QUESTION 35: Do you agree with the requirements of Policy BEX9? If not, how would you wish to see it amended?

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

-Policy BEX9 Land off Spindlewood Drive, Bexhill

The site has high potential for prehistoric and Roman archaeological remains, so should be subject to archaeological assessment before being allocated.
-AMBER

Ecology

BEXHILL Page 128

Yes

I do not agree with the requirement BEX9. Priority should be given to development along the NBAR.

I propose a deferment for reconsideration of development of this site until at least 2022. A further full survey can then be undertaken as to EXACTLY how many residences will be needed, after other more suitable sites have been developed, and the roads and infrastructure capacity demands re-assessed.

Development here would create excessive OVERLOADING of Little Common Village, School, MEDICAL CENTRE, Parking, Public Services, and ABOVE ALL the roads into and out of Spindlewood Drive and Meads Road. Also the SEVERE POLLUTION and INACCESSABILITY for Ambulances, Paramedics, Fire Engines would become a CRITICAL PROBLEM. In addition, extra traffic would cause BLOCKING of the A259 for
MEDICAL services running between EASTBOURNE and the CONQUST HOSPTTAL and vice versa.

Meads Road and Spindlewood Drive are DEFINITELY NOT suitable for a increase of traffic both in and out of any new development.

As a local resident in Little Common Village of almost 35 years, I am opposed to the proposed development of Policy BEX9 in its entirety.

I am requesting that it be removed from the list of Preferred Sites and that it not be considered for any future development as part of any second DaSA consultation process.

* Rother District Council ("RDC") has stated that it is not willing to take projected 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.
* I think it to be unnecessary: in the light of the capacity of other proposed sites to provide adequate development potential (for employment as well as residential properties) as well as the almost certain excess of windfall developments we feel that RDC can achieve, even exceed, its development targets without this development.
* I consider it to be totally undesirable. It is wholly impractical, likely to have a significant detrimental impact on west Bexhill, further burdens limited local infrastructure, is out of character with Little Common Village and based on highly suspect traffic predictions.
* 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, such as the Spindlewood site is, according to the National Planning Policy Framework document (NPPF) paras17, 89 and 111..

Is the development at Spindlewood Drive really necessary?

I believe the development to be unnecessary for RDC requirements to meet its housing development targets. My comments to other questions in this consultation, particularly Q27 indicate that other developments already at advanced planning stages or under consideration in the DaSA are already likely to enable RDC to exceed its development targets with no development necessary for BEX9/BEX116, especially if windfalls were to be taken into account by RDC.

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

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

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

Why is this development unwanted?

Local traffic problems

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

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

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

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

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

Undoubtedly, there will be increased traffic flows along Meads Road into Cooden Sea Road resulting in congestion along Meads Road and increased congestion along Cooden Sea Road onto Little Common roundabout and the A259. The recently published survey on traffic flows provided by the proposed developer makes no mention of the increased traffic along these roads other than to concentrate on the impact of additional traffic on Little Common roundabout. This is dismissed as being negligible. I would strongly dispute this and believe the underlying assumptions about traffic queues entering the roundabout from Cooden Sea Road, Peartree Lane and Chestnut Walk are seriously underestimated and do not reflect the current reality. Queue sizes need to be electronically recorded over a period of two weeks to verify the facts.

As stated above, I am told that the would-be developer of BX116 has provided a "Technical Note" predicting an "immaterial" impact from increased BEX116 traffic on the Little Common roundabout (available on the DaSA web site, presumably with RDC's endorsement). This is simply beyond comprehension. It avoids addressing traffic flows along Spindlewood Drive and Meads Road which is incomprehensible. This obviously self-serving document seems to have been accepted at face value by RDC but must be re-assessed on a more realistic and analytical basis in terms of the impact on Meads Road, Maple Walk and Spindlewood Drive.

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

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

* Peak traffic flow (08:00 - 09:00 & 17:00 - 18:00) of between 90-100 vehicles each hour along Meads Road & Spindlewood Drive
* Total traffic movements of c 850 per day

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

There is a real risk, therefore, that some traffic for the BX116 housing estate will use Maple Walk as a rat-run alternative to Meads Road. As a resident of Maple Walk, I view this possibility at my age with concern. Maple Walk is an unadopted road, much of it very narrow, effectively single lane, like Meads Road. The increased traffic flow along Maple Walk and Maple Avenue would be unbearable for my family and neighbours, not to mention the added wear and tear on the roads which we must maintain at our own expense. People living in Maple Walk and Maple Avenue, bought their properties because of the calm and quiet nature of the neighbourhood, and paid a premium for this privilege. We have already noticed, since our arrival in Maple Walk, an increase in the volume of traffic and also the speed. Any development on BX116 would greatly affect our living conditions in a significantly adverse way. So there should be no entry or exit allowed from BX116 into Spindlewood Drive, if the development were to be allowed. Obviously, this is a personal opinion, but one that is shared by all our neighbours, and surely should be taken into consideration by RDC.

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

Density of proposed development

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

Environmental Concerns

Although the would-be developer has provided an Ecological Appraisal for BX116 many issues remain to be carefully considered and studied further. There are valid questions to be raised about the ease with which their suggested mitigations can be implemented and their likely effectiveness. This site lies adjacent to areas which are designated SSSI and/or Ramsar sites, deserving of especially rigorous protection. These observations and re-assurances do not seem to have been studied and approved by the relevant utilities, environmental protection and wildlife authorities. The study was commissioned by and paid for by the developer with a commercial interest in this site, hardly an uninterested party. Not least are the issues about drainage and flooding risks, SUDS designs and expectations. Nor is it clear who would be held responsible for any future flooding or environmental damage and how they might be sanctioned in the event of any failure of these measures. I believe that as part of the evaluation process, RDC must require a flood risk assessment. Already there is a considerable amount of water closely adjacent to this site, and this would be enlarged if such a large concrete footprint is allowed to be laid on this proposed development site

Wider local impact:

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

It is a widely held view across the whole Bexhill district that the A259 is wholly unsuitable for the traffic levels passing through Little Common Village and Bexhill overall. Much of it is through traffic which must use the A259 as the only major east-west route along England's south coast. If anything, the new Bexhill-Hastings Link Road has added to traffic pouring through Little Common Village as it provides an improved route for traffic aiming to bypass St. Leonards and Hastings. Some 30 years ago, a much more suitable link road, which would have terminated at the end of the marsh road, was scrapped by the newly elected Labour Government. The more recently much talked about Bexhill bypass comes to mind - linking the NBAR to the A259 west of Bexhill which would alleviate some of this traffic, not to mention bringing a huge area for further housing and business development into play.

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

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

Conservation

The field is adjacent to a Site of Special Scientific Interest (SSSI) and a RAMSAR (site 973), part of the Pevensey Plains and protected by International Law - any development on this site could have detrimental impact on those areas.

Air pollution

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

It is known that existing air pollution levels around Little Common Village are getting close to breaching safe levels. It could be expected that additional traffic flows and congestion forecast once Barnhorn Green construction starts will result in pollution levels rising to unacceptable levels and will thus be a danger to all local residents. New air pollution monitoring along Barnhorn Road is now essential to establish the current levels of NOx and particulates that are known o be serious health risks.

Development creep

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

The area of west Bexhill to the south of Barnhorn Road and to the west of Cooden Sea Road currently provides an oasis of peace, tranquillity, wildlife and an overall enviable environment. Most residents living in this area chose to do so because of this environment. Developing Spindlewood would fundamentally and detrimentally affect this environment. This is simply unnecessary and must not be allowed.

We need to protect the village character of Little Common, which would be lost forever, were approval to be granted on such a large scale as is currently under consideration. I feel that we have every right to expect our council/councillors to give total respect and consideration to its/their residents' views.

As a Committee, we have a responsibility to all those with a frontage (frontagers) onto Maple Walk (South). Similar committees represent the interests of the residents of other unadopted roads in the vicinity of the proposed development of BX116.

Under the terms of the original development of the De La Warr Estate, frontagers are required to pay an annual sum towards the upkeep of the road. They are also required to keep the frontages properly maintained and litter-free. The proposed development of BX116 seems to have been put forward without any regard to the special and historically significant nature of Maple Walk and the other private roads on the De La Warr Estate, nor of the impact upon the current and future residents. The additional traffic (and the damage to the road it will cause) represents a totally unacceptable burden upon the frontagers. They would face a considerable and enduring additional annual expense, plus a loss of amenity. There is no pavement on Maple Walk, and additional traffic (both during construction and thereafter) also represents a risk to pedestrian safety.

We are thus fundamentally opposed to the development of BX116. It is our view that no development of the site should go ahead.

Were some development to proceed notwithstanding our opposition, then given our responsibilities we should comment simply upon paragraph (ii) of policy BEX9.

Given the impact upon the unadopted roads (and upon Meads Road - which is narrow and not well maintained), in our considered judgement both the vehicle and pedestrian entrances should be onto Barnhorn Road, and there should be no entry into or out of Spindlewood Drive. Barnhorn Road is a trunk road and, although badly congested at peak times - a strong reason for opposing all the suggested ribbon development adjacent or close to the A259 - it is maintained at public expense to take a much higher traffic flow. (Closing the link between BX116 and Spindlewood Drive would be necessary to prevent its use as a rat-run to and from the A259 to avoid the Little Common roundabout.)