Policy BEX10: Land at Northeye (Former UAE Technical Training Project), Bexhill

Although mainly a brownfield site, Northeye should only be considered for redevelopment if it can be shown without doubt that there will never be any damage to the integrity of the nearby Pevensey Levels and that consequent traffic from the housing development onto Barnhorn Road will be very small.
As RDC stated in its statement for the RR/2016/3206/P appeal, the traffic on Barnhorn Road is relentless. Long queues of vehicles back from Little Common past Coneyburrow Lane are frequent. Coneyburrow Lane is a very narrow, often single-track lane off Barnhorn Road, the beginning section of which is the access/exit road for Northeye. There have been several accidents on Barnhorn Road by Coneyburrow Lane because it is very difficult to drive onto the south side of Barnhorn Road from Coneyburrow Lane, Coneyburrow Lane is often used by drivers wanting to avoid the long queue into Little Common, frequently causing blockages because the lane is too narrow for vehicles to pass one another.
This means that any redevelopment of the site should only be allowed if another road from Northeye to Ninfield or north Bexhill is built.
Barnhorn Road is already operating near capacity as shown by the lengthy delays to vehicles attempting to travel along it. Little Common roundabout is a bottle neck so the stop-start traffic along Barnhorn Road is producing considerable air pollution, particularly in peak hours.
The above means that the inclusion of BEX10 in the DaSA local plan needs very careful consideration and must have strongly worded conditions attached. Otherwise, it should be removed from the local plan.

Thank you for consulting Sport England on the above named document. Please find herein our formal comments for your consideration.

Sport England has an established role within the planning system which includes providing advice and guidance on all relevant areas of national, regional and local policy as well as supporting local authorities in developing the evidence base for sport.

Sport England aims to ensure positive planning for sport, enabling the right facilities to be provided in the right places, based on robust and up-to-date assessments of need for all levels of sport and all sectors of the community. To achieve this our planning objectives are to seek to PROTECT sports facilities from loss as a result of redevelopment; to ENHANCE existing facilities through improving their quality, accessibility and management; and to PROVIDE new facilities that are fit for purpose to meet demands for participation now and in the future.

We work with the planning system to achieve these aims and objectives, seeking to ensure that they are reflected in local planning policies, and applied in development management. Please see our website for more advice: http://www.sportengland.org/facilities-planning/planning-for-sport/

Site allocations and playing field provision

Development that would either involve the loss of playing field or prejudice the use of the playing field (for example, housing immediately adjacent to an existing playing field) would be strongly resisted by Sport England.

I also see that as part of site allocation BEX10 there is the potential for a cricket and or football pitch. I would advise that this element of the site allocation should be justified by a robust and up to date Playing Pitch Strategy (see below). It is often the case that single-pitch sites are found to be unsustainable and therefore there can be issues finding clubs/tenants to take them on.

I also note that BEX11 (Sidley Sports Ground) has been allocated for sport. Sport England is fully supportive of this allocation which is backed up by evidence in the most recent Playing Pitch Strategy.


Playing Pitch Strategy

The Local Plan should be informed by a robust and up to date assessment such as the Playing Pitch Strategy which I understand was completed for Rother in 2016. Sport England's most recent Guidance is clear that PPSs should be updated at least annually (Stage E). I would strongly encourage you to ensure a Stage E review is undertaken as soon as possible in order to ensure the evidence base for the local plan is up to date and robust. I note that this document forms part of the Local Plan evidence base. This document should also be used to inform questions around sporting infrastructure that is required (either in terms of updating or new provision).

Protecting playing fields and sport facilities
Currently the NPPF states:

Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

* an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements
* the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location
* the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

I note that there would not appear to be a policy dedicated to the protection of playing fields and sport facilities in line with the NPPF. Sport England would strongly recommend that such a policy be included in line with national policy.

Economic Development

it is noted that the local plan includes a section on the economy.

Sport England wishes to highlight the fact that sport makes a very substantial contribution to the economy and to the welfare of individuals and society. It is an important part of the national economy (measured using Gross Value Added) and employment. For those who participate there are health and well-being (or happiness) impacts. Its economic impact places it within the top 15 sectors in England and its wider economic benefits mean that it is a key part of society, which results in huge benefits to individuals and communities. Sport England would therefore request that the value of sport to the economy is reflected within the Local Plan.

I note within the document that there are references to ensuring the health and wellbeing of residents, improving pedestrian and cycle connectivity, prioritising cyclists and pedestrians (including creating links where previously there were none) and ensuring high quality public realm; these are welcomed.

Sport England believes these references would be further strengthened by specifically referencing Sport England's Active Design Guidance, with the recommendation that future design proposals follow its principles.

Sport England and Public Health England have recently refreshed our 'Active Design' guide which provides some really useful advice and case studies with clear reference to the NPPF to maximise the opportunities for design in physical activity. Sport England would commend this to you and suggest the concept of 'Active Design' be incorporated into policy and any new developments - please see website extract and link below:

Active design

We believe that being active should be an intrinsic part of everyone's daily life - and the design of where we live and work plays a vital role in keeping us active.
Good design should contribute positively to making places better for people and create environments that make the active choice the easy choice for people and communities.

That's why Sport England, in partnership with Public Health England, has produced the Active Design Guidance. This guidance builds on the original Active Design (2007) objectives of improving accessibility, enhancing amenity and increasing awareness, and sets out the Ten Principles of Active Design.

I note within the document that there are references to ensuring the health and wellbeing of residents, improving pedestrian and cycle connectivity, prioritising cyclists and pedestrians (including creating links where previously there were none) and ensuring high quality public realm; these are welcomed.

Sport England believes these references would be further strengthened by specifically referencing Sport England's Active Design Guidance, with the recommendation that future design proposals follow its principles.

Sport England and Public Health England have recently refreshed our 'Active Design' guide which provides some really useful advice and case studies with clear reference to the NPPF to maximise the opportunities for design in physical activity. Sport England would commend this to you and suggest the concept of 'Active Design' be incorporated into policy and any new developments - please see website extract and link below:

Active design

We believe that being active should be an intrinsic part of everyone's daily life - and the design of where we live and work plays a vital role in keeping us active.
Good design should contribute positively to making places better for people and create environments that make the active choice the easy choice for people and communities.

That's why Sport England, in partnership with Public Health England, has produced the Active Design Guidance. This guidance builds on the original Active Design (2007) objectives of improving accessibility, enhancing amenity and increasing awareness, and sets out the Ten Principles of Active Design.

Ten principles

The ten principles have been developed to inspire and inform the layout of cities, towns, villages, neighbourhoods, buildings, streets and open spaces, to promote sport and active lifestyles.

The guide features an innovative set of guidelines to get more people moving through suitable design and layout. It includes a series of case studies setting out practical real-life examples of the principles in action to encourage planners, urban designers, developers and health professionals to create the right environment to help people get more active, more often.

The Active Design Principles are aimed at contributing towards the Government's desire for the planning system to promote healthy communities through good urban design.

Active Design has been produced in partnership with David Lock Associates, specialists in town planning and urban design.

Thank you once again for consulting Sport England. Please do not hesitate to contact me should you have any queries.

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.

Rother District Council - Proposed Submission
Development and Site Allocations (DaSA) Local Plan consultation

Highways England ref: #6113

Thank you for your email of 26 October 2018 inviting Highways England to comment on Rother District Council's Proposed Submission Development and Site Allocations (DaSA) Local Plan and its accompanying Sustainability Appraisal.

Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity. We will therefore be concerned with proposals that have the potential to impact the safe and efficient operation of the SRN.

Department for Transport Circular 02/2013 "The Strategic Road Network and the Delivery of Sustainable Development" and the September 2015 document 'The strategic road network Planning for the future - A guide to working with Highways England' explains how we engage on planning matters and the Local Plan process in order to deliver sustainable development whilst safeguarding the primary function and purpose of the SRN.

The SRN in Rother consists of the A21 and the A259 between Bexhill and Rye. As you are aware the SRN currently experiences congestion particularly in the peak hours. We therefore look to the Rother Local Plan to promote policies to help manage the impact of development traffic on the SRN.

The Rother District Local Plan Core Strategy 2011-2018 was adopted in September 2014. The DaSA has been produced to address the need, identified in the Core Strategy, for more detailed development policies and specific site allocations. The DaSA forms part 2 of the Local Plan and together with the Core Strategy will form the basis for determining planning applications.

In February 2017 Highways England commented on the DaSA Local Plan Options and Preferred Options consultation. Key among our comments was
* We recommended the transport evidence base be updated as the study which had informed the Core Strategy was from 2011.
* The transport evidence base should include proposals for employment sites
* The transport evidence should examine the maximum that individual / cumulative sites can be developed to without unacceptable impacts on the combined road networks (strategic and local) or the points at which there is a requirement for mitigation
* Funding for improvements on the SRN should not rely on CIL contributions but require section 278 agreements
* We suggested mini Infrastructure Development Plans be considered for each allocation

As part of the current consultation, we have reviewed the following documents and set out our comments below.

* Development and Site Allocations Local Plan - Proposed Submission, October 2018
* Highways Capacity Assessment (HCA) Report (2028 Development and Site Allocations) Version 4.2, November 2018
* Infrastructure Delivery Plan, February 2015

The headings and numbering below refer to those used in the consultation and supporting documents.

Development and Site Allocations Local Plan

For Highways England to consider the Local Plan to be sound, the development proposed must be supported by a transport evidence base which assesses the cumulative traffic impact of all the development in the Plan upon the SRN. If required, the Local Plan must propose mitigation which delivers 'nil detriment' and which we can be confident is deliverable within highway land or land under the control of either yourselves as Local Planning Authority or the applicant and is compliant with all of the requirements of the Design Manual for Roads and Bridges (DMRB). Further, we must be confident that funding for any required highway mitigation is or will be in place and available at the appropriate point in the buildout period of the Local Plan. Mitigation schemes therefore need to be developed to a sufficient stage at outline design to enable robust cost estimates to be derived, which should be confirmed with Highways England.

5. Economy

Shopfronts, Signage and Advertising
Paragraph 5.2

In terms of the A259 and A21, Highways England does not allow advertisements within the highway boundary in accordance with Circular 02/2013 paragraph A2.

6. Environment

Sustainable Drainage
Paragraph 6.48

Highways England does not allow water run off due to any change of use into the highway drainage systems, nor new connections into these systems from third party development and drainage systems. On land where there is an existing drainage connection into the SRN drainage system then only the extant land use and existing outfall from that land will be accepted. Any continuation of the connection following change of use will not be permitted (Circular 02/2013 paragraph 50 applies.).

8. Overview

We note that the Core Strategy housing requirement target is at least 5,700 net additional homes up to 2028. Paragraph 8.6 states that the DaSA Local Plan and Neighbourhood Plans need to identify further sites for at least 1,574 dwellings in addition to those identified in the Core Strategy. In paragraph 8.17 there is an intention to have a margin of over provision, particularly in Bexhill, because the annualised housing requirement has not been achieved to date.

As noted above, the transport evidence should examine the maximum that sites can be developed to without unacceptable impacts on the strategic and local road networks or the points at which there is a requirement for mitigation to bring about a 'nil detriment'.

9. Bexhill
Policy BEX3: Land at North Bexhill - Infrastructure

We note that the development of the sites in policies BEX3a, BEX3b and BEX3c shall be required to contribute to shared infrastructure.

The cumulative impact of sites upon the SRN will need to be assessed and mitigated as necessary to result in a 'nil detriment' situation where the network is shown to be overcapacity. Any physical works will need to be agreed by Highways England, comply with design standards, be deliverable and fully funded by the development or an alternative realistic funding source identified. It is suggested that the policy context is re-worded to ensure that it is clear that 'nil detriment' (no worse than otherwise) is provided where the cumulative impact is 'severe' i.e the network is taken or is already over capacity.

This policy refers to direct provision and legal agreements in order to implement the shared infrastructure requirements. It should be noted that works to the SRN will be via a Section 278 of the Highways Act 1980 agreement and not a Section 106 of The 1990 Town & Country Planning Act agreement.

Policies BEX6, BEX9, BEX10 and BEX11 include requirements to provide off site highway works to make the development acceptable in highway terms. BEX14 requires works to improve junction of Beeching Road and London Road. It should be noted that combined, these sites may have a cumulative impact on the SRN and may therefore be reasonably required to contribute towards improvements on the wider road network. In the case of BEX9 Spindlewood Drive, this site will also be required to upgrade the existing access onto the A259 Barnhorn Road as well as provide an access to Spindlewood Drive on the local road Network. This was shown to be necessary to avoid 'severe' impact at the A259 Little Common Roundabout.


Highways Capacity Assessment (HCA) Report (2028 Development and Site Allocations)

We note that the transport study covering the Local Plan transport assessment work has been undertaken using a revalidated Bexhill Hastings Link Road assignment model. The Local Plan evidence base does not appear to include any documentation covering the revalidation of the model. Without an assessment of how good the model is we are unable to concur that the outputs are reliable.

In terms of any impacts upon the SRN, our concerns relate to the non-consented development element of the Local Plan. The two future year scenarios examined in the above report are the "2028 with DaSA" and "2028 without DaSA". In terms of the modelling approach our essential requirement is to compare the 2028 with consented development scenario against the 2028 with additional non-consented scenario. In this respect, the "with" and "without" scenarios in the report (based upon the allocations in Table 2-3) do not quite seem to equate to the housing and employment numbers or allocations in Table 18 and Paragraph 8.19 of the main "Development and Site Allocations Local Plan Proposed Submission" document. Clarification is required as to whether Highways England's requirement has been met in this regard particularly as the sites at Barnhorn Green, Grand Hotel and Worsham Farm appear to be committed development. Any non-consented windfall assumed should also be included in a non-consented scenario.

Page 6 of the Highways Capacity Assessment Report states that the "2028 without DaSA scenario "excludes traffic growth due to increases in households or employment in the locations of development in the DaSA scenario". Information should be supplied to explain how this was done.

The Highways Capacity Assessment Report shows in Table 2-3 the numbers of trips to and from the modelled site allocations. We would like to see TRICS outputs showing trip rates for the different allocations to establish whether they are robust.

The Highways Capacity Assessment Report states that for both future scenarios that a furness procedure has been used to determine the future trip distributions. We request that the trip row and column totals within the matrices be provided prior to furnessing to ascertain whether the differences are significant (unless the process was singly constrained).

The Highways Capacity Assessment Report has focussed on development solely within the Bexhill Bexhill/Hastings part of Rother District. The model does not extend out towards Rye in the east and Wadhurst in the north. Further information and potentially assessment is required of non-consented development impacts upon the SRN elsewhere in the District, or text on why further assessment is not required. At this stage we consider that although the model includes the A259 trunk road it should at least be extended to include the A21 north of Hastings.

The Highways Capacity Assessment Report assumes a number of highway improvements will have been implemented by 2028. These are:

* The North Bexhill Access Road (NBAR)
* Queensway Gateway Road (QGR)
* Complementary measures associated with BHLR - junction improvements on The Ridge at Queensway and Harrow Lane and bus priority measures on the A259
* Junction improvements due to North East Bexhill development
* Signalised junctions of B2182 Holliers Hill / A2036 Wrestwood Road and B2182.

Whilst we are aware of the programme for the more significant schemes (NBAR & QGR) there is no detail on these schemes, no junction or link analysis, nor a programme to show that all of these improvements will be in place at the appropriate point in the Local Plan.

Notwithstanding these comments and queries the highways report includes V/C outputs for the 2028 "with" and "without" scenarios. The plots appear to show increasing numbers of vehicles and capacity issues on certain sections of the A259 classed as SRN. For our purposes it would be more useful to look at queues and delays rather than V/C ratios to ascertain whether the differences between the scenarios require further more detailed examination and mitigation. Assuming that the above queries and comments can be resolved we would need to see outputs in these formats moving forward.

The assessment shows increases on the A259 during the AM and PM peak periods, in the range of 50-200 vehicles per peak period. With our earlier comments above in mind with regard to the use of V/C in the assessment, the V/C ratio analysis highlights specific sections of the A259 that are shown to be operating at over 80% capacity. These being:

* A259 West of Little Common
* A259 East of A269 signal junction
* A259 East of A2036 roundabout (near Bexhill Leisure Pool)

However, the report contains no mitigation proposals for any junction or link that is shown to exceed capacity in 2028. Whilst here is a "Potential Mitigation Measures" chapter this does not deal with specific measures and is rather vague and includes items such as MOVA or SCOOT, along with other undefined junction modifications / improvements. It is not possible for Highways England to give views on the suitability of the proposed developments without there being clear identification of where mitigation is required, and what form it will take.

Your attention is drawn to Paragraph 18 of Circular 02/2013 which states that "Capacity enhancements and infrastructure required to deliver strategic growth should be identified at the Local Plan stage, which provides the best opportunity to consider development aspirations alongside the strategic infrastructure needs."

In the absence of any proposed mitigation measures which have been demonstrated to provide a 'nil detriment' situation, nor costings and funding sources, Highways England has no confidence that the development in the Plan is deliverable without severe harm to the SRN.

In addition, within the councils Core Strategy adopted in September 2014, policy TR3 is clear that "development will be permitted where mitigation against transport impacts ... is provided." It would appear therefore, that the requirements of Policy TR3 are not met within the Highways Capacity Assessment Report, and therefore the developments proposed in DaSA are not shown to accord with the councils adopted Core Strategy.


Infrastructure Delivery Plan (IDP)

The IDP needs to be brought up to date once SRN mitigation required to deliver the development in the Local Plan has been agreed with Highways England. As part of this, any works will need to be costed and realistic funding sources identified. Funding via CIL contributions is not appropriate for SRN improvements as this does not provide sufficient certainty. All improvements/mitigations to the SRN will require section 278 of the Highways Act 1980 agreements.

There are also several references to the Highways Agency within the document which should be updated to Highways England.

Highways England can advise that the A259 Little Common roundabout improvement has been implemented.


Highways England's Current position

Highways England therefore considers that the DaSA Local Plan is not sound on transport grounds as it does not meet the tests of Justified nor Effective.

Whilst our current position may not be what the council had hoped for, we are keen to work with you, East Sussex County Council and any consultants employed by the councils to resolve our concerns and comments as advised above. We hope that we can reach a position prior to EIP which will enable us to enter into a Statement of Common Ground with the Council and County Council which shows that all parties consider the Local Plan is sound in terms of Transport matters. We look forward to your response in due course and hope that you find these comments, queries and advice useful.