Policy BEX3c: Land east of Watermill Lane

Objecting to the proposal of the traveller site. This is a shocking idea and has hardly been well advertised to the local community and residents that this is going to be considered with much of the public being unaware, cleverly it seems the council have kept this information from the public. I have lived in the Sidley area for well over 15 years and have noticed how already busy the village is also becoming, crime isn't exactly at a stable and low level and having a gypsy site added to the equation will only make matters worse. This proposed site being watermill lane will effect family's schools and doctor surgeries and increase waste and effect the economy overall I will be starting a petition against this going ahead. I hope you really consider how this proposal of a gypsy site being set up will effect the local area.

The travellers site should not be on this site. The rubbish they produce will build up and be a constant drain on the councils resources to clean up. The whole area will look like a tip. Antisocial behaviour by them will cause problems in the local community.
Access to the whole site will be a problem.
Biodiversity will be destroyed and is not replaceable.

We are very concerned at the proposals for a new gypsy site and the potential anti-social and disruptive behaviour that we have experienced in the past (from the Downs and Glyne Gap) from unauthorised sites.

Including damage to property, thieving, negative impacts to the local environment and a general lack of care for their sites.

Mayo Lane and the wider Bexhill community is typically an area with an elderly population and many locals that I have spoken with have voiced their worry that they will not be able to leave their homes safely.

We have experienced the anti-social behaviour previously from unauthorised campsites and are unsure how Rother will be promoting a "peaceful and integrated co-existence" in line with the government guidance. Additionally we would be concerned about the extra strain on our local schools and health services.

We are confused as council tax payers as to why we should be paying for a new site that does not reflect what the community wants or needs, and also the potential impact to house prices in the area. I am sure that the community would prefer that the money invested for this site could be put to much better use in other areas.

I object to the provision of five pitches for the permanent residential use by gypsies and travellers in the location as listed under Bex3c. It is likely that Mayo lane will be used to access this site. Mayo Lane is narrow without a pavement. There are likely to be accidents if vehicles larger than cars are driven down Mayo Lane. Under the development plan more cycle and pedestrian use of Watermill Lane is envisaged and to encourage access by larger vehicles seems contradictory.

Proposed Travellers Site Land east of Watermill Lane, Bexhill [BEX3]
We wish to lodge our objection to the proposed Travellers site, as above, for the following reasons:
1. The site being so close to the proposed new housing sites and existing properties.
2. The site will no doubt cause conflict with new and existing residents, owing to the bad reputation of travellers and gypsies, which has been proven many times as reported in the local/national press.
3. The rubbish and destruction left behind when travellers move on, such as that reported in recent times on Bexhill Down and St Mary's playing fields, the cost of which would be a further burden on Rother District Council's finances.
4. The consultation plan states the site would be "discretely" screened from view. Surely this comment points to the site being an eyesore!
5. The proposed site is definitely an unsuitable location and we are anxious that this proposed does not get past the consultation stage.

The Map does not show the North Bexhill Access Road in any form and this is of great relevance because it is the only reason why all this land has been opened up for development.

The map does not show the North Bexhill Access Road in any form and this is of great relevance because it is the only reason why all this land has been opened up for development.

Already suffered two years of blight due to the north Bexhill access road construction and all its delays. Once completed (who can say) we will have to take the blight of the traffic noise and increased traffic flows, then to have the double blight of the travellers' site imposed upon us.
The next statements are not made up and I do not wish to stereotype any faction of society but all came about from the previous travellers' site being located in Watermill Lane.
Trespass:
Then, interacting with customers on the campsite, myself and my family in an antisocial threatening manner of behaviour.
Rural Crime:
Static caravan gas regulators stolen as well as the bottles; holly and Christmas trees cut down and stolen. Stacked wood stolen.
All access for the crime came via trespass off the footpath
Sussex Police's unwillingness to follow up any lines of enquiry which lead back to the travellers' site or even step foot on the site.
All these factors will result in me having to apply to close the public footpath because I will be failing in my duty of care to my customers and it will make it impossible for my business to function

Please would you lodge my objections to the proposed traveller site intended at the southern end of Watermill Lane.
I have read with interest this proposed development in the scope of the Preston Hall farm area as detailed in Development and Site Allocations ("DaSA") Local Plan.
As a local resident to the area my concerns are the impact on local housing in the Watermill lane area especially now the southern end has now been stopped up which only allows traffic in and out of the southern end onto the A269.
There is already a large stock of social and residential housing in the location that will be affected by the use of this section of Watermill Lane which will result in Travellers entering or leaving this the proposed site using larger vehicles and towing Caravans which would not be suitable on this residential road that already has width restrictions towards Preston Hall and Mayo Lane.
Travellers are inherently a fluid community not wishing to reside permanently on this site.
The comments to question responses raised as below are incoherent as you have said in so many words that it will have no impact and yet yourselves have admitted that screening may be appropriate.
"The proposed site for up to 5 pitches for Gypsies and Travellers is regarded as inappropriate, especially having regard to its exposure following construction of the new road. It is proposed to be relocated to a site at the end of the southern section of Watermill Lane. Proximity to existing housing is not a fundamental incompatibility, although
visual screening may be appropriate. "(page 173)
Reading through the plan I have tried to locate where exactly this proposal of the Travellers site is on maps provided on your site with no success. I have heard from local residents that it is to be somewhere between Watermill lane and Mayo Lane.
If this is to be sited on land with restrictions below then this is in contravention of the clause as stated in the question answer below.
"It is recognised that all the 3 Options that have been developed for Bexhill show a potential Gypsy and Traveller Site to the east of the proposed housing allocation. On this land there is a clause in the contract of sale preventing development on the site. The proposed allocation, therefore, goes against this legal restriction and therefore the land should be excluded from the allocation. "(page 175)
Looking at the whole large scale development and the increase of housing stock and business use the siting of a traveller site in area would be completely inappropriate without proper consideration of existing and future residents let alone adequately accommodating the needs of the travellers themselves.
I fully understand why so many local residents are aggrieved and strongly suggest instead of burying this information in a wordy document of over 420 pages proper consultation to the public should have been made.

I am writing to object to the proposed site of up to five pitches for the permanent residential use by Gypsies and travellers.

Having worked in local government for over 30 years, I have a lot of experience of the problems caused by these sites. I refer to the amount of mess that some travellers leave for the local authority to clear up at council tax payer's expense. The rise in crime such as burglaries, vandalism and public order offences in the area surrounding the sites. Also the drop in house prices caused by sellers declaring the proximity of the sites to potential buyers.

I am also concerned about the movement of traveller's lorries, caravans, trailers etc up and down Watermill Lane. As Watermill lane is also a dead end now, it is very likely to become a target for fly tippers. I strongly believe that a permanent traveller site can only exacerbate that problem.

Map incorrect: not showing Access Road and roundabout/ unclear reference to farm track.
Foot/cycle ways appear more important than vehicular access.
Transport assessment should have been carried out as part of the proposals to avoid 'expectations' listed.
Proposed Gypsy/traveller site will have negative impact on Sidley and surrounding area, for
- safety of dog/walkers, cyclists, horse riders using routes either side of the site,
-local business on Ninfield Rd., and Cobbs Hill Caravan site bringing tourists and money into the area
-new homes adjacent to the site
- the safety of people in their homes
-shops in Sidley, an area needing boosting.
In 2007, travellers moved onto a field opposite Preston Cottage and caused huge distress to local people. First hand experience: I and others were harassed, intimidated, left feeling vulnerable. Theft, disrespect for property, confrontation between residents and travellers was a daily occurrence, the site left in a disgusting state. (See police and RDC planning records.)
Re: The Equality Impact Assessment Oct 2018, Conclusion 4.1, 4.2 states the site will benefit these racial/ ethnic group. This site will not benefit the local community. See also p273 Other Policies: Gypsies and Travellers with reference to the site at Brindies Tarn.

Re. Watermill Lane Development
We wish to raise our strong objection to the forthcoming plans for the new developments around The North Bexhill Access Road and in particular Watermill Lane.
The loss of countryside and wild life would be detrimental for the well being in this area. Not only of the housing, people and the resultant increase in traffic but with the infrastructure of schools, doctors and other services struggling to cope now.
The prospect of having a travellers' site in amongst housing is ridiculous and who has to pay for the upkeep of the site and clearing up of subsequent disruption?
After living in Mayo Lane for the past forty-seven years we have seen many changes, the future plans look grim - there is NO footpath in the Lane and the increase in traffic looks horrendous for the elderly and young families on foot
We hope you take considerable thought in deliberating all of the plans!

Sir, we strongly object to the current proposal for a travellers site, at the rear of Preston Hall farm off the new Bexhill access road It is a totally inappropriate site with its close proximity to established residential properties and in particular to Sidley Village centre.
I trust that the council will refuse such an application at all times.

I object to the proposed gypsy and travellers site. It will be detrimental to the area sited among private residential properties and not in keeping with the area. It will devalue all the surrounding residential properties and those in the local area. The lanes into and including Watermill Lane are narrow and not suitable for large caravans, lorries, motor homes that go with this type of site. It will become a tip with rubbish left behind when vacated.

I object to the gypsy and traveller site being sited next to Preston Cottage on Watermill Lane. It is unnecessary to have it so close to the Sidley area. Travellers do not mix with other communities. There is increasing risk of theft and violence when there is already too much in Sidley. If it is such a poor area then surely we should be trying to improve things.
People who want to live in a safe environment will not out of choice choose the Sidley area to live in with a traveller site on their doorstep.

Proposed Traveller Site Watermill Lane
Sirs, please register my objection in the strongest terms to the above site proposal.

Traveller site Watermill Lane, Sidley
Please register my objection to this site being built, in the strongest possible terms.

Traveller site off Watermill Lane Planning number not known
Sirs, please register my objection to this proposed plan in the strongest possible terms.

Proposed Traveller site Watermill Lane, Sidley
Please register my strong objection to the proposed Traveller site in Sidley.

Thank you for your email and I have registered as an agent objecting to the proposal of 5pitches for travellers at the rear of Preston Hall farm with access from the new road. I have been approached by many residents in Watermill Lane and other areas and I have advised them to write to you before 7/12/2018 registering their objection. I also object as a local resident as there is no reason to locate a travellers site so close to Sidley and private residents.

We note the allocation of land within our ownership, for five gypsy and traveller pitches as part of the BEX3c allocation. We are disappointed that the local planning authority did not positively prepare this allocation by prior engagement with the objector prior to publishing this draft DaSA allocation. There are several issues with this allocation that make it unsound. These are set out below;
1. The land included within the allocation is encompassed within the planning application for NBAR as part of the landscape mitigation scheme as included in planning permission for the road (ref: RR/2015/2260/P) granted in February 2016.
2. The site itself is bounded on three sides by other land owners who may not be willing to provide a route of access via their land for the proposed use, leading us to conclude an access onto NBAR would be required.
There is a significant levels difference between the road and this site which would need to be graded with a suitable treatment to allow access for full size caravans. The construction of such an access would at this point in the road would utilise a significant portion of the site and be a costly endeavour, leading us to doubt the ability of this site to be delivered without subsidy from a wider development which we are not able to offer as our efforts are focused on commercial development and employment creation within the area, which in itself has a requirement for subsidy and has a considerably lower potential for profit than the housing allocations being brought forward in this plan.
3. We consider the approach of allocating the traveller sites to cover the entirety of a single land ownership parcel already dedicated for the delivery of an existing planning permission detrimental to the viability of delivery for this development. In proposing this the local planning authority limits the potential for securing the viable
delivery of these pitches within the plan period. As a result of the above highlighted issues, we are of the view that the proposed allocation was not positively prepared and is unlikely to be effective. While we recognise that this land has potential to contribute towards meeting housing needs and will support the council in bringing forward viable development to contribute towards this on this site, we consider it unlikely that that could be achieved without achieving prices in excess of those
previously achieved in the UK market for these pitches.
We recognise the identified need for these pitches and the planning authorities legal duty to allocate them but would consider it a more appropriate approach to incorporate these pitches as part of more profitable use allocations to allow them to be effectively secured as part of planning conditions for these schemes and ensuring that the needs of the gypsy and traveller communities can be met throughout the plan period.

It has been with great difficulty I have tried to understand RDC (DaSA)local plans or even find the documents

I did respond to the first documents in 2017 but my letter was sent back to me, If I remember rightly something to do with my genuine comments on travellers. But I am a honest person and anything I Say is the truth

I notice that the proposed traveler site has been greatly moved from the 2017 plans
I am obviously alarmed as it is even closer to my home and business.

I will not bother writing regarding all previous problems we have had with travellers as last time I was not allowed to comment.

Is this what I am expected to endure again?

The plans are very poorly marked the only one I could find did not even feature the new road at present being built

No roads marked for access to traveler site or new houses.

We have experienced first hand over the last two years the incompetence and lack of concern to our business in the building of the new by pass in Bexhill.

We do not expect any better from this consultation.

What we have learnt is in these matters is that absolutely no notice is taken by any of these so called consultations.

And this is probably a complete waste of my time

East Sussex County Council Representations on the Proposed Submission Rother Development and Site Allocations (DaSA) Local Plan

The County Council wish to make the following representations which seek modifications to make certain aspects of the Proposed Submission DaSA Local Plan sound. We also have some other comments and observations which relate to certain points that we raised at the draft consultation stage.

Minerals and Waste Planning

The comments below are made by East Sussex County Council in our role as the relevant Minerals and Waste Planning Authority for the plan area.

Soundness - Policy DEN3: Strategic Gaps

As identified in our previous comments on the Options and Preferred Options DaSA, Pebsham Household Waste Recycling Centre and Waste Transfer Station, which is a strategic safeguarded waste site, and the Pebsham Waste Water Treatment Works are located within the Bexhill and Hastings/St Leonards Strategic Gap (Policy DEN3), but are not within the Combe Valley Countryside park (Policy HAS1).

The East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (WMP), adopted 2013, sets out the strategy for waste management within East Sussex, Brighton & Hove and the South Downs National Park. Policy WMP22 of the WMP supports proposals for increasing capacity within the boundaries of an existing waste management site and making the most efficient use of existing waste sites. This was a consideration in the identification of sites under the Waste and Minerals Sites Plan (2017).

The Council recognises the importance of retaining strategic gaps as set out in Policy DEN3. However, it is concerned that the stipulation that development may only occur within the strategic gap under exceptional circumstances undermines the ability of the WMP to make most efficient use of waste sites as supported by adopted Policy WMP22 of the WMP. This creates ambiguity between the two policies, and the Council therefore believes that Policy DEN3 is currently unsound on the grounds that it is not effective. 2

To resolve this soundness issue the County Council requests that the following text is inserted into the supporting text after paragraph 6.18:

"This Plan recognises that there are strategic waste facilities within the Gap. Proposals for the intensification of these facilities within their existing boundaries, as enabled by the Waste and Minerals Plan, are supported in principle and do not have to demonstrate exceptional circumstances, provided that the openness of the Gap is maintained."

Requested Minor Modifications

Reference is made to the Waste and Minerals Plan and the Waste and Minerals Sites Plan in section 1 which is appreciated. However, there is no mention of the safeguarding of minerals sites, wharves and railheads within the Rother Local Plan area, as identified in policies SP8 and SP9 of the Sites Plan and policies WMP14 and WMP15 of the Waste and Minerals Plan as previously suggested in the County Council's response to the Options and Preferred Options DaSA. It is requested that reference to these policies or to the safeguarding of mineral sites is made.

Presently, safeguarded waste and minerals sites do not appear to be referenced on the Rother Local Policies Map. It is requested that either the safeguarded minerals sites within the Rother Local Plan area are included in this Policies Map, or that reference to the Waste and Minerals Policies Map is made on the Rother Policies Map as required by article 9 of the Town and County Planning (Local Planning) (England) Regulations 2012 (as amended).

Paragraph 10.3 of the supporting text for policy HAS1 which concerns the Combe Valley Countryside Park refers to the continued use of land within the locality for waste collection, and states that such operations must be contained and should not conflict with the aims and objectives of the Combe Valley Countryside Park. This should refer to 'waste management' rather than waste collection.

Policy DEN3 states that development in a Strategic Gap will only be permitted in exceptional circumstances. Further clarity could be provided on what constitutes 'exceptional circumstances'.

Other Comments

The reference to the National Planning Policy for Waste in paragraph 1.22 is welcomed.

In section 2, the inclusion of policy DHG7 External Residential Areas item (iii) Waste and Recycling is welcomed.

With regards to policy RHA2: Harbour Road Employment Area, Rye Harbour, the comments made by the County Council in response to the Options and Preferred Options DaSA have been taken into account. Paragraph 11.204 and policy RHA2 (vi) include text which requires proposals that could affect the wharf to demonstrate that capacity for landing, processing, handling and storage of minerals is safeguarded. This is strongly supported. Recognition of the waste management operation at Rye Oil is also appreciated.

Alterations to the Sustainability Appraisal are noted, and references to Commercial & Industrial Waste and Construction, Demolition and Excavation Waste are appreciated.

Alterations to the Sustainability Appraisal are noted, and references to Commercial & Industrial Waste and Construction, Demolition and Excavation Waste are appreciated.

Highway Authority

ESCC Cycling and Walking Strategy

Although the Cycling and Walking Strategy is briefly mentioned in the introduction section on page 13 we would request that a minor modification is made by adding the following text in the opening pages of the Bexhill site allocations chapter (pages 113-115) and the opening pages of the Hastings Fringes chapter (pages 175-178):

ESCC are in the process of developing a County wide Cycling & Walking Strategy, which will aim to deliver cycling and walking infrastructure on key corridors of movement between residential areas (including new developments) and key trip attractors, including education, employment, retail and leisure activities'.

Proposed site allocations

The County Council, in our role as the relevant Highway Authority for the plan area, have worked closely with Rother District Council in the production of the DaSA Local Plan and provided input at the Options and Preferred Options stage. For this reason, we do not wish to oppose the principle of the proposed allocations. However, we do seek some minor modifications to certain policies, and also wish to raise a soundness concern over one particular policy (BEX10). Despite this, we have set out below how we consider this soundness issue can be addressed by way of a modification to the policy in question.

It is recognised that a number of the proposed allocations have been, or are subject to planning applications that the Highway Authority has provided comment on (i.e. BEX1, BEX2, BEX7 and BEX9). In light of our involvement and our stated positions on the applications for these sites, alongside the evidence supporting the plan, we do not wish to object and raise concerns over the soundness of those particular proposed allocations.

BEX3: (Land at North Bexhill -Infrastructure) and sub-policies BEX3a, BEX3b, BEX3c

Policy BEX3c imposes a traffic calming requirement (criteria iii b) but Policy BEX3b doesn't. This does not suggest consistency across the three sites/sub-policies of BEX3 - as all traffic and most non-vehicular movement from the 3 sites reaches the proximity of Mayo Lane.

We therefore request that minor modifications are made to Policy BEX3 and BEX3c:
-that the policy criteria of Policy BEX3c (iii) (b) regarding traffic management is deleted from BEX3c and is instead written into the shared infrastructure policy (Policy BEX3).

BEX4: Land at Former High School Site and Drill Hall, Down Road, Bexhill
We agree with policy text in point (v) regarding the transport assessment.

We recommend that there should be a masterplan/design brief as the uses are specific and sustainable transport/connectivity should be a key feature.

The main impact of this development from a highways perspective will be on the trunk road.
BEX10: Land at Northeye (Former UAE Technical Training Project)

From a transport perspective, we do not consider that the proposed allocation is in a sustainable location and a development on this site could be reliant on access to and from to be primarily made by private car. This is primarily the case due to the sites detachment from the main settlement of Bexhill (as recognised in paragraph 9.107 of the plan) and that few amenities, community facilities and employment opportunities exist within a reasonable walking distance of the site. However, the County Council recognises the overarching development strategy set out in the Local Plan 'Core Strategy' 2014 and the fact that the site is partly brownfield. Given this we do not wish to object to the principal of the proposed allocation. Instead, we wish to ensure that any development in pursuant of this allocation is able to take full advantage of, as well as make improvements to sustainable transport measures in the locality, as well as seeking to implement measures that minimise the risk of travel by private car.

We therefore request that there is a modification to the policy that requires a Travel Plan to be submitted and approved by us for any planning application on the site. The Travel Plan will need to demonstrate how opportunities for walking and cycling can be fully utilised (there are existing cycle lanes either side of the A259), as well as other sustainable transport measures (e.g. possible car club, measures that encourage journeys to be made by bike and bus, etc).

We also request that an amendment is made to criteria vii) of the policy. It is not just the bus stops we would wish to see improved, we would also want to see improvements which aid the accessibility of the bus stops - i.e. widening of footways and an improved crossing point on the A259.

It is considered that such modifications are required to the policy in order for it to be effective and consistent with national policy (in reference to the tests of soundness).
FAC1: Land at Former Market Garden, Fairlight Cove

The supporting text for the policy notes that the access to the site will be on roads that are unadopted and privately maintained. It is highly unlikely that this road could be brought up to an adoptable standard. Although the County Council does not wish to oppose the proposed allocation, we would ask that reference is made within either the supporting text, or the policy itself, that consideration will need to be given to creating safe pedestrian routes to and from the site, which is particularly important given the lack of footway on the unadopted highway.

WES4: Land between Moor Lane and the A28, Westfield

The indicative parking area for the proposed allotments is located opposite a 4 way junction. Therefore it will be important to fully consider highway safety at planning application stage. It would be hazardous for vehicles to reverse out of the site into the main road and therefore the parking area should be designed in a way that removes the need to reverse out. It is suggested that reference is made to this requirement in paragraph 11.237 of the supporting text to the policy.

Ecology

Energy from biomass (Paragraph 2.17)
It should be noted that because Ancient woodland requires ongoing management it does have some potential as a source for biomass energy.

Policy DHG2: Rural Exception Sites

We request the following minor modification: That biodiversity is added to Point (vi) of the policy i.e. to state that 'the development does not significantly harm biodiversity'.
Locally designated sites (Paragraph 6.3.4)

We request the following minor modification:

Delete the reference to 'East Sussex County Council' in this paragraph. This is because the Sussex Biodiversity Record Centre is the main contact for information on locally designated sites (the Sussex Local Wildlife Site Initiative and the Sussex Geodiversity Partnership are both hosted by the Record Centre).

Biodiversity and Green Space (Page 60)

We request that a minor modification is made:

Mention should be made of Habitats and Species of Principal Importance, as listed under Section 41 of the Natural Environment and Rural Communities Act 2006. The S41 lists are used to guide decision-makers, including local authorities, in implementing their duty under Section 40 of the Act to have regard to the conservation of biodiversity in England, when carrying out their normal functions. S41 habitats within Rother include woodland, maritime cliff and slopes, hedgerows and lowland meadows, and s41 species include hedgehog, common toad, house sparrow, brown-banded carder bee and pennyroyal.

Biodiversity opportunities in development: Paragraph 6.43

We request that the following minor modifications are made (additional words in italics and underlined) to paragraph 6.43 on page 84:

Ecological surveys and reports will be required to be submitted with planning applications for major development or where the development may impact on any designated sites, priority habitat of protected or notable species.

Housing allocation policy detail maps:

Policy detail maps show indicative layouts, but these may need to be adapted depending on the ecological constraints and opportunities. Site masterplans for allocated sites should be informed by an Ecological Constraints and Opportunities Plan (in line with BS42020:2013).


Lead Local Flood Authority

The Lead Local Flood Authority (LLFA) recognises that the Local Plan 'Core Strategy' was supported by a Strategic Flood Risk Assessment (SFRA) and that the DaSA sets out non-strategic policies within the overarching development strategy for the district. Recognising the content of paragraph 156 of the NPPF, it is not a requirement for the DaSA to be supported by an up-to-date version of the SFRA. Nevertheless, the LLFA would wish to place on record that when Rother District Council review their Core Strategy, it will be required to be supported by an up-to-date version of the SFRA. This is particularly paramount given that since the 2008 version has been produced, a significant amount of evidence has been collated by the LLFA on local flood risk matters in the district.

The LLFA notes that the DaSA has been informed by site assessments and a number of background evidence studies. This has included surface water flooding information and flood zone mapping provided by the Environment Agency.

In light of the above, the LLFA does not wish to challenge the soundness of the DaSA and oppose the principle of the proposed allocations. However, we would request that the plan acknowledges that in avoiding areas of flood risk and ensuring that appropriate drainage proposals are delivered on the allocated sites (in the form of SuDS) that the quantums of growth set within each proposed policy allocation may need to be compromised in some instances. This is considered essential given that the LLFA has yet to see detailed masterplanning that identifies the potential land-take for whatever the appropriate drainage method will eventually be implemented. We would therefore suggest that the terms "approximately" or "circa" are used prior to the stated amount of residential development allocated to the site in question.

The County Council is aware that Rother District Council intends to formally submit the DaSA Local Plan to the Secretary of State in January 2019. The County Council supports this course of action as we consider that the matters raised in this representation can be suitably addressed and resolved during the Examination in Public into the DaSA Local Plan.

Should you require any further information on these points please do not hesitate to contact myself.

Site BEX3c is allocated for development in the proposed submission version of the DaSA. As detailed in section 3, the Site constitutes an area of 8.8ha to the north of the settlement of Bexhill, south of the recently constructed NBAR, and has been identified as a draft allocation in the Regulation 19 Proposed Submission Consultation of the DaSA. The allocation of the Site under Policy BEX3c: Land east of Watermill Lane sets out that the site is allocated for housing ("some 150 dwellings") and open space.

The allocation of this site is supported. The site is located in a sustainable and accessible location, with a direct relationship with the existing residential development of Bexhill and the wider north east Bexhill strategic growth area. The existing topography presents a site that is enclosed by natural landscape features and one that would not negatively impact upon the wider countryside.

There are, however, two technical amendments that we wish to see:

1) Removal of gypsy/traveller section on draft allocation site BEX3c

The allocation of Site BEX3c includes the provision of up to five gypsy and traveller site pitches for permanent residential use by gypsies. This aspect of the allocation is sought to be removed for three primary reasons:
i. the proposed gypsy and traveller pitches are not distributed evenly across all proposed allocations;
ii. there is insufficient evidence indicating that any Gypsy and Traveller pitches are necessary;
iii. The site of the allocation is the same as the location of an area of mitigation/compensation approved as part of the NBAR planning application.

The inclusion of all Gypsy and traveller sites on one prospective allocation site is an unbalanced approach that will not allow for integration, creating a clustering effect that would be detrimental to both the travelling community and local residents. If they are proven to be needed, the provision of a number of smaller sites across various site allocations set out in the DaSA would allow for a better approach to integration with the local community and allow an even distribution of traveller pitches, ensuring that not only were all sites close to amenities, but no amenity provider was overburdened.

The allocation of Gypsy and Traveller pitches on site BEX3c would be fundamentally unsound as the proposed allocation of part of the site for such pitches has not been based upon any recent evidence that details specific Gypsy and Traveller need. The evidence that has been submitted in association with the DaSA dates from 2011 and refers to Planning Policy Statements and Planning Circulars - both of which pre-date the current National Planning Policy Framework and are therefore out-of-date. As a clearly outdated piece of evidence, it cannot be relied upon to be indicative of any current or future need.

The construction of the NBAR was approved under application RR/2015/2260/P. As part of the application an Ecological Design Strategy showing a landscape and ecological mitigation plan was required as part of the pre-commencement conditions. This was submitted and approved. As part of this, Drawing (08)011 Rev.B Landscape Masterplan - E3 Specification for mitigation/compensation (Figure B.2.1) clearly shows the location of Native Broadleaved Wet Woodland Planting on the area that has been identified for the Gypsy and Traveller pitches. Therefore allocation of this site for development of Gypsy and Traveller pitches would be in direct conflict with the approved Ecological Design Strategy & Biodiversity Monitoring Strategy (March 2017) submitted and approved under application 2015/2260/P for the NBAR.

2) Allocation of land to the north of the North Bexhill Access Road (NBAR)

In the representation made to the regulation 18 DaSA, land to the north of the NBAR was highlighted as being suitable for inclusion as a site allocation, however it has been overlooked in the Proposed Submission version of the DaSA. Given the additional need for housing allocations in the DaSA, as identified and set out in the first part of this section, and the sites availability within the first five years of the plan period, it would be erroneous to not include land to the north of the NBAR as a further site allocation in the DaSA.

As set out in section 3, the site consists of approximately 4.6ha, is bounded to the north and east by ancient woodland, to the south by the NBAR, and is in flood zone 1. The proposed masterplan for the site includes development of housing and the development of community sports facilities. This would entail the development of approximately 25 units on the eastern portion of the site, with a cricket pitch and associated pavilion on the western part of the site.

The need for a ground for the cricket club has been identified in the DaSA, in particular in paragraph 9.13, where the specific needs of Sidley Cricket Club are identified. The supporting Sidley Sports Ground Feasibility Study, that has been prepared as part of the evidence base for the DaSA, identifies that the Sidley sports ground has been closed and a number of sports teams have been forced to relocate outside of the District on order to continue operating. Redevelopment options for the sports ground have concluded that an artificial turf football facility would be the most beneficial development on the site. However, this results in the playing surface being unsuitable for cricket, and there remaining a need for a cricket ground. The allocation of the land to the north of the NBAR would enable this community facility to be accommodated and the retention of Sidley Cricket club in the local area. If the site were to be allocated and the residential development of 25 units on the northern part of the site to go ahead, it would enable the cricket ground to be gifted to the community and enhance the recreation facilities available to the local population.

The erection of the cricket ground on the west of the site and the modest element of housing on the east would enable the open nature of the west part of the site to be maintained, whilst making best use of the available land resource to the east which is more naturally screened from wider views and therefore readily able to contribute towards the much needed housing supply.

Whilst the newly constructed North Bexhill Access Road has been identified in the DaSA paragraph 9.17 as "a clear edge between the urban area and the countryside to the north", it is a man-made boundary. The stronger, more defensible natural boundary that exists to the north of the road - the area of ancient woodland - which would provide a more robust and natural feature and would provide a natural limit for the settlement boundary. In the Core Strategy (2006), it is set out in paragraph 10.19 that "development to the north and north east of Bexhill should plan for the creation of a robust, long-term urban edge, with development contained from the wider countryside setting by well-defined topographical and landscape features."

Accordingly it would be in keeping with existing approaches and a far more logical step to include the site as part of the allocations of the DaSA through extending the settlement boundary to the edge of the woodland area, utilising a natural landscape feature of ancient woodland to set a firm, defensible boundary.

Additionally, the road need not be seen solely as a boundary and a limiting factor in development to the north, as it could readily operate as a spine road providing access to both its northern and southern sides without impacting upon the traffic flows through the area. A Highways Access report has been prepared by GTA Civils (August 2018) that has examined the capacity of the road and its ability to effectively service development to the north of the road. The road has been designed and built to be 'future proof', and is capable of a far higher vehicular capacity than is currently being proposed/operated. This has been reinforced in the Highways Access report, which has found that trip generations from the proposed development would have no material impact on the operation of the highway network.

The Highways Capacity Assessment Report that has been produced as part of the evidence base of the DaSA has identified that scope to increase road capacity within Bexhill is limited, and therefore further development within the existing urban area, through densification or other means, will lead to additional pressure on the road networks. Development on a well screened area that is in a sustainable location with good access to public transport networks would therefore make best use of existing land and help to accommodate an identified and much needed community facility.

It has already been highlighted as being available and developable within the first five years of the Plan period, and would utilise the newly constructed the NBAR as its means of access.

A precedent for development to the north of the NBAR has already been set, as Outline Application RR/2017/2181/P for uses B1 and B2 includes development to the north of the NBAR close to the junction of Combe Valley Way in a well screened location. The allocation of land to the north of the NBAR as detailed in these representations would also be in a well screened location with a strong natural boundary.

The Bexhill development boundary does not go far enough. It does not include the land to the north of the NBAR which was submitted to the Local Plan and representations made in support of at the regulation 18 round of consultation.

Accordingly the proposed Bexhill settlement boundary should be revised to include the land to the north of the NBAR. This amendment would enable the provision of an additional 25 dwellings that will further ensure that the plan is robust against any increase in housebuilding and enable the provision of a new cricket pitch for Sidley Cricket Club.

Please see attached full representation for further information.

Highway Access report:
http://www.rother.gov.uk/CHttpHandler.ashx?id=31171

Preston Farm Hall Representations report
http://www.rother.gov.uk/CHttpHandler.ashx?id=31172

I am objecting to the proposal of the traveller site due to the infrastructure such as schools, roads, GPs, shops, parking not being able to support an increased level of residents in the area.

Sidley is a small area that struggles to support the current population without increasing it.