windfalls should be taken into account over the next 5 years to see how they affect the environment and how the local infrastructure copes with the increase of traffic, noise and air pollution within the Little Common area before the proposed development of Spindlewood/Maple Walk progresses further.

The following comments, related to biodiversity matters, are made on behalf of the Sussex Wildlife Trust.

If a question from the consultation is not included below, please assume that the Trust has no comments to make at this time.

PART B: DEVELOPMENT POLICIES

QUESTION 2: Do you agree that the optional water efficiency standard should be adopted and the proposed policy wording?

We are concerned that this policy appears to limit itself to water efficiency and believe that it should be broader in its approach to water resource management. The policy appears to consider only domestic water efficiency and we question if the policy should also consider commercial use.

QUESTION 3: Where, if anywhere, do you think could be an appropriate location for wind turbine(s) to be sited in the District?

Any proposal for wind turbines and associated infrastructure, such as connections to the grid, needs to ensure that impacts on biodiversity and their placement within the landscape in terms of their potential impacts on ecological networks are assessed before suggestions are made regarding suitable locations.
Therefore changes in policy wording to reflect this should be made.

QUESTION 4: What opportunities do you think there are to encourage biomass/wood fuel from local sources and how should these be reflected in planning policy?

This could be demonstrated through a policy which encourages biomass potential in commercial and possibly residential developments through appropriate design. However, the policy would need to recognise the importance of protecting woodlands so that their biodiversity value is considered and enhanced through the process. Further, the Rother Local Plan currently does not include an ancient woodland policy; if a wood fuel policy is adopted a separate ancient woodland policy is needed.

QUESTION 7: Do you agree with the policy approach to equestrian developments and the proposed policy wording?

We are encouraged to see the supporting text for this policy recognise the sensitivities of equestrian developments in the countryside and the need to ensure that these features are safeguarded. In relation to this we highlight that in paragraph 7.16 the last sentence states 'However, there is scope for equestrian development in the countryside that is limited in scale'. The term 'scale' perhaps needs defining to add clarity.

We are concerned about equestrian developments being proposed on designated sites such as Local Wildlife Sites. Therefore we welcome an approach to more clearly defined acceptable limits of equestrian development in relation to designated sites. The policy could benefit from underlining the need for up to date ecological management plans accompanying proposals, as per National Planning Policy Framework ( NPPF) section 165.

QUESTION 12: Do you agree with the proposed policy approach to external residential areas and the proposed policy wording? If not, what changes would you wish to see?

Creative approaches and orientation should be considered when designing external spaces. Their setting within the green infrastructure aspirations of the District should be looked at during the planning application stage. This would ensure a holistic and considered approach to green infrastructure.

While bullet point (i) gives clarity to the external spaces of dwellings of 3 or more bedrooms, there is a lack of commitment to the amount of space need for flat and complex developments. The last sentence of this bullet point states that, 'an appropriate level of usable community and amenity space should be provided'. We are concerned that this statement does not give the decision maker a clear enough direction for its interpretation.

Bullet point (ii) should reference the need to be permeable and where gardens are being lost efforts should be made to ensure there is no loss to biodiversity reference NPPF section 109. The council may find the RHS advice leaflet useful www.rhs.org.uk/advice/profile?PID=738

We suggest bullet point (iii) uses wording to incorporate green roofs on waste and recycling stores to help add to a developments' contribution to biodiversity as per NPPF section 118 'Opportunities to incorporate biodiversity in and around developments should be encouraged'.

QUESTION 13: Do you agree with the proposed policy approach to extensions to residential gardens and the proposed policy wording? If not, what changes would you wish to see?

This is an interesting policy and we welcome its inclusion. The Sussex Wildlife Trust have concern that an extension to a garden, if allowed, could in time lead to other development within that garden boundary. Therefore, the type of habitat a garden extension would involve needs to be considered.

We remind Rother District Council that the NPPF section 53 highlights the need to resist inappropriate development of gardens. Therefore perhaps wording to this effect is needed within the policy.

QUESTION 15: Do you agree with the policy approaches to boundary treatments and drives and accesses and to the wording of the proposed policies? If not, what changes would you wish to see?

The Sussex Wildlife Trust suggests that policy DHG7 (Boundary Treatments) includes wording to reflect the sentiments of section 118 of the NPPF.

This could be achieved by including a bullet point requiring impermeable boundary features to include gaps or passages beneath them to enable movement of wildlife such as hedgehogs and amphibians.

In addition policy DHG8 (Accesses and Drives) should reflect the need to ensure the proposals for new driveways do not lead to a loss in natural capital delivering ecosystem services. Therefore these should be permeable and look to include biodiversity features. See RHS guidance www.rhs.org.uk/advice/profile?PID=738

QUESTION 18: Do you agree with the policy approaches to maintaining landscape character and the High Weald AONB and to the respective proposed policy wordings?

The Sussex Wildlife Trust supports the policy approach to maintaining landscape character and the High Weald AONB. We recommend that policy DEN2 be strengthened by the addition of wording requiring development to deliver biodiversity gains which meet the AONB objectives.

We are concerned that the wording in the last sentence of the policy 'major development will be resisted' would not allow a decision maker to be clear when determining an application. What is the level of resistance intended?

QUESTION 19: Do you agree with the proposed definition of the Strategic Gaps, and the policy applying to them? If not, what changes would you wish to see?

Figure 7 demonstrates that an area of the existing Bexhill and Hastings/St Leonards green gaps is proposed to be removed from the strategic gap. However the supporting text (10.19 - 10.21) does not indicate the reasons for the exclusion. We feel the supporting text for this section would benefit from a brief explanation for the reason in inclusion or exclusion of areas.

We ask the council to consider the value of the strategic gaps in harnessing the district's natural capital. This natural capital will be delivering vital ecosystem services to the district and potentially to the authorities adjoining Rother District. Therefore we would suggest that this is reflected in the policy wording by:
'Within these gaps development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive, not detract from the openness of the area and ensure that ecosystem services are not compromised.'

We believe this additional wording will reflect the importance of strategic gaps for ecosystems service delivery and will also enable the policy to sit in line with NPPF para 109.

QUESTION 20: Do you agree with the policy approach to supporting biodiversity and green space and to the proposed policy wording?

We are encouraged by the manner in which the supporting text for this policy has been approached. The Sussex Wildlife Trust supports the inclusion of an 'Enhancement Policy' approach, however the wording should be strengthened to better conform to the wording and ethos of Chapter 9 of the NPPF.

Part i - the qualification of 'in principle' should be removed. The proposal is either supported in full or it is not, 'in principle' adds nothing to the policy.

Part ii - the word 'significant' should be removed. All developments should aim to avoid harm to biodiversity.

Part iii - should look to reflect the sentiments of the NPPF section 109. The first sentence should be amended to read:
'In addition to ( ii) above , all developments will be expected to deliver net gain to biodiversity by retaining and enhancing biodiversity in a manner appropriate to the local context ....'

Part iv has a requirement for 'larger developments of more than 2 hectare or 50 dwellings...' to produce a green infrastructure (GI) masterplan'. Looking at the allocations, very few meet this requirement. We recognise that there are some larger allocations around Bexhill where we would certainly support the need to produce GI masterplans but we are concerned about the substantial number of allocations which do not meet these criteria. We suggest that the threshold is lowered to 25 dwellings. We also recommend that the policy requires all development to contribute to the aspirations of Rother's Green Infrastructure Strategy.

We suggest that Rother District Council include an Ancient Woodland policy within the Local Plan. This would reflect the ethos of the NPPF which clearly states in section 117:
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

QUESTION 21: Do you agree with the policy approach to sustainable drainage and the proposed policy wording?

Reviewing the supporting text and policy wording there is no recognition of Pevensey and Pett being low lying areas (below sea level) and the associated risk of sea and ground water flooding. We suggest that this is included.

QUESTION 23: Do you agree with the policy approach to managing environmental pollution through the planning process and with the proposed policy wording?

The policy would be strengthened by ensuring that there is mention of biodiversity within the policy bullet point relating to lighting.

Lastly, although the supporting text highlights that the district is not subject to any Air Quality Management Areas, with increasing development we suggest that the council recognise the natural capital that helps filter and deal with pollutants.

Increased levels of development in the district means resources may come under increasing pressure. It may benefit the council to consider talking to the Sussex Biodiversity Record Centre about their Ecoserve programme. This programme shows where the district's natural capital is delivering ecosystem services such as air purification in relation to population demand.

QUESTION 24: Do you agree with the policy approach to comprehensive development and the proposed policy wording?

We support recognising the importance of a holistic approach to development which considers the three roles of sustainable development. In order to achieve this within the policy wording we suggest that the policy looks to include wording regarding net gain to biodiversity as per section 109 of the NPPF. We feel that this is important as phased development may overlook the cumulative impact on the district's natural capital and the ecosystem services being delivered.

PART C: SITE ALLOCATIONS

General Comments
The Trust recognises that the presence of designated sites and priority habitats and species has been a contributing factor in the assessment of the suitability of site allocations. We very much support the council's approach to exclude designated sites and sites of high biodiversity value for development. However we note that the site assessments were primarily based on desk-top studies. With the exception of North Bexhill and Spindlewood Drive it does not appear that any on the ground assessments have been carried out.

Given the council's commitment in the Core Strategy objectives 'To protect important ecological resources in the district' and in policy EN5 to 'support opportunities for management, restoration and creation of habitats...' we recommend that preliminary ecological appraisals are carried out for the preferred sites before they are officially allocated. This will ensure that any issues relating to ecology are identified before the plan reaches the examination stage.

We are pleased to see that the 'Key constraints/opportunities' sections for many of the preferred site allocations consider ecological impacts. However, these considerations are again inconsistently reflected in policy wording. For example, policy IDE1 requires that an ecological assessment is undertaken and that any impact on protected species mitigated. Further to this, policy MAR1 states that development proposals should be subject to an ecological survey.

By singling out only two of the site allocations, this may give the impression that proposals for other allocations may not require ecological surveys. The NPPF has a clear requirement for planning decisions to be based on up to date information and for development to achieve net gains for biodiversity. It would not be acceptable for proposals to proceed without the inclusion of up to date ecological information, especially given that thus far the sites have only been assessed at a desk-top level. This position needs to be reflected in the Biodiversity Policy (please see comments for QUESTION 20) and in all the site allocation policies. Therefore the following wording should be added to all site allocations:
'Prior to determination:
A site wide landscape and ecological management plan that is informed by up to date ecological information, including information on the site's utilisation and delivery of ecosystems services, will be produced. Mechanisms needed for implementation will be identified and secured. This will be to the
satisfaction of the local planning authority to ensure long term maintenance of retained and newly created habitats.'

We recognise that information regarding a site's utilisation of ecosystem services maybe too onerous for small allocations. However, we take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Ecoserve. This programme uses biodiversity and habitat data to look at the ecosystems services currently provided by an area's natural capital. It also assesses where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider as an aid to helping smaller developments see how they could make a contribution or enhancements to the continued delivery of those services through their site.

Additionally, many of the site allocations are adjacent to ancient woodland. Again whilst this is usually noted in the 'Key constraints/opportunities' section, it is not consistently reflected in the policy wording for the allocation. For example Policy BRO1 part (v) specifies that 'a buffer zone of at least 15 metres is provided to the Ancient Woodland', while the presence of an ancient woodland is not mentioned in, for example, policy BEX1 or BEX2. Conversely policy BEX 9 does specify the need for a buffer to protect the adjacent ancient woodland, but the width of the buffer is not specified.

Core Strategy policy EN1 and NPPF paragraph 118 require the protection of ancient woodland in the district. Additionally, Natural England's Ancient Woodland standing advice is clear that a minimum buffer must be at least 15 metres. We therefore recommend that an Ancient Woodland policy is included in the DaSA and that any site allocation policy with the potential to impact on ancient woodland includes a requirement of a buffer zone of at least 15 metres.

We also note that most of the allocations require the 'retention and enhancement of boundary planting'. We understand that this requirement is primarily to mitigate visual impacts on the AONB, however this is also an opportunity to ensure that each allocation contributes to the creation of an ecological network for the district. We therefore recommend that when boundary planting is specified, additional wording is used, such as:
'Provision is made for the retention and enhancement of boundary planting, for the benefit of biodiversity and for screening purposes'.

The majority of the site allocation policies use the term 'some' when describing the number of dwellings or size of employment space required within a development. This is not a standard planning term and hence we are concerned that its use leaves the policies open to broad interpretation. Given the landscape and ecological sensitivities of many of the site allocations, we recommend that a maximum figure is proposed in each policy. This will provide clarity and ensure that the policy can be robustly applied.

Alternatively, if an approximate value is preferred, we recommend the use of the word 'approximately' rather than 'some' as this is more frequently used in a planning policy context. However, if the council is minded to use this approach, we would ask that an additional requirement is added to the policies to ensure that overdevelopment does not occur. We recommend the following:
'The final number of dwellings/employment size selected must be based on up to date environmental information that demonstrates the current ecosystem delivery of the site and its capacity to absorb the proposed level of development. '

QUESTION 26: Do you agree with the requirements of Policy BEX1? If not, how would you wish to see it amended?

General comment
The Sussex Wildlife Trust supports a plan-led planning process and acknowledges that site BEX1 is included in the adopted North East Bexhill SPD. However, we question whether the district's natural capital can absorb this level of development around Bexhill. All the allocated sites around the north east of Bexhill should be treated holistically and assessed for their impact on ecosystem services (NPPF paragraphs 109, 114 and 117). There must be a strategic approach to the development of these sites to ensure that ecological networks are retained across the sites.

Policy BEX1
We support the protection of the adjacent ancient woodland and the retention of the tree line through the centre of the site, as shown in the detailed map. However, this protection does not appear to be repeated in the policy wording. Additionally, the 'Key constraints/opportunities' section recognises that the land along the Combe stream to the north-west of the site should be retained as an amenity/wildlife corridor. Again, this is not reflected in policy wording. If requirements are not included in the policy, we are concerned that they may be disregarded at the application stage. This could also lead to confusion for developers and inconsistency in the decision making process. Therefore, policy BEX1 should be strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 The retention of the central belt of trees and enhancements to create a robust corridor between the ancient woodland and the wider countryside.
 The retention of the land along the Combe stream as an amenity/wildlife corridor
The Trust supports the retention of the central tree belt; however, the proposed access appears to sever this corridor. We recommend that the access is reconfigured to ensure the corridor is preserved in its entirety. If this is not deemed feasible wording should be added to ensure that the tree belt still functions as and ecological corridor.

It is vital that any green infrastructure within the site connects well to the surrounding area. We recommend additional wording in section (iv) to insure this:
'landscape and woodland belts are developed, implemented and connected to the wider landscape as an integral part of proposals'.

QUESTION 27: Do you agree with the preferred sites for housing development at Bexhill? If not, which site(s) should be preferred?

The Trust questions whether the district's natural capital is able to absorb this level of development around Bexhill. Before finalising site allocations, especially larger greenfield sites around the development boundary, we recommend that the council assesses the capacity of these sites to provide ecosystem services. We take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Eco serve which uses biodiversity and habitat data to look at the ecosystems services the natural capital is currently providing and where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider.
QUESTION 28: Do you agree with the requirements of Policy BEX2? If not, how would you wish to see it amended?

General comment
As per our comments for QUESTION 26, site BEX2 should be assessed strategically with allocation BEX1 and BEX3. Overall, these allocations cover a significant area of greenfield, which will be providing vital ecosystem services to the district. The cumulative impact of these allocations on the district's natural capital needs to be assessed and accounted for to ensure that the expansion of Bexhill is truly sustainable as per the NPPF. Additionally, any green infrastructure strategy should cover all these sites to ensure permeability throughout the developments and multifunctional benefits across the north east of Bexhill are achieved.

Policy BEX2
As per our comments for QUESTION 26, we are concerned that some of the intentions in the 'Key constraints/opportunities' section and the detailed map are not reflected in the policy wording. We recommend that policy BEX2 is strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 Part (ii) should include a requirement for the pond to be retained as an ecological feature with landscaping to connect it to the wider countryside

QUESTION 29: Do you agree with the requirements of Policy BEX3? If not, how would you wish to see it amended?

Notwithstanding our general comments in QUESTIONS 26 and 28, if development is to occur here then option 1 would be preferable. This would retain a larger proportion of greenfield and allow more creative approaches to green infrastructure and ecological enhancements. We recommend that information on the site's utilisation and delivery of ecosystem services should be produced and used to inform the site's layout.

The Trust is concerned that the now approved North Bexhill Access Road severs the ghyll woodland at Kiteye Wood.

Any development in this area should seek to mitigate this impact through appropriate habitat creation and/or management. Additionally, the policy should make reference to the retention of the land along the Combe stream as an amenity/wildlife corridor, as per policy BEX1. These requirements could be included in part (vii) of the policy, which we support.

As with previous comments the wording to protect ancient woodland should be strengthened to include a requirement for a 15 metre buffer.

We also recommend that the policy protects the 'Woodland Complex at Buckholt Farm' Local Wildlife Site, to the north east of the site allocation. Whilst it sits outside the development boundary, this ancient woodland could still be harmed by the indirect impacts of the development. These need to be assessed and avoided at the master planning stage.

QUESTION 33: Do you agree with the requirements of Policy BEX7? If not, how would you wish to see it amended?

The Trust supports the retention of the southern section of the site as an ecology area. However, the wording of section (iv) should be strengthened to include a requirement to enhance the area as per core strategy policy EN5. We recommend:
'The southern section of the site remains undeveloped as an ecology area. Ecological enhancements should be implemented to improve the area for biodiversity. Provision should be made for the long term management of this area.'
QUESTION 35: Do you agree with the requirements of Policy BEX9? If not, how would you wish to see it amended?

The Trust supports the retention of the tree belts in the centre of the site, the designation as a natural green space and the wording of part (vi). However, it is not clear to us how this corridor will be retained intact given that vehicle access is only proposed from the east of the site. This indicates that internal roads will sever the corridor in order to access the residential area in the North West. This should be a consideration in designing the layout of the site. At the very least we recommend wording to ensure that the integrity of the green corridor is maintained.

We support the inclusion of section (vii), however this should be strengthened with a requirement for the ancient woodland buffer at least 15 metres wide.

Additionally, it should be specified that the pond is retained as an ecological feature, rather than as part of any SuDS scheme for the site.

QUESTION 36: Do you agree with the requirements of Policy BEX10? If not, how would you wish to see it amended?

The Trust supports requirement (ii), however this should be expanded to specify that integration includes an integrated scheme of green infrastructure to ensure that the entire site remains permeable and receives multifunctional benefits.
The words 'where possible' should be removed from part (v). The pond should be retained and enhanced; this cannot be seen as unduly onerous given the site of the scheme.

QUESTION 37: Which of the development options for Northeye do you prefer? Should other options be considered?

Any policy for this site must include protections against the potential negative impacts of the creation of sports pitches such as flood lighting and impermeable surfaces. We recommend wording is included to ensure that there are no harmful impacts of this type of development.

QUESTION 38: Do you agree with the requirements of Policy BEX11? If not, how would you wish to see it amended?

This policy should include wording to manage the type of playing pitches which might be suitable on this site. Consideration should be made to the use of artificial pitches and associated lighting. In particular, potential impacts on bats which are likely to be present in the area should be considered.

QUESTION 43: Do you agree with the requirements of Policy BEX15? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that 'a large proportion of the site suffers from surface water flooding'. Therefore, we recommend that an additional criterion is added to the policy to ensure that a SuDS scheme is implemented to rectify this issue. We also recommend that green infrastructure is included to both help with the flooding issue and to connect the site to the wider GI network in the town.

QUESTION 47: Do you agree with the preferred site for housing development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust supports the allocation of brownfield sites of low ecological value over the allocation of greenfield sites. A large amount of development is already proposed for the fringes of Hastings through the Hastings Development Management Plan. We would not support any further urban sprawl into the surrounding countryside without full accounting of the area's natural capital and assessment of the area's utilisation and delivery of ecosystem services.

QUESTION 49: Do you agree with the preferred sites for employment development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust does not support further urban sprawl at the Hastings fringe; however of the four sites recommended, the preferred sites seem to be the least damaging. As stated previously we recommend that preliminary ecological appraisals are carried out before sites are formally allocated to ensure that there is no significant harm to biodiversity.

Additionally, a wider green infrastructure plan should be required, covering both of these sites in conjunction with the adjacent Hasting allocations to ensure a holistic approach.

QUESTION 50: Do you agree with the requirements of Policy HAS2? If not, how would you wish to see it amended?

We recommend that point (iv) is strengthened as follows to ensure net gains to biodiversity as per the NPPF:
'provision is made, in conjunction with the adjoining employment allocations, for the retention, enhancement and long-term future management of woodland to the north of the site for the benefit of biodiversity'.

QUESTION 51: Do you agree with the requirements of Policy HAS3? If not, how would you wish to see it amended?

We support criterion (iv), however any green infrastructure should be integrated into the surrounding employment allocations, to ensure multifunctional benefits are seen across the whole area.

QUESTION 53: Do you agree with the requirements of Policy HAS5, including the boundary as defined in the Policies Map? If not, how would you wish to see it amended?

We recommend an addition to criterion (ii) to ensure net gains to biodiversity as per the NPPF.
'...the Site of Nature Conservation Importance within it, and creates net gains to biodiversity within the Park...'

QUESTION 54: Do you agree with the recommendation regarding the Hastings Fringes development boundaries? If not, please explain how you wish the development boundaries to be applied to this area?

The Trust strongly supports the designation of a strong development boundary which prevents further urban sprawl into the wider countryside. (Please see QUESTION 47).

QUESTION 56: Do you agree with the requirements of Policy BEC1? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 57: Do you agree with the requirements of Policy BEC2? If not, how would you wish to see it amended?

We recommend that the policy is strengthened to better reflect the contents of the 'Key constraints/opportunities' section. In particular, reference should be made to the requirement to keep the remaining area as amenity land and to the retention of the pond as an ecological feature rather than as part of any SuDS scheme deemed necessary.

QUESTION 59: Do you agree with the preferred sites for development at Broad Oak? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value such as BO14. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 60: Do you agree with the requirements of Policy BRO1? If not, how would you wish to see it amended?

The Trust strongly supports the wording of requirement (v) and the specification of a buffer of at least 15 metres. We recommend that this wording is replicated in other policies for sites adjacent to ancient woodland.

We support requirement (iv), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 61: Do you agree with the requirements of Policy BRO2? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 65: Do you agree with the requirements of Policy CAM2? If not, how would you wish to see it amended?

This policy needs to be strengthened to ensure that the adjacent Local Wildlife Site, Local Geological Site, SSSI and Special Protection Area are protected from harm. Whilst the protection and management of the dunes is a key landscape and ecological objective of the SPD, there does not appear to be a specific requirement to protect and enhance these designated sites. This should be addressed in the policy.

QUESTION 66: Do you agree with the proposed development boundary? If not, how would you wish to see it amended?

The Trust strongly supports the deletion of the SSSI from the development boundary. Dungeness, Romney Marsh & Rye Bay SSSI is of national importance to biodiversity and should not be degraded through encroaching development.

QUESTION 68: Do you agree with the requirements of Policy CAT1? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that buffer planting should be informed by ecological surveys, however this requirement is not reflected in the policy wording. Given that the site appears to contain well developed scrub, any application for this site must include a thorough ecological survey to assess if the site can absorb the level of development suggested whilst producing net gains for biodiversity.

QUESTION 69: Do you agree with the requirements of Policy CAT2? If not, how would you wish to see it amended?

Requirement (iii) should be subject to ecological surveys to assess the impact of severing the hedgerow. We also recommend that 'for the benefit of biodiversity' is added to the end of requirement (iv)(b) to ensure that any tree and hedgerow planting contributes to the wider ecological network in Catsfield.

QUESTION 72: Do you agree with the requirements of Policy HUR1? If not, how would you wish to see it amended?

As the stream/ditch that sub-divides the two lower fields is recommended to be retained for both heritage and ecological reasons, this should be reflected in the policy. We recommend that requirement (vii) is amended to:
'...is retained and incorporated within the layout as an ecological feature. Development should ensure that the biodiversity value of the feature is enhanced and that it is integrated into the wider blue/green infrastructure plan for the site...'

QUESTION 73: Do you agree with the requirements of Policy HUR2? If not, how would you wish to see it amended?

This site is adjacent to Hurst Green Meadows and Woodland Local Wildlife Site. This should be acknowledged in the policy and a requirement to protect and enhance the LWS should be included.

QUESTION 76: Do you agree with the requirements of Policy IDE1? If not, how would you wish to see it amended?

We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species. Opportunities to incorporate biodiversity gains throughout the development should be taken.

QUESTION 79: Do you agree with the requirements of Policy NOR1? If not, how would you wish to see it amended?

Enhancements to the existing tree belts should be sought for the benefit of biodiversity.

QUESTION 82: Do you agree with the requirements of Policy PEA1? If not, how would you wish to see it amended?

The Trust strongly supports the protection of the traditional orchard and the aims to bring it into long-term sustainable management. This is a priority habitat and as such its protection and enhancement is fundamental to the council's aims in the Core Strategy. We strongly support requirement (v) and recommend that there is a requirement for a long-term ecological monitoring and management plan for the site.

Requirement (vi) should include 'enhancement' as well as retention to ensure net gains to biodiversity. We also recommend that the requirement for a SuDS scheme is included in the policy.

QUESTION 83: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

The Trust strongly supports the exclusion of the traditional orchard from the development boundary. This will help to protect the site in the long term.

QUESTION 84: Do you agree with the preferred site for development at Rye Harbour? If not, which site should be preferred?

The Trust strongly supports the exclusion of sites designated as SSSI. These would clearly not be suitable for development and their allocation would be contrary to the Core Strategy and NPPF.

QUESTION 85: Do you agree with the requirements of Policy RHA1? If not, how would you wish to see it amended?

The site is also adjacent to the SPA and this should be acknowledged in the policy. We recommend that requirement (iv) is extended as follows:
'...development of RH10 does not adversely impact upon the Rye Harbour SSSI and avoids impacts on the SPA'.

QUESTION 86: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

It appears a typo is included in paragraph 15.98. The reference to Donsmead, Station Road should be removed.

We support the proposed development boundary as it should prevent further development encroaching onto sites designated for their biodiversity value.

QUESTION 87: Do you agree with Policy RHA2 regarding the Harbour Road Industrial Estate and the proposed boundary changes? If not, how would you wish to see it amended?

Given the ecological sensitivity of the land surrounding this allocation, we recommend that requirement (iii) is strengthened as follows:
'...a comprehensive landscaping strategy and an ecological monitoring and mitigation plan to improve the overall appearance and the biodiversity value of development.'

QUESTION 88: Do you agree with the preferred sites for development at Westfield? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 89: Do you agree with the requirements of Policy WES1? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. Further to this, as identified in the 'Key constraints/opportunities' section, the previous ecological appraisals suggested biodiversity gains. The Trust strongly supports the inclusion of wording to support biodiversity gains but seeks that these are not limited to bird and bat boxes. Instead biodiversity gains should be implemented depending on the findings of the up to date ecological surveys submitted at the time of the application. We remind the council that if they are minded to suggest bird and bat boxes as part of the gains for this site in future, wording should be included to highlight the need to incorporate natural features supporting these artificial homes.

QUESTION 90: Do you agree with the requirements of Policy WES2? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. The aerial photograph shows the degraded formal gardens and it would be interesting to see if this allocation could consider how these former gardens might be integrated into the layout of the development site, as it may enable the retention of features of interest.

QUESTION 91: Do you agree with the requirements of Policy WES3? If not, how would you wish to see it amended?

The southern section of the allocations lies within the Hasting Fringes Biodiversity Opportunity Area (BOA). We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species.

Opportunities to incorporate biodiversity gains throughout the development as per the ecological surveys and aspirations of the BOA should be taken.

QUESTION 92: Do you agree with the requirements of Policy WES4? If not, how would you wish to see it amended?

We note this allocation falls outside the 2006 development boundary. However, we are supportive of measures taken to encourage modes of sustain able transport and to interlink those benefits with biodiversity gains. The text accompanying the allocated site states that there are locally present protected species. Therefore we recommend that (iii) reads:
'ecological improvements are based on up to date ecological surveys and are implemented in accordance with these findings and those of the Hasting Fringes Biodiversity Opportunity Area and Rother Green infrastructure Strategy'.

Question 93 - 103

We support the retention of gaps between settlements. While these gaps are often retained for reasons of coalescence and visual sensitivities, we highlight that the Sussex Wildlife Trust also sees the need to recognise the importance of these green gaps in delivering ecosystem services to the local communities (NPPF section 109).

QUESTION 105: Do you agree with the requirements of Policy GYP1, including the boundary as defined on the Policies Map? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per are general comments at the start of this section.

QUESTION 109: Do you agree with the requirements of Policy (MAR1)? If not, how would you wish to see it amended?

We support the requirement for an ecological survey. We recommend that criterion (i) includes 'for the benefit of biodiversity' and the criterion (iv) requires the use of SuDS.

QUESTION 110: Do you agree with a policy to support the continued allocation for the re-instatement of the railway link from Robertsbridge to Bodiam along its original route?

The Sussex Wildlife Trust support sustainable modes of transport. However, we do not have enough information about this particular scheme to offer an opinion on this policy. It is unclear whether the application has been progressed with the consideration of the existing landowners and the level to which biodiversity interests have been considered.

QUESTION 111: Do you have any comments on this scope or content of the new Local Plan that are not covered by other questions?

We highlight the need for a specific Ancient Woodland Policy as per section 117 of the NPPF.
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

We welcome the inclusion of the green infrastructure study as an evidence base for the local plan. We would like to know if this will progress into a clear strategy identifying delivery mechanisms. We suggest that the local plan may benefit from a specific policy on green infrastructure/ecological networks to ensure consistent integration of this infrastructure within development.

Should you have any further questions regarding our consultation response please feel free to contact me.

Yours sincerely,
Laura Brook
Conservation Officer

I disagree strongly with development of any of the sites which would affect Little Common; specifically, they are the Spindlewood Drive development proposal (BEX09/BX116) and BX101 (Northeye) because tha Little Common area of Bexhill already has inadequate infrastructure.

These inadequacies will soon become even more obvious with the traffic disruptions aggravated by the Barnhorn Green development north of Barnhorn Road, with access close to Greyhorses bend. Little Common has further residential developments either currently under way or proposed and which in total could amount to some 465 houses.

Current and agreed developments around Little Common include Barnhorn Green (BX120 - 342 properties), the former Nat West Bank in Cooden Sea Road (RR/2015/3103/P - 8 properties), 45/47 Barnhorn Road (RR/2016/2430/P - 8 dwellings); potential developments include land adjacent to Ashridge Court Care Home, Barnhorn Road (BX50 - (RR/2016/3206/P - 31 properties)), the former Co-Op site in Cooden Sea Road (RR/2016/3254/P - 9 properties) and Sidley Sports Ground Glovers Lane (RR/2016/3127/P) - 65 properties.

Before considering ANY new development a proper viable strategy must be developed and committed to by Rother DC, which addresses at least the following points:

Main road inadequacy - most days now eastbound traffic on the A259 is stationary several times each day from Little Common Roundabout, back at least to the fuel station at the end of Coneyburrow Lane, creating delays of typically 15 minutes. the A259 is already close to capacity with 900 vehicles per hour in both directions throughout the day and the situation will be exacerbated by the installation of traffic lights at the entrance to Barnhorn Green, the zebra crossing to be installed at Kite Nests Walk, and in due course by the additional traffic generated by the residents of Barnhorn Green.

Increased traffic for travel to work, as there are few new employment opportunities in Little Common.

Increased traffic for travel to go shopping, as the shops in Little Common are at best rudimentary.

Increased air pollution and noise - because of the increased traffic, harmful to the environment and will generate additional noise and air pollution especially around the A259.

Additional School capacity for the new children who would live in the area.

Additional Medical facilities - Little Common Surgery has little capacity for new patients.

Free or affordable off-road car parking - most residential roads, and several urban through routes such as Collington Avenue and Birkdale, the Golf Club end of Cooden Sea Road, are reduced in width by parked vehicles almost permanently. The minor roads close to Little Common are heavily parked during the working day by people who work in the village; this has increased noticeably since parking charges were applied in the only off-road car park.

Little Common's current infrastructure will not cope with additional large numbers of properties and people. Any further large scale residential developments in or around Little Common will create a state of crisis and must therefore not be permitted.

More Suitable Sites

There are far more appropriate sites to develop than the properties proposed for Spindlewood Drive (BEX09/BX116) and Northeye (BX101).

The most appropriate by far would be off the North Bexhill Access Road (NBAR - BEX3) - site ref BX124. Options 2 and/or 3 would be suitable (in addition to Option 1) due to the far better infrastructure availability for the residents and without serious detriment to the environment .

These infrastructure benefits of BX124 include

Access to local jobs especially BX113 (with access directly off the NBAR) and Enterprise Way. Other job opportunities are also possible at St Leonards, Hastings and Bexhill and can all be accessed easily via Coombe Valley Way.

Easy access to local schools including the newly proposed nursery and junior school in North East Bexhill as well as secondary schools, all accessed via Enterprise Way.

2 GP surgeries are within easy reach at Bexhill old town and Sidley

Good shopping facilities are provided and easily accessed at Ravenside, St Leonards and Hastings.

A 24 hour pharmacy is provided at Ravenside and Tesco Extra at St Leonards is also available for long periods.

Good train services are easily available at Bexhill and St Leonards Warrior Square without having to access the A259 (already running at close to capacity).

Car access to all local areas is readily available via the NBAR and Coombe Valley Way and without needing to access the A259.

The A21 and the Conquest Hospital are just a few minutes' drive away.

A second but far less suitable site than BX124 would be BX101 (Northeye). This is a brownfield site so should be preferred over any greenfield site.

As already explained, this option would greatly aggravate the pressures on Little Common's infrastructure, including the A259.

Errors of omission by RDC mean that there is no need to include the Spindlewood Drive site, nor some of the others in the current DaSA plan/proposals

I must now insist that the bases upon which RDC proposes the Spindlewood site BEX09/BX116 as a Preferred Site are ill-founded, and that there is absolutely no need to include BEX09/BX116 in the DaSA plans/proposals.

Some simple studies of RDC's records by a group of neighbours - whose integrity and findings I support - has shown that the Spindlewood Site development proposal (and others around Little Common) is superfluous.

Each and every year over the past 10 years, RDC has approved an average of 70 small development applications, which has allowed Bexhill to expand at a manageable rate, without crises or critical infrastructure problems. In the next 11 years there is every reason to epect these 'windfall' increases to continue, resulting in a further 770 homes across Bexhill, irrespective of any resulting from the DaSA processes.

I understand that RDC has stated that it is not willing to take projected small windfall properties into account when estimating their target figure of 3100 for Bexhill. This is illogical, and morally wrong. It amounts to ignoring information which they cannot be bothered to consider, which, if they did ignore would be incompetent. If only half the likely windfall numbers WERE taken into account, RDC could still avoid the risk of making decisions on development sites that need not be developed (such as BX116) in order for RDC to meet (and perhaps) beat their target of 3100.

By acting wisely, RDC could avoid making such errors from which peoples' lives and quality of life would be irrevocably damaged. That unnecessary consequence would be both tragic and unforgivable.

This further information explains with more detail, my point - and probably the same point as is being presented by other residents.

Using the figures contained in RDC's Housing Land Supply document dated as at April 2016 and making allowance for projected small and large site windfalls over the period 2016 - 2028 as well as the recently proposed developments in and around Little Common as detailed in 3(a) above, it is estimated that Bexhill will be able to achieve approximately 3315 properties by the end of 2028. This exceeds by 215 the target set by RDC of 3100 and excludes the following sites
BEX6 - Turkey Road
BEX7 - Fryatt's Way
BEX9 - Spindlewood Drive
BX101 - Northeye

Consequently, these 4 sites should be removed from the second DaSA consultation process.

I disagree strongly with development of any of the sites which would affect Little Common; specifically, they are the Spindlewood Drive development proposal (BEX09/BX116) and BX101 (Northeye) because the Little Common area of Bexhill already has inadequate infrastructure.

These inadequacies will soon become even more obvious with the traffic disruptions aggravated by the Barnhorn Green development north of Barnhorn Road, with access close to Greyhorses bend. Little Common has further residential developments either currently under way or proposed and which in total could amount to some 465 houses.

Current and agreed developments around Little Common include Barnhorn Green (BX120 - 342 properties), the former Nat West Bank in Cooden Sea Road (RR/2015/3103/P - 8 properties), 45/47 Barnhorn Road (RR/2016/2430/P - 8 dwellings); potential developments include land adjacent to Ashridge Court Care Home, Barnhorn Road (BX50 - (RR/2016/3206/P - 31 properties)), the former Co-Op site in Cooden Sea Road (RR/2016/3254/P - 9 properties) and Sidley Sports Ground Glovers Lane (RR/2016/3127/P) - 65 properties.

Before considering ANY new development a proper viable strategy must be developed and committed to by Rother DC, which addresses at least the following points:

Main road inadequacy - most days now eastbound traffic on the A259 is stationary several times each day from Little Common Roundabout, back at least to the fuel station at the end of Coneyburrow Lane, creating delays of typically 15 minutes. the A259 is already close to capacity with 900 vehicles per hour in both directions throughout the day and the situation will be exacerbated by the installation of traffic lights at the entrance to Barnhorn Green, the zebra crossing to be installed at Kite Nests Walk, and in due course by the additional traffic generated by the residents of Barnhorn Green.

Increased traffic for travel to work, as there are few new employment opportunities in Little Common.

Increased traffic for travel to go shopping, as the shops in Little Common are at best rudimentary.

Increased air pollution and noise - because of the increased traffic, harmful to the environment and will generate additional noise and air pollution especially around the A259.

Additional School capacity for the new children who would live in the area.

Additional Medical facilities - Little Common Surgery has little capacity for new patients.

Free or affordable off-road car parking - most residential roads, and several urban through routes such as Collington Avenue and Birkdale, the Golf Club end of Cooden Sea Road, are reduced in width by parked vehicles almost permanently. The minor roads close to Little Common are heavily parked during the working day by people who work in the village; this has increased noticeably since parking charges were applied in the only off-road car park.

Little Common's current infrastructure will not cope with additional large numbers of properties and people. Any further large scale residential developments in or around Little Common will create a state of crisis and must therefore not be permitted.

More Suitable Sites

There are far more appropriate sites to develop than the properties proposed for Spindlewood Drive (BEX09/BX116) and Northeye (BX101).

The most appropriate by far would be off the North Bexhill Access Road (NBAR - BEX3) - site ref BX124. Options 2 and/or 3 would be suitable (in addition to Option 1) due to the far better infrastructure availability for the residents and without serious detriment to the environment .

These infrastructure benefits of BX124 include

Access to local jobs especially BX113 (with access directly off the NBAR) and Enterprise Way. Other job opportunities are also possible at St Leonards, Hastings and Bexhill and can all be accessed easily via Coombe Valley Way.

Easy access to local schools including the newly proposed nursery and junior school in North East Bexhill as well as secondary schools, all accessed via Enterprise Way.

2 GP surgeries are within easy reach at Bexhill old town and Sidley

Good shopping facilities are provided and easily accessed at Ravenside, St Leonards and Hastings.

A 24 hour pharmacy is provided at Ravenside and Tesco Extra at St Leonards is also available for long periods.

Good train services are easily available at Bexhill and St Leonards Warrior Square without having to access the A259 (already running at close to capacity).

Car access to all local areas is readily available via the NBAR and Coombe Valley Way and without needing to access the A259.

The A21 and the Conquest Hospital are just a few minutes' drive away.

A second but far less suitable site than BX124 would be BX101 (Northeye). This is a brownfield site so should be preferred over any greenfield site.

As already explained, this option would greatly aggravate the pressures on Little Common's infrastructure, including the A259.

Errors of omission by RDC mean that there is no need to include the Spindlewood Drive site, nor some of the others in the current DaSA plan/proposals

I must now insist that the bases upon which RDC proposes the Spindlewood site BEX09/BX116 as a Preferred Site. are ill-founded, and that there is absolutely no need to include BEX09/BX116 in the DaSA plans/proposals.

Some simple studies of RDC's records by a group of neighbours - whose integrity and findings I support - has shown that the Spindlewood Site development proposal (and others around Little Common) is superfluous.

Each and every year over the past 10 years, RDC has approved an average of 70 small development applications, which has allowed Bexhill to expand at a manageable rate, without crises or critical infrastructure problems. In the next 11 years there is every reason to epect these 'windfall' increases to continue, resulting in a further 770 homes across Bexhill, irrespective of any resulting from the DaSA processes.

I understand that RDC has stated that it is not willing to take projected small windfall properties into account when estimating their target figure of 3100 for Bexhill. This is illogical, and morally wrong. It amounts to ignoring information which they cannot be bothered to consider, which, if they did ignore would be incompetent. If only half the likely windfall numbers WERE taken into account, RDC could still avoid the risk of making decisions on development sites that need not be developed (such as BX116) in order for RDC to meet (and perhaps) beat their target of 3100.

By acting wisely, RDC could avoid making such errors from which peoples' lives and quality of life would be irrevocably damaged. That unnecessary consequence would be both tragic and unforgivable.

This further information explains with more detail, my point - and probably the same point as is being presented by other residents.

Using the figures contained in RDC's Housing Land Supply document dated as at April 2016 and making allowance for projected small and large site windfalls over the period 2016 - 2028 as well as the recently proposed developments in and around Little Common as detailed in 3(a) above, it is estimated that Bexhill will be able to achieve approximately 3315 properties by the end of 2028. This exceeds by 215 the target set by RDC of 3100 and excludes the following sites

BEX6 - Turkey Road
BEX7 - Fryatt's Way
BEX9 - Spindlewood Drive
BX101 - Northeye

Consequently, these 4 sites should be removed from the second DaSA consultation process.

Landscape


BEXHILL Page 128

Yes to all Bexhill development polices

Archaeology

Please note that for most answers in this section a Red, Amber or Green rating has been assigned. In providing these responses, regard has been had to paragraph 169 of the NPPF. We are of the view that in order to satisfy this part of the NPPF, some of the proposed site allocations should be subject to archaeological assessment prior to the Pre-Submission version of the DaSA being published - these particular sites are identified below. For all the proposed allocations there will be a requirement for the subsequent planning applications to satisfy paragraph 128 of the NPPF.

BEXHILL Page 128

-Site options for housing

We have assessed most sites as either low or medium risk, with those at medium requiring archaeological assessment. Only BEX4 is of concern due to the site containing a non-designated heritage asset that would be vulnerable to impact / demolition.
-AMBER

SPINDAG's asserts that traffic flows along Barnhorn Road had already reached levels predicted not to be achieved by Highways England until 2028.

I attach information relating to these issues.

1. The Ashridge Court proposal and associated traffic flows along Barnhorn Road (table 3.1) and traffic movements in and out of the proposed site of 31 properties (table 5.2). This latter table was used in extrapolated form to predict traffic flows along Meads Road for the Spindlewood site - http://www.rother.gov.uk/CHttpHandler.ashx?id=28225
2. Comments on the Exigo report - provided by a resident Mr Geoff Lawson (an ex Civil Engineer with particular expertise in traffic management) - http://www.rother.gov.uk/CHttpHandler.ashx?id=28223
3. Little Common traffic flows - also from Mr Geoff Lawson - http://www.rother.gov.uk/CHttpHandler.ashx?id=28224
4. Question 27 submission from David Allen a SPINDAG Committee member with knowledge and experience in traffic issues - http://www.rother.gov.uk/CHttpHandler.ashx?id=28248

All these documents support our case that Barnhorn road traffic is already close to capacity with potential serious implications for future traffic congestion once the traffic lights and zebra crossing are operational along Barnhorn Road near to the entrance to Barnhorn Green.

They also support the case that the traffic assessment report provided by Exigo is full of inconsistencies and inaccuracies and takes no account of the traffic chaos that will ensue along Meads Road and into Cooden Sea Road and Little Common roundabout should the Spindlewood development access be via Spindlewood Drive (and which is contrary to your own Core Strategy Document of Sept 2014 that stated that all access to new developments to the West of Little Common roundabout should be via Barnhorn Road).

I do not agree with the preferred sites for housing development. The BX116 site should be removed from the list.

Overall Comment
Although some reference is made to traffic no solution is offered nor attempt made to quantify the impact of the development proposed sites. Based on the figures published in 2011 for the link road submission this overall level of development is likely to increase the traffic of the A259 by between 14000 and 20000 vehicles per day. Current levels of traffic measured on the A259 provided by Highways England show a figure of 21500 vehicles per day. Based on the figures given in TA79/99 Part 3 the A259 through Little Common can be classed as Road Type UAP3 with a capacity limit of 900 vehicles per hour. Measured (by Highways England) peak traffic is recorded at 869 vehicles per hour and the total proposed new build will add at least 171 vehicles/hr, more likely a total of up to 1200 vehicles per hour will be reached, leading to gross overloading of the road and roundabout at Little Common. As regular drivers along this route will know the eastbound flow in 2015 often has mile long queues and the westbound flow queues can be in the order of 0.5 miles.

A late appearance of a note about the impact of the traffic generated by the proposed developments does little to relieve the concern. (This document does not meet the full requirements of Guidance on TransportAssessment - DoT 2007.) There are a number of reasons for this. The housing data does not reflect that current figures used elsewhere in the DaSA documentation and there is no reference to any industrial development that is considered so important to the mix. The traffic is assumed to be all cars whereas the road carries a significant portion of HGVs and regular buses that add to the volume and delays experienced by users at present.

No effort has been made to consider the combined impact of the new junction/lights required to provide access to and egress from Barnhorn Green (already granted planning permission) nor the pedestrian crossings before and after the roundabout and that a primary school is also situated close to the roundabout. Surprisingly all the data used assumes that all approach roads to the roundabout have a 99999 vehicle per hour capacity. This is clearly incorrect as the A259 has a capacity limit of 900 vehicles per hour and the minor road much less.

To show traffic exceeding a realistic limit makes the results of this study count for little. As is already experienced by A259 users queue lengths can be long without the impact of the new road junction and traffic lights west of the Little Common roundabout.

Please see more detailed comment and analysis at Appendix 1.
Making provision for Population Movements

If the presumption is now in favour of (housing) development then it is illogical and inconsistent not to have a presumption in favour of infrastructure development also. In particular the need to enhance road capacity to meet the expected demand new development generates.

The only sensible way to improve capacity for viable longer term traffic flow across Bexhill is to provide a new northern bypass between, say, the Lamb Inn and the Ninfield Road so linking with the new western extension from the Link Road. Undoubtedly such new construction of this nature should be part funded by the CIL raised from developers. This would be easier if the developments permitted were to follow round the north along the route of such a new road and make sites such as BX101 and BX 80 more accessible.

This approach has already been outlined in the adopted Core Strategy that states:

8.12 Growth also provides an opportunity for the town. Development has been focused on urban redevelopment in recent years, as limited transport capacity on the A259 to Hastings has frustrated new sites being developed. A high proportion of this has been flatted chemes, often for older people. However, there is the potential for sustainable urban extensions, subject to additional traffic capacity.

8.47 Housing growth may both stimulate business development as well as help otherwise achieve the vision for the town. However, large-scale growth would not be consistent with the objective of retaining its essential character, nor with the commercial property market. Even within these other sustainability parameters, the very limited highway capacity, primarily along the A259 trunk road towards Hastings but extending through the town, is a real constraint upon development at present.

8.56 Development to the west of Little Common, both north and south of Barnhorn Road (A259), will also be considered. Again, the area enjoys an attractive pastoral character, but without impacting on the wider landscape for the greater part. It also benefits from reasonable access to shops and services at the Little Common district centre. Access would need to be created directly off the A259, supplemented by existing estate roads. Whydown Road and Sandhurst Lane are unsuitable access roads.

There appears to be little point in having a strategy published and approved if some of its fundamental points are to be ignored.
Critique of Transport Note dated November 2016 (Exigo)

Introduction

This document addresses the A259 Little Common Section but fails to state any practical capacity limits on the road or other traffic relevant infrastructure such as crossings, traffic lights or the Little Common roundabout. The computer modeling used appears to have no practical limits set and it produces results these bear little, if any relation, to the perceived behavior on the A259 at this location.

The so called SHLAA sites to not correspond totally with the Preferred Options in the DaSA and so render the overall results as unreliable for drawing any proper conclusions regarding long term traffic impacts. The traffic being modeled does not include any HGV or regular bus services.

Guidance on Road capacities is published in TA79/99 and based on the parameters of this road the A259 may be classed as UAP3 with a capacity of 900 vehicles/hr each way. This is the figure missing from the analysis presented.

The document addresses the situation at Little Common roundabout in isolation. Traffic is significantly affected by the overall environment where a pedestrian crossing is on the east side of the roundabout and there is a Primary School within 0.5 miles also on the east side. Furthermore, the period covered by most of the analysis (ie the future) fails to recognize the existence of the new road junction, traffic lights and pedestrian crossing required to serve the already approved development at Barnhorn Green west of the roundabout.

Before presenting an alternative and more complete analysis there are 2 further comments. This note states it addresses the impact of site BX116. In particular the table at 4.2 stating a current Barnhorn Road queue length of 12 vehicles at the peak hours bears no relation to actual queue lengths now experienced (in the order of 1 mile or approx 300 vehicles). However, it states at 4.3 queue lengths after the SHLAA completion would be 132 and, if Spindlewood Drive (BX116) is added, at 4.8 this is extended to 155 (or a 17.4% increase). If these figures are multiplied by the factor the current situation is out then 25 times these numbers may be the outcome (possible 10 mile queue!!)

Alternative Analysis

Current Traffic figures (possibly measured in 2015) have been provided by Highways England (Table 1) together with a diagram of the Little Common Roundabout (Diagram 1). Projected traffic is based on the housing and industrial premises proposed in the DaSA suitably weighted using the data already published in support of the Link Road submission in 2011/12.

The final situation is quite complex and I have not found a way of determining the cumulative effect. However it is possible to surmise the impact of the new Barnhorn Green access road, the combined effect of the Roundabout , pedestrian crossing and Little Common School and how these would impact on the A259 flow.

While the professional Traffic Analysts have access to advanced software to assist them I have had to use manual methods. My analysis is based on models with fewer parameters but produces results confirmed by current experience of users of the A259. All calculations have been made using Excel spreadsheets. The models are in published documents and the empirical model used to examine the overall situation on the Roundabout follows published work in the USA about a very similar situation.

Current Traffic

The (2015) measured level of A259 traffic reveals a both way 24 hour total of 21452 vehicles with a peak period between 0700 and 1900 when the average levels are 748 vehicles/hr eastbound and 735 vehicles/hr westbound. Max levels at 1000hrs (westbound) and 1600hrs (eastbound) are 750 and 869 respectively. These are carried on a road that has a capacity of 900 vehicles per hour in each direction.

A very recent traffic survey over a 3 day period (September 2016 as reported in Reference A. 3.1.10 revealed total 2 way traffic to be 23530 vehicles/day. This is an increase of 9.6% over a single year.

Projected Traffic

It has not been possible to get projected traffic figures for the A259, so far, from Highways England. So using the TRICS Generation Rates in Table 2 and the DaSA development targets for houses and industrial premises a comparison has been made with the forecast figures published in support of the Link Road submission, See Table 3. The proposed DaSA buildings are shown to generate 1309 vehicles/hour at peak times. An average of 834 vehicles per hr and a daily total of 20000 vehicle movements per day. This figure has been scaled to reflect the difference between this amount of building and that used in the Link Road submission and scaled for the Barnhorn Road levels shown in that submission (See Table 4). This gives a total of 14059 vehicles per day compared to the figure of 19600 calculated for projected building in 2011. This needs to be uplifted by the percentage increase measured in current actual traffic (21500-18200)(*100/18200) or 18%. Giving a prediction of an extra 16570 vehicles per day on the A259.

On the assumption that the traffic pattern follows the curve shown in Diagram 2 the peak 12 hour traffic will be approximately 552 vehicles/hour and the daily traffic both ways increased by about 8285 vehicles. Hence total peak hour traffic demand will rise to approximately 1250 vehicles/hr both ways along the A259.

In Reference A. 5.2.5 the projection for A259 base traffic for 2026 is 27382 vehicles/day. This alone means the peak hour traffic will rise to 1047 vehicles/hr, well in excess of the A259 capacity, without considering any additional contribution from the developments proposed in the DaSA.

Other Planning Applications like Reference A, if approved, will only serve to add further additional traffic (about 160 vehicles per day) to the A259.

Traffic Lights at New Junction for Access to Barnhorn Green

In order to provide access onto the A259 from the Barnhorn Green approved development the Developer proposes to create a junction with traffic lights about 800m west of the Little Common Roundabout. Diagram 3 refers. This junction will be single lane except for the north turning traffic on the west bound lane of the A259 where an unspecified length of waiting space is planned for this traffic. Hence A259 both ways traffic will need to be halted for right and left hand turning traffic from the new access road and for the right turning traffic into the new road the A259 eastbound traffic will need to be halted. Depending on the volume of traffic turning right into the new access road A259 westbound traffic will be halted once the waiting lane is full.

An analysis of the effect of this junction and lights using a 1:4 ratio for the Barnhorn Green/A259 traffic (171:748 approximately). This is shown in Table 5. Using an arbitrary traffic light cycle of 174 seconds this shows average delays of nearly 9 minutes and capacity through the junction of 45% of the demand. Clearly the parameters used for this junction will have a critical and potentially deleterious effect of the A259 traffic flow in the short term and become a very serious blockage in the long term should the predicted traffic levels not be reduced. Reference A also proposes an uncontrolled pedestrian crossing to the east of the Barnhorn Green junction and this will added to delays experience by A259 traffic.

Little Common Roundabout Capacity

The configuration of this road junction is shown in Diagram 1. A check analysis of the circumstances experienced by users of this roundabout and of its capacity has been made (Table 6). This reveals the junction is at design capacity for a lot of the time and explains the queue lengths of about 1 mile experienced by east bound traffic at present.

Future Roundabout Performance

In the future traffic will be increased due to Barnhorn Green and the other developments proposed in DaSA. In particular, the proposed BX116 site will double peak hour conflicting traffic from Cooden Sea Road. An empirical formula has been derived from work in the USA for a similar situation of a roundabout, pedestrian crossing and local school and is felt appropriate to adopt this to predict the effect on traffic of the Little Common Environment. Table 7 presents this analysis and shows queue lengths of 1 mile (today) extending to 3 miles (post Barnhorn Green) and then 7 miles following
completion of all developments. (Note that the impact of the turning traffic into Barnhorn Green junction examined above has not been factored in). Such a situation would be intolerable for A259 users and local residents and must not be allowed to just happen through inaction to achieve rerouting of traffic. The impact on emergency services is also likely to be severe. Specifically, ambulance access to, and transfers between, the Eastbourne DGH and the Conquest at Hastings.

Conclusion

The traffic loading of the A259 has been a matter of concern for many years although no mitigation schemes have been completed in full. This latest proposed round of building in the Bexhill area will cause even greater loading on a trunk route already running to near capacity for a significant part of each working day. In recent years the traffic levels have been steadily rising. Analysis shows that the total anticipated additional traffic load will saturate the road and the Little Common Roundabout unless steps are taken to provide alternative routes for traffic traversing the district. A total approach to the problem is required rather than the current situation where planning responsibilities are divided and communications between the players appear to be inadequate. Further, analysis of the potential problems should not rest solely with those who have a vested financial interest in individual projects but with public servants who should be able to provide a proper overview of the complete situation. Piecemeal examination of the effect of individual developments does not reveal the full picture.

Additional supporting information was supplied which can be viewed here:
http://www.rother.gov.uk/CHttpHandler.ashx?id=28223

I do not agree with BX116 - Land off Spindlewood Drive, as this is a GREENFIELD site. See detailed comments to Questions 35.

I am writing to express my wholehearted objection to the inclusion of BX116 amongst the possible sites for new housing development, although I am conscious of the pressures Rother District Council are under to provide a suitable number of properties to meet their target of 3100 by 2028.

1. Infrastructure

I. A major issue that seems not to have been addressed in any development in Little Common Village, and in this DaSA documentation, is the lack of infrastructure planning to support proposed developments. Already planning permission has been granted for 342 houses on Barnhorn Green and I understand that there are other planning applications in the pipeline or approved for Ashridge Court (RR/2016/3206/P - 31 properties), 45/47 Barnhorn Road (RR/2016/2430/P - 10 dwellings, 63/65 Cooden Sea Road (RR/2015/3103/P - 8 properties) and 40/42 Cooden Sea Road (RR/2016/3254/P - 9 properties). Surely, no further developments should be contemplated for the Little Common area until and unless a Little Common by-pass has been constructed joining the A259 near The Lamb Inn to Ninfield Road joining with the new North Bexhill Access Road (NBAR) and an impact assessment on Little Common Village and the A259 has been completed after the Barnhorn Green development has been built and been in existence for a period of several years.

ii. I see that there are other and indeed more suitable sites available to provide at least some of the housing; in particular (a) site ref BX124 (Option 2) off the NBAR where up to 65 dwellings can be provided with far better infrastructure availability and (b) site ref BX101 (Northeye) - a brownfield site with up to 115 houses proposed. I understand that it is government policy that brownfield should always be preferred to greenfield, according to the National Planning Policy Framework document (NPPF).

iii. Surely, it makes more sense to defer any decision on BX116 for at least 5 years and until final decisions are known on residential dwellings for BX120 (Barnhorn Green), BX124 (NBAR) and BX101 (Northeye) as well as other proposed developments in the area. The need for any further development along the A259 around Little Common Village might then be seen to be redundant.

iv. Given the above comments, were permission to be granted for any proposed development in the Little Common area, the questions I have to ask are:

1. Where are the children to go for their primary or secondary schooling? Little Common Village Primary School is already at capacity.
2. Where are the Doctors' surgeries? Little Common GP Surgery is also already at capacity or near capacity.
3. Little Common is a village with very few local jobs, which means that residents must drive to work putting more pressure on the existing roads.
4. Parking by parents for the primary school has increased significantly on Birkdale and is hazardous at the best of times, with vehicles parked on both sides of the road, frequently on the pavement and green verges. It is also on a major and busy bus route, which causes huge traffic congestion at put down and pick up times. There will be even greater problems if, for instance, a bus or large vehicle is going one way and an emergency vehicle wants to go the other way. This can only worsen and there is an accident or incident waiting to happen here.
5. The only parking for the doctors' surgery is down a side residential road, which is generally completely full of cars.

There is no evidence of any of these issues being considered or addressed properly in any of the proposals.

As a local resident of almost 35 years, I have to say that a proposal for 160 houses is far too dense for this area and the available local infrastructure. The density could be reduced by building the affordable housing off site (e.g. site ref BX124 or BX101) and taking into account any future submitted planning applications in the immediate area, as mentioned above. This could reduce the residual housing need to no more than 80 properties and perhaps considerably less. At least, any decision on future developments should not be contemplated until the full impact of the Barnhorn Green development, along with other current proposals, has been fully assessed.

2. The proposal for site access off Spindlewood Drive, if this site were to be approved, is totally inappropriate for the local roads and it must be instead off Barnhorn Road. Furthermore, this is in accordance with RDC's Local Core Strategy Paper of September 2014, paragraph 8.56.

a. Due to the lack of suitable infrastructure, nearly all traffic resulting from the above listed developments will arise from the need by residents to use their cars to go to work, take children to school and to go to large shopping centres. This is harmful to the environment and will generate additional noise and air pollution especially around the A259. Little Common Village provides only limited village amenities.

b. As already stated, there are serious car parking issues in and around Little Common Village with frequent and obvious breaches of parking laws as people double park or park on double yellow lines and on pavements and verges.

c. Any further large residential developments in or around Little Common Village will consequently tip the local infrastructure into a state of crisis and surely must not be approved nor permitted.

3. Conclusion

d. The proposed development off Spindlewood Drive is not required and is inappropriate and would be highly detrimental to Little Common Village as a whole.
e. Alternative sites are far more appropriate in terms of access and exiting or planned infrastructure facilities and minimal environmental damage, especially the NBAR site (BX124)
f. RDC must take small site windfalls into account when estimating the likely numbers of properties to be achieved up to 2028.
g. Spindlewood Drive (BX116) can then be removed from the second DaSA consultation process as it will have become superfluous.
h. RDC must defer any decision on BX116 for at least 5 years and certainly until the impact is known from the residential dwellings built on sites BX120 (Barnhorn Green), BX124 (NBAR) and BX101 (Northeye) (if approved) as well as other proposed developments in the area.

1. Executive Summary

1.1. These representations are made to the Rother District Council Development and Site Allocations Local Plan Options and Preferred Options Consultation that runs until 20th February 2017.

1.2. Representations are made on behalf of Mr Donald Gill and seek to promote an area of land, in Mr Gill's sole ownership and amounting to 13.8 Hectares, at Preston Hall Farm, Watermill Lane, Bexhill on Sea. This parcel of land is shown on the attached location plan (Appendix 1), and herein is referred to as "The Site". It is not currently allocated for development in the Adopted Plan, but is shown within the Options and Preferred Options Consultation Document as forming part of the North Bexhill Strategic Mixed Use allocation (Emerging Policies BEX2 and BEX3).

1.3. The Site is currently shown as being suitable for a combination of residential development, commercial development and green / amenity space. However, these representations illustrate that The Site is more than capable of accommodate a larger quantum of residential development than is proposed or expected by Rother District Council. This higher quantum would assist in ensuring that Rother District Council meets its objectively assessed need for housing over the plan period with a suitable uplift included to accommodate changes in market signals, employment and migration.

1.4. Development of The Site meets all requirements of the National Planning Policy Framework in respect of the social, economic and environmental dimensions of sustainability. The development would provide housing that is needed in a popular location and is highly accessible to local facilities and a range of public transport modes. The wider development of The Site would complement the area and through an appropriate design would complement the character and appearance of both the natural and built environments. Provision of some open space within the site, that provides a useable, accessible amenity space for the general public, would have clear social and health benefits which would further enhance the wider locality and ensure that the new residential development within The Site has an attractive, welcoming environment for future residents to enjoy.

1.5. Rother District Council adopted the Core Strategy in 2014. This does not include allocations of land, hence the need for a further strategic document including allocations. The Core Strategy set a target for 335 dwellings to be built per annum through the Core Strategy Period. In order to ensure that this target is, at the very least, met, and that the housing required in the district can be provided, it is essential that the best and most efficient use is made of available, deliverable housing sites. This is even more applicable to those sites, such as The Site at Bexhill, which are recognised by the Council as being suitable as part of the Emerging Site Allocations Document.

1.6. The Site is not subject to any statutory designations and there are no physical or legal restrictions over the land that would prevent it from coming forward early on in the Plan Period. The Site can make a valuable contribution towards housing delivery and therefore the proposed allocation should be amended to reflect a more comprehensive and efficient use of The Site.

1.7. These representations comment on the proposed allocation of The Site in much more detail, in addition to various questions specific to proposed policy text and subjects which are also included in the consultation. This expands to matters including of housing, strategic gaps, landscaping and ecology.

1.8. In conclusion, these representations illustrate that in order for Rother District Council to achieve a Plan that can sufficiently meet the needs and requirements of the District's population, it is essential that a wider parcel of land within The Site is allowed to be developed for housing. It is also identified that there should be some other changes to the proposed development option under policy BEX3 that would allow the best possible use of this site to be made.

2. Introduction

2.1. On behalf of Mr Donald Gill ("our client"), Savills is responding to the Rother District Council (herein referred to as "The Council" or "RDC") Development and Site Allocations Local Plan Options and Preferred Options Consultation (herein referred to as "the DaSA"). The consultation closes on 20 February 2017.

2.2. The purpose of the DaSA is to allocate land for a range of development types, notably, housing, commercial and community facilities. Once adopted, the DaSA will form part of the Development Plan alongside the Core Strategy, adopted in September 2014.

2.3. The Government, through the National Planning Policy Framework (NPPF) requires local planning authorities (LPAs) to plan positively, seeking new opportunities for development that can meet the identified needs of their respective District or Borough. Sufficient flexibility must be applied to allow for rapid change. To achieve this, LPAs must have an up to date Development Plan that has been informed by an extensive evidence base, formed from various technical studies and reports that have been through a rigorous consultation process and, essentially, justify the proposals within the Emerging Plan. Much of the evidence base supporting the Core Strategy will apply to the DaSA Consultation. However, additional documents have been published, including the following:

* Sustainability Appraisal of the DaSA
* Strategic Gap background Paper
* North Bexhill Landscape and Ecological Study (Report 1)
* North Bexhill Appraisal and Recommendations of Development Options (Report 2)
* Green Infrastructure Background Paper Addendum
* Employment Sites Review Background Paper
* Water Efficiency Background Paper
* Site Assessment Methodologies Background Paper
* Rother and Hastings Playing Pitch Strategy
* Renewable and Low Carbon Energy Background Paper
* Other evidence, notably that prepared for the Core Strategy

2.4. Those highlighted in bold are directly of relevance to this representation and will be referred to where appropriate.

2.5. Evidence from the Core Strategy that is also referred to where applicable includes:

* Strategic Housing Market Assessment 2013
* Assessment of housing need in the Hastings and Rother HMA
* Strategic Housing Land Availability Assessment June 2013

2.6. This representation is divided into 4 main sections. The first provides details of The Site. The second examines relevant evidence base documents. The third section then reviews relevant development policies which form the first element of the consultation. Key policy areas considered here are housing, the environment and implications. The final section in this representation reviews the proposed allocations, specifically North of Bexhill and policy BEX3.

2.7. Throughout each of these chapters, comments are applied in relation to The Site and how, in our opinion, RDC should look to amend or update the Emerging DaSA to correctly reflect The Site's capacity.

2.8. The remaining section provides a summary of the representations and comments relating to The Site.

2.9. Savills reserves the right to comment further on any of the consultation documents at a later date, where applicable to representations that may be made before adoption of DaSA Local Plan.

3. The Site

3.1. The Site is located to the north east of Bexhill and comprises an area of 13.8 hectares formed of a number of vacant parcels of land associated with Preston Hall Farm, a detached chalet dwelling. There are also a number of former agricultural barns within a complex located to the west of Preston Hall Farm. These buildings, including the existing dwelling, would all be removed as part of the allocation of land for housing in the Local Plan 2006, under policy BEX3. There are some planting and landscape features in and around The Site which also has an undulating topography.

3.2. Adjacent to Preston Hall Farm are two properties associated with Preston Hall. Both Preston Hall and the Cottage in the Grounds of Preston Hall are Grade II Listed Buildings (listing entry: 1044252 and 1044253 respectively) and sit in a plot of circa 4.5 acres. The properties have been vacant for some time and are understood to be in a poor state of repair. They are however well screened from the surrounding area by mature boundary planting. Both are considered to have limited heritage value. This view is supported by the proximity of the housing allocation under policy BEX3 of the Local Plan 2006. In addition, the grounds of Preston Hall are shown on the Proposals Map as open space.

3.3. The Site as outlined in red on the location plan in Appendix 1 is currently divided by a strip of land which runs in a west to east direction and broadens towards the east. This parcel was voluntarily sold to Seachange, in common with the land associated with the strategic employment allocation under policy BEX3 of the Local Plan 2006, and specifically serves the relief road around north eastern Bexhill including associated mitigation land. Works for this road have commenced on site. Photographs of this area and The Site are contained in Appendix 2.

3.4. Figure 1 shows The Site in relation to the land for the relief road and relevant elements of the strategic allocations under BEX3 of the Local Plan 2006. Figure 1 also shows the use of Preston Hall as open space as per the current proposals map.

3.5. Access to The Site is currently gained via Watermill Lane which traverses in a south to north direction from Bexhill towards Catsfield. This access also serves Preston Hall Farm with associated existing outbuildings, garages and agricultural barns. This also provides access to the, now vacant, properties at Preston Hall. Watermill Lane is predominantly defined by mature (some gaps) planting with dispersed access points.

3.6. The majority of The Site falls within flood zone 1, and has the lowest fluvial risk of flooding. However, the Combe Haven waterway runs through the southern part of The Site in a west to east direction. This waterway is essentially a narrow ditch, with the benefit of an existing crossover. This, and an adjacent narrow strip of land, is within flood zone 3.

3.7. Throughout The Site, topography changes considerably. The relief road is sited in a high position along a stretch of flat landscape. The Combe Haven is one of the lowest land levels, with inclines away from this valley. The plan of The Site in figure 1 also indicates the level changes.

3.8. A public footpath runs through the site in a north to south direction. This is understood to be Footpath no.16b with stiles, gates and bridges along its length.

Figure 1: Annotated Site Location Plan Extract (not to scale): http://www.rother.gov.uk/CHttpHandler.ashx?id=28186

3.9. The main settlement of Bexhill lies to the south / south west and is currently separated from the site by a small field. This field was subject to an allocation for housing in the currently adopted local plan for Rother. This field is relatively flat and, as such, there are clear views of the existing residential area of Bexhill from our client's site. The relationship of The Site to this adjacent housing allocation and the wider settlement of Bexhill is a material consideration of weight.

3.10. The Site falls partially within identified area BX124 "North Bexhill" as indicated in figure 19 of the DaSA. This is shown as a preferred option for residential development in the Emerging Plan. This is examined in more detail in the remainder of this representation. However, some of The Site is not currently part of this allocation, despite having a direct relationship to the existing settlement, and the Strategic Allocations. This representation will demonstrate that The Site, as a whole, should be included in the DaSA for a housing allocation.

4. Evidence Base

Sustainability Appraisal

4.1. Rother District Council has published a Sustainability Appraisal (SA) specifically of the Development and Site Allocations Local Plan, Options and Preferred Options. This assesses the proposed policies and development options against specific sustainability criteria, and each are scored based on their anticipated benefits and / or adverse effects. Question 1 of the DaSA consultation asks specifically for comments on the SA and therefore the following should be read in response.

4.2. The sustainability appraisal does not examine site BX124 "North Bexhill", which forms part of the strategic development options under policy BEX3. Instead, the SA of the site is contained in its own document entitled "North Bexhill - Appraisal & Recommendations of Development Options' which is examined below.

4.3. Despite not assessing site BX124, the SA does review policy BEX3: "land at North Bexhill" against the SA objectives. The policy is assessed as resulting in significant beneficial effects, supporting objectives, having no effect or uncertain effects. At no point does RDC conclude that the policy would cause conflicts or significant adverse effects.

4.4. We generally concur with the conclusions of the SA regarding this policy. It is agreed that the site is in a sustainable location, and that the site is capable of bringing forward essential market and affordable housing for this locality. However, reference is made to other land uses, which as discussed further below, are not considered appropriate for this location, and should be relocated away from our client's land. In particular, part of the adjacent landholding is shown as a potential site for Gypsy and Traveller pitches. This parcel of land was sold to Seachange specifically for use on the relief road and associated mitigation works. The contract states strict controls on the future use of the land. Legally therefore, the proposed allocation of this parcel for gypsy and traveller pitches, cannot take place. RDC should therefore review this with their appointed legal team before finalising any proposals.

Strategic Gap Background Paper

4.5. The Strategic Gap Background Paper assesses 5 strategic gaps in the District. The aims of the strategic gaps are to maintain separate identity and distinctiveness between settlements, maintain settlement patterns and prevent coalescence of settlements.

4.6. Of relevance to The Site is the Bexhill and St Leonards strategic gap which is proposed to be extended in a westerly direction, covering the area of the Combe Valley Way and recommended to include the Combe Haven valley and its tributaries. The proposed extension to the Strategic Gap is highlighted in red on Bexhill Map 1 in the Strategic Gap Background Paper, a relevant extract of which is produced in figure 2 below. This is on the basis that the gap has been subject to considerable change with development of the Combe Valley Way releasing land for the north of Bexhill Masterplan.

Insert: Figure 2: Extract from Bexhill Map 1 - Strategic Gap Background Paper

4.7. Whilst it is understandably necessary to protect landscape character and the relationship of one settlement with another, it is important to stress that our client's site does not have the characteristics required to contribute to the strategic gap. Notably, The Site is not required to create a separate identity between Bexhill and any nearby village, town or settlement to the north or north east of Bexhill. The Site represents only a few small parcels of farmland, land that has a direct relationship with the settlement and an allocated residential site to the immediate south west. It is also not sufficient an area to prevent, or in any way influence, the merging of two adjacent settlements, bearing in mind the significant proximity between Bexhill and other nearby villages beyond the site.

4.8. Therefore, whilst it is not entirely clear from the Strategic Gap Plan what land is proposed to be included in the gap, it is abundantly clear that our client's site is not, and should not, be included within that area. In fact, The Site provides an excellent opportunity for new residential development that can contribute positively to the character and appearance of the area and to ensure the housing needs and demands of this locality can be sufficiently met. Land to the north, including the ancient woodland, clearly provides a
defensible feature to assist in meeting the strategic gap objectives.

North Bexhill Landscape and Ecological Study (Report 1)

4.9. The purpose of the Landscape and Ecology Study (Report 1) was essentially to assess the capacity of the study area - i.e. the North Bexhill Strategic growth area - for housing growth. The conclusions inform "Report 2" and enable RDC to review its growth options for the area and ultimately decide which is most appropriate in landscape and ecological terms.

4.10. It should be stressed that whilst landscape and ecology considerations are essential to determining whether land should be used to provide new development, RDC must ensure that other material considerations are also taken into account, and that an appropriate balance is drawn between, what essentially could be, competing interests.

4.11. It addition, it is of concern that the study area only covers the specific, identified boundary of the strategic growth area and does not consider any land immediately adjacent to it which is shown within the DaSA as forming a part of the strategic options. For example, our client's land at Preston Hall Farm is shown in the DaSA as forming land for housing, commercial development and landscape / amenity space. However, there remain areas of land which are close to the established settlement and adjacent to the strategic allocation North East of Bexhill, but which are not included in this assessment. These areas relate directly to the existing settlement and provide a clear opportunity for new development to be provided where it is likely to have a lesser impact both physically and visually on the wider area. If such land were to be assessed, it would be clear that there are no ecological or landscape constraints and that a development opportunity does exist.

4.12. On this basis, whilst the majority of our client's Site is included in the study area, key elements of it have been excluded and this does not, in our opinion, reflect a full objective assessment of all land opportunity in this location and the associated landscape and ecological constraints that may or may not exist. Further investigation of the land surrounding Preston Hall Farm should therefore be undertaken.

4.13. Notwithstanding this, the Landscape and Ecology Study identifies that the remainder of our client's land falls within the Combe Haven Local Character Area, which is described as:

* "Focal, open, flat valley floor with wetland.
* Intricate terrain of small winding valleys and ridges around levels, with abundant woods and ghylls.
* Extensive areas of Ancient Woodland.
* Contrast between valley floor and slopes"

4.14. The study area is divided into smaller parcels for assessment. The Site falls within area "LDU A" which is described as having south facing slopes, landforms that generally slope towards the watercourse (Combe Haven) and rising towards Preston Hall. Importantly, it is recognised that the ancient woodland to the north east of LDU A encloses the land to the east and particularly from the north (section 2.4.2) and that the North East Bexhill strategic growth area will enclose Preston Hall Farm to the south.

4.15. Figure 2.20 provides a plan of the area and indicates conclusions of the landscape assessment of the area. For completeness, an extract of this is produced in figure 3 below.

Figure 3: Extract of figure 2.20 from the Landscape and Ecology Study - Report 1: http://www.rother.gov.uk/CHttpHandler.ashx?id=28188

4.16. As can be seen in figure 3 above, there is a narrow strip of land between the housing and employment land allocations under BEX3 of the 2006 Local Plan (south) and the proposed allocation for North Bexhill in the DaSA. The land would be entirely enclosed by built form. There is no practical reason therefore why this land should not form part of the DaSA allocation and be developed to provide additional housing. This additional parcel of land provides a further good opportunity for new additional residential development to be provided where it would have a direct relationship to the settlement and no harmful impact on the landscape character. This land is not assessed fully and therefore should be subject to further review and consideration. The area is shown partially in white on the plan in figure 3, immediately above indicator A1 and partially as an area of restraint, although this has not been fully explained in the document.

4.17. This additional parcel of land clearly provides an important opportunity for development. However, if it were not allocated, it is envisaged that pressure may arise in the future for its development due to its direct links to the built up area and strategic allocations. Allocation of the land would allow RDC to work with the landowner to secure an acceptable scheme that appropriately reflects the built and natural environments.

4.18. The assessment has concluded that land north of the new relief road from Bexhill (zone 2) has a "Moderate to High" sensitivity, with views from the immediate north. However, we do not consider this to be entirely accurate. It is fair to say that some of the area north of the relief road is visible from the north, owing the limited amount of mature boundary planting provided to divide fields. However, the central field in this area is enclosed to the north by mature boundary planting. This can be seen in the photographs provided in Appendix 2. It also falls in a valley between the high level relief road and a south facing slope that extends beyond the field itself. The land here is enclosed. It is not visible from the north and is not considered to be highly sensitive to change. In our view, this landscape can sufficiently accommodate development without a harmful impact resulting on the surrounding area.

4.19. In terms of the detailed assessment, this provides a general description of "LDU A" and rates both zones 1 (southern portion) and 2 (northern portion) against the landscape sensitivity categories. However, whilst there is some description provided, the assessment does not say clearly why the areas are concluded to have the stated sensitivities. Indeed, it is not clear in the report what specific landscape factors have influenced the conclusions. This is left to interpretation of how the assessor applied each of the landscape and visual criteria in the methodology (section 2.2).

4.20. Furthermore, the document precludes consideration of the impact of the new road on the landscape. This relief road runs through "LDU A" and, as illustrated in figures 23, 24 and 25 of the DaSA, provides the only access into the new development forming part of the allocations. It is clearly a very material consideration from a landscape and visual impact perspective and failing to consider this skews the findings of the assessment, particularly as the relief road is currently being constructed.

4.21. An example of this is under visual receptors. The report concludes that the areas have moderate to moderate high sensitivity as there are no views to, from or of main roads. However, the new road is under construction and will be a significant visual feature in this locality. Not only will it be visible, but as it will serve as the only access into the new development area, views will also be available for all future residents and users. Its presence is therefore highly significant and would clearly affect the character and sensitivities of the area. It should therefore have been taken fully into account.

4.22. With regard to mitigation, the assessment concludes that development should be avoided on land that would impact on the setting of Preston Hall. Whilst the intentions of this are understood, the assessment is not a heritage assessment but rather a review of the landscape and ecology only. As such, there is currently no evidence to justify this conclusion, and it is reasonable to expect that rather than relying on these comments, RDC will be undertaking a separate heritage assessment to determine whether it is reasonable to restrict development surrounding Preston Hall. Due regard must also be given to the Local Plan 2006 strategic allocation at North East Bexhill (BEX3) which includes development in the immediate vicinity of the Listed Buildings. In the absence of evidence to contrary, this suggests that the Listed Building is not of any significant heritage value. Therefore the development of land to the north should not be precluded.

4.23. Chapter 3 goes on to review ecological considerations. This examines the area more broadly and does not subdivide it as has been done for the landscape review. Consequently, comments are relatively generalised and it is left to the reader to establish which features are applicable throughout the study area. This makes it difficult to establish what, if any restrictions there may be or what habitats may be present on individual parcels, and therefore, somewhat difficult for landowners to apply the findings and establish what mitigation or improvements may be required on their land. RDC should revisit the study as it does not provide the clarity or certainty required to support the DaSA at present.

4.24. The report suggests enhancements could take place along the Combe Haven watercourse. This would need to be considered in the context of proposals for The Site. However, given that much of the area shown as an opportunity area is within a higher risk flood zone, it is reasonable to assume that some habitat and ecological enhancements could be provided in this location. In any event, detailed site investigation would be undertaken before a planning application were pursued and so should the need arise, proposals would incorporate habitat protection and enhancements wherever possible and in line withtechnical assessments carried out specifically for The Site.

North Bexhill Appraisal and Recommendations of Development Options (Report 2)

4.25. This is the second appraisal document for the North Bexhill Strategic proposals and importantly, recognises that the strategic development will make a significant contribution to meeting the town's development needs, in tandem with the allocated development at North East Bexhill. We concur with this conclusion and consider that The Site as a whole, including land currently excluded from the strategy, makes an essential contribution towards the growth of Bexhill. It would provide the land required for new housing that will not only secure the anticipated residential quantum for Bexhill, but also help to meet the identified local housing needs over the plan period and address the current housing shortfall evidenced by the very limited housing land supply that RDC currently has (3.9 years of the required 5 years as of April 2016).

4.26. With regards to the structure of Report 2, it essentially summarises the findings of Report 1, highlighting areas where the most and least landscape capacity are considered to be sited. In section 2.3.3, it is suggested that land to the east of Watermill Lane, notably where The Site is located, has moderate capacity to accommodate new development in conjunction with the planned extension at North East Bexhill. However, the report also suggests that without the planned extension, development of this area would cause harm to the landscape. In addition, it is suggested that development should be avoided on lower slopes of the valley around the listed Preston Hall as this would intrude on its setting.

4.27. The Site forms land surrounding Preston Hall to the north, east and west. As clearly stated in this representation, Preston Hall is a vacant building and is in a poor state of repair. It is not considered to be of considerable heritage value. RDC has not carried out a review of this heritage asset or its merits. As such, whether it is to be surrounded by development or not, cannot be judged fully at this time.

4.28. In any event, land to the south, south west and south east of Preston Hall is subject to existing allocations for residential and employment use (see figure 1). It would be surrounded by development and its setting considerably changed. Subsequently it is clear that there is scope for additional development at The Site, within the vicinity of Preston Hall, without a detrimental impact being caused.

4.29. In section 2.5, a "Strategic Regulating Plan" is produced to illustrate the findings of Report 1. Interestingly, this shows an area of ecological improvement along the northern strip of the Combe Haven only. This strip of land does not extend to the south and subsequently does not immediately reflect the findings or suggestions in Report 1. It is considered therefore that this extended northern strip is not required.

4.30. Nevertheless, whilst ecological enhancements are necessary, it is questionable whether the right location for this is between two major strategic growth areas. This area, unless specifically designed as amenity land, would likely be subject to considerable pressure for public access, including dog walking and could therefore upset the ecological balance which the DaSA is seeking to create. Subsequently, a more logical approach would be to provide some moderate landscape enhancements in this location and relocate ecological and biodiversity enhancements elsewhere where they can better relate to the surroundings.

4.31. The accompanying text to the Strategic Regulating Plan also suggests that the landscape to the east of Watermill Lane has a "moderate to low" capacity to accommodate development, whereas the Plan and detail in Report 1 suggests that this area of land actually has a moderate capacity to accommodate development, and it is only the area of land north of the new bypass road (formerly shown as zone b in LDU A) that has a moderate to low capacity. This should be appropriately modified.

4.32. In section 2.6 a set of guiding principles are detailed that are to help shape the final strategic option for North Bexhill. Whilst it is appreciated that Report 2 follows the findings of Report 1, it is important to ensure that the strategic allocations are not simply being determined on the basis of landscape and ecological consideration. Other material considerations must inform the final decision to ensure the DaSA is found sound. At present, the focus of the guiding principles on ecology and landscape does not demonstrate that this has been satisfactorily achieved. Nor does it demonstrate that the best and most efficient use of land will be made as part of the strategic allocation.

4.33. In chapter 4 a sustainability appraisal (SA) is carried out for the three development options at North Bexhill which are detailed in chapter 3. Question 1 of the consultation document specifically asks for comments on the SA of the DaSA. These comments should therefore be read in relation with that question.

4.34. Essentially the three options show a small, medium and high level of growth. In terms of dwellings, they propose 420, 480 and 630 dwellings respectively. These options are examined below in relation to the DaSA. Here, figure 4 provides a copy of the SA summary of the three options against the 16 SA objectives.

Figure 4: Sustainability Appraisal of the three development options - from figure 5.1 of Report 2 North Bexhill Appraisal and recommendations of development options August 2016: http://www.rother.gov.uk/CHttpHandler.ashx?id=28189

4.35. Based on the SA, RDC indicates that option 1 (lowest level of growth) is the preferred development option. However, there is only 1 objective of the 16 that enables this conclusion to be drawn compared to option 2, namely objective 14. Objective 14 is to conserve and enhance biodiversity and geo-diversity. The report argues that the preferred site would meet objectives for protection of habitats whereas option 2 could not achieve this and that option 3 would have an unacceptable impact. Overall it is stated that development options 2 and 3 lack containment and by proposing commercial development near to the woodland, would result in, "on balance, a slightly increase landscape impact". This statement does not provide the certainty required to illustrate that the option 1 is the only appropriate strategy, particularly as option 1 would fall short of meeting the greater development (employment and residential) needs of the area, which both options 2 and 3 would clearly offer more comprehensively.

4.36. In this regard, it is highlighted that chapter 13 "Bexhill" of the DaSA states very clearly that "the amount of business accommodation is relatively low for the size of the town" (para 13.5). If this is the case, RDC must ensure its allocations address the need for additional commercial space. Option 1 does not allow sufficiently for this and therefore cannot be said to comply with the economic role of sustainability as set out in the NPPF. Equally, by providing a lower amount of development Option 1 would not make the best use of available land, would make a lesser contribution to meeting the identified housing needs in Bexhill and would potentially fall short of NPPF requirements by failing to allow for sufficient flexibility to accommodate change over the plan period.

4.37. Bexhill is required to contribute to over 54% of the District's housing requirements over the Core Strategy period. The North Bexhill Strategic Allocation, must therefore make a substantial contribution towards this and further regard should be given to options 2 and 3 which offer higher growth potential. This is emphasised by the minor differences between the SA for the three options which are essentially based on only 1 of the relevant 16 sustainability criteria.

Site Assessment Methodologies Background Paper

4.38. Having reviewed the assessment criteria used, we have no comments at this time. However, Savills reserves the rights to comment on the assessment methodology at a later date should the need arise with specific regard to our client's site at Bexhill.

[SECTION 5 HAS BEEN ENTERED INTO JDI]

6. Strategic Allocations

6.1. Part C of the DaSA provides the site allocations for development. Of specific interest to this representation is chapter 13 "Bexhill", as our client's Site falls within this area and is partially within the strategic growth area. On this basis, comments are provided only in relation to proposals for Bexhill.

6.2. The policy indicates that of the 5,700 dwellings required to be provided over the Core Strategy period, 3,100 or 54.4% of these are expected to be provided at Bexhill. In addition, 60,000sqm (60%) of the 100,000sqm requirement for commercial space, is to be provided in and around Bexhill. Clearly, the town is to accommodate a substantial amount of the development for the District, and therefore it is essential that appropriate, deliverable sites come forward and are included in the DaSA as strategic allocations.

6.3. Paragraph 12.4 and the associated table in figure 14, suggests that committed development and completions as at 1 April 2016 already allow for 2,996 dwellings, leaving a further 1,044 to be allocated in the DaSA in Bexhill. However, at paragraph 13.8 alternative figures are provided, and instead it is suggested that 318 dwellings have been constructed, 1,631 have planning permission, and therefore, a requirement of 1,151 dwellings remains. This position must be clarified as conflicting figures may threaten RDC's plan in the long term. In any event, the housing targets are to be seen as minimum as has been confirmed on numerous occasions by Planning Inspectors, and the overall objective to boost significantly the supply of housing must play its role in supporting housing allocations.

6.4. In addition, whilst planning permissions may have been granted for a number of sites, and allocations in the Core Strategy are expected to come forward, there is no guarantee that they will come forward and therefore it is essential that RDC allows for a higher housing provision to ensure the minimum housing targets can, at the very least, be met over the plan period. The current housing land supply position of Rother further emphasises the need for additional housing land. At present, RDC can only demonstrate a 3.9 year supply of housing against the Core Strategy Target. This indicates that fewer housing schemes are coming forward compared to those expected, and that a higher provision is essential to meet long and short term housing requirements for the District.

6.5. Out client's Site at Preston Hall Farm, including land both within and outside of the North Bexhill Strategic Growth area provides an excellent opportunity for RDC to boost housing provision in this sustainable, accessible location. Additional housing on The Site, including land to the immediate north and west of Preston Hall Farm (outside of the Strategic Allocation Area), and land to the north of the bypass road (within the Strategic allocation but shown for planting) would have a direct relationship to the existing settlement and proposed settlement extensions under BEX3 of the Core Strategy and proposed policy BX3 of the DaSA. The Site would allow for a considerable number of additional dwellings on top of the expected delivery of circa 420 dwellings (preferred development option 1). The site is also available, suitable for development and deliverable within the early stages of the DaSA. It can thus make an essential contribution towards housing need and overcoming the 5 year housing land supply position.

6.6. The availability and deliverability of The Site is a material consideration of weight, bearing in mind that RDC concedes at para 13.14 that the proposed North Bexhill allocation, coupled with other preferred sites, past completions and expected windfall allowance (number not specified) would only "slightly exceed" the minimum housing target of 3,100 for Bexhill. This would not reflect the national objective as set out in the NPPF is to significantly boost the supply of housing and therefore, may risk significant objections to the DaSA as it progresses towards Examination.

6.7. Before moving on to examine the details of the DaSA allocation for North Bexhill, it is first highlighted that the details in the DaSA are considered to be somewhat misleading, as they show only the development sites for the DaSA and not those sites which are already subject to allocation and are coming forward. These other parcels of land are clearly part of the growth strategy for the area and therefore will affect the character and appearance of the surroundings. If these were shown on the DaSA proposals, as demonstrated in figure 5 below, it would be evident that there are parcels of land that will be entirely enclosed by development arising from the allocations and which are otherwise suitable for development.

Figure 5: Annotated site plan showing surrounding allocations in the 2006 Local Plan and DaSA Options and Preferred Options: http://www.rother.gov.uk/CHttpHandler.ashx?id=28190

6.8. As can be see, a large area of The Site, should be included within the proposed North Bexhill Allocation for residential development owing to its evident relationship with existing and proposed allocations.

6.9. Question 27 asks whether we agree to the preferred development sites for housing. Within the preferred list are two sites of interest - BX19 and BX124. BX19 was allocated in the Rother Local Plan 2006 as part of the East Bexhill Strategic Allocation (see figure 5 above). It remains a preferred site for development and is understood to be coming forward very shortly. This allocation directly relates to the settlement and therefore, it is expected that this will continue forward into the DaSA as an allocation for housing.

6.10. With specific regard to housing provision we agree with the proposed allocation of BX124 as this area, which includes The Site, provides an excellent opportunity for housing to be provided to help address local need. However, as illustrated in this representation, there is further land falling immediately outside of the proposed housing allocation in BX124, but that has a direct relationship to it and the settlement. Such land would also be suitable for housing, and should be incorporated into the allocation. These areas are marked in figure 6.

Figure 6: Extract from Figure 19 of the Bexhill North Housing Options, identifying key additional areas for housing: http://www.rother.gov.uk/CHttpHandler.ashx?id=28191

6.11. The DaSA produces three options for development in North Bexhill, which essentially cover BX124 and some of the surrounding land. The description of the proposed allocations in paragraph 13.21 suggests a higher quantum of development than suggested in the Landscape and Ecology Reports and SA. This should be reviewed and clarified by RDC to ensure that evidence reflects the DaSA proposals.

6.12. The three options for development shown in figures 23, 24 and 25 all show that part of The Site forms an important part of the allocation. However, they all exclude the area of land to the south west which is immediately adjacent to the two strategic allocations at BX19 and BX124 (Area "1" on figure 6 above). This is a prime development site in a location where there would be little, if any, effect on the locality. A more efficient use of the site should therefore be made to provide additional, much needed housing for the area.

6.13. In addition, land to the north of the new road is shown entirely for green space (Area "2" on figure 6 above). This land is enclosed by existing landscaping and topography, and, as a result, provides a further key opportunity site for additional housing. Option 1 (preferred option) further incorporates an area (Area "3" on figure 6 above) which is also shown as green space (shown for employment in options 2 and 3).

6.14. If RDC is to meet and exceed its housing requirements, provide flexibility to change, and reflect the requirement to boost significantly the supply of housing, it is essential that such parcels of land are put to an efficient use. From a site visit it is evident that there is sufficient protection afforded to the countryside by the existing woodland to the north; The Site is not needed for this purpose. It also does not have any defining landscape features that warrant protection over and above other areas of land proposed for allocation in the DaSA. Further review of the opportunities on this land, and principally on The Site, must be undertaken before RDC can conclusively decide that it is unsuitable for more residential development.

6.15. It is also recognised that all three options show a potential Gypsy and Traveller Site to the east of the proposed housing allocation. As highlighted above, there is a clause in the contract of sale preventing development on the site. The proposed allocation goes against this legal restriction and therefore the land should be excluded from the allocation.

6.16. RDC has also prepared a draft policy for Land North of Bexhill - policy BEX3. This indicates that a comprehensive approach will be sought to development of the area and that a SPD will be prepared for the allocation. Question 29 asks if we agree to the wording of the proposed policy including its requirement. There are 13 requirements in the policy in total, and although the aims are clear, this does seem excessive. Many of the points are already set out in other policies which could easily be referred to. In addition, a strict requirement to achieve 30% affordable housing, in addition to the considerable infrastructure and green space, may simply not be achievable and therefore whilst an optimistic approach to delivery of the site is understood, this should be left to agree as part of the SPD, allowing flexibility for the right type of development to come forward, which is, ultimately deliverable.

6.17. Figure 53 shows the proposed amendments to the development boundary of Bexhill. For North Bexhill, figure 55 provides a more detailed map. To reflect our representation, the development boundary should be amended to incorporate all of our client's land as this land would make an important contribution to housing in the District over the plan period. To illustrate this, figure 7 below provides an annotated extract of the map from figure 55, with an additional blue dashed line showing an approximate location of where the settlement boundary should be drawn. This would then encapsulate all land to the south and enable the best of the land to be made.

Figure 7: Annotated extract of 53 from the DaSA - Settlement Boundary map: http://www.rother.gov.uk/CHttpHandler.ashx?id=28192

6.18. It also appears that figures 53 and 55 exclude an area of land, currently included in the proposed strategic growth area for North Bexhill. This land lies to the west of the blue line in figure 5. RDC should therefore reassess this before finalising the Plan.

7. Conclusions and Summary

7.1. The Options and Preferred Options Consultation document for the DaSA is structured in such a way that allows consideration of the various policy options and development strategies that are being considered by RDC. However, in places, the evidence base and details of the DaSA appear to conflict, and it is considered that further evidence is required to fully support the preferred options.

7.2. In terms of North Bexhill, the preferred option essentially provides the lowest level of growth for the area. It is appreciated that some allocations in this area already exist, and that with existing planning permission and expected windfall allowance, RDC expects the minimum housing target for the area, of 3,100 units, to be met. However, this is only expected to be marginally met and in order to ensure that that plan fully accords with the national housing agenda, it is essential that a higher housing provision is allocated in this area. The NPPF is clear with regard to housing provision, meeting objectively assessed needs, and allowing flexibility to account for change over the plan period. At present, it is considered that the proposed allocation at North Bexhill does not achieve these objectives and additional land for housing must be allocated.

7.3. In addition, the structure of the DaSA is considered somewhat misleading, in that it does not show areas of land that are already subject to allocation in the Local Plan 2006 and which are still likely to come forward. These other parcels of land will have a direct impact no the character and appearance of the area, and affect the relationship of the proposed DaSA allocations to the settlement. Had these have been identified in the DaSA Options and Preferred Options documents, it would become clear that additional parcels of land are suitable for development and should be included in the proposed allocations at North Bexhill.

7.4. These representations have demonstrated that our client's land (The Site) which partially forms an integral element of the strategic growth option for North Bexhill, offers an excellent opportunity for additional housing provision in this sustainable, accessible and highly popular location. The land has a direct relationship to the existing settlement and to the North East Bexhill strategic allocation. The Site is well enclosed by existing landscape features and topography, meaning that no harm would result to the wider countryside as a result of the development of The Site as a whole.

7.5. The preferred development options put forward by RDC do not appear to take the opportunity to fully utilise this available, achievable, suitable land to secure housing delivery in a short period of time. Additional developable areas have been clearly identified and should be included within the allocation. However, RDC has instead proposed that considerable parts of The Site are used as green or open space. Although it is appreciated that some green space is needed, the level proposed in this location is highly excessive, particularly as the Strategic Gap lying to the north east is proposed to be extended, and the presence of the woodland immediately north of The Site provides a clear, defensible boundary to contain housing growth.

7.6. Overall it is considered that RDC's preferred option for North Bexhill is overly cautious, prioritising landscape and ecology over the housing needs of its community. In order to meet housing needs and national objectives for the area, RDC must reconsider the options and ensure that the best, most efficient use of land is being sought, and that this is appropriately balanced / prioritised against other planning considerations. The need for this reassessment is further emphasised by the lack of a 5 year housing supply against the adopted Core Strategy target. Clearly The Site is capable of helping to address this current shortfall and ensure that future targets for the area are at the very lest, met, over the plan period.

7.7. In addition, it is clear that RDC needs to obtain further evidence to support the allocations, or lack of, in the DaSA. In particular, a heritage assessment is required to justify proposals around Preston Hall, in light of the existing strategic allocations that are evidently much closer to the heritage asset than our client's developable land at Preston Hall Farm.

7.8. Savills reserves the right to comment further on the DaSA and associated evidence base as the Emerging DaSA Local Plan progresses and throughout further consultations.

Appendix 1.0 Site Location Plan
Appendix 2.0 Site Photographs

Additional supporting information was supplied with the submission and can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28186
http://www.rother.gov.uk/CHttpHandler.ashx?id=28187
http://www.rother.gov.uk/CHttpHandler.ashx?id=28188
http://www.rother.gov.uk/CHttpHandler.ashx?id=28189
http://www.rother.gov.uk/CHttpHandler.ashx?id=28190
http://www.rother.gov.uk/CHttpHandler.ashx?id=28191
http://www.rother.gov.uk/CHttpHandler.ashx?id=28192
http://www.rother.gov.uk/CHttpHandler.ashx?id=28193
http://www.rother.gov.uk/CHttpHandler.ashx?id=28194