11.109

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Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24278

Received: 07/12/2018

Respondent: East Field Action Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The 21 dwellings have not been justified.

The landscape assessment has been badly carried out with a predisposed bias towards finding suitability for a development, the opening statement makes that clear.

The study aim is already biased toward some form of development, the focus is on what level of development could be sited here.

Had the Landscape assessment been carried out with a neutral perspective, the outcome would be somewhat different. The site is visible from many areas so how is the visual impact low? Landscape sensitivity would be Medium-High not medium-low, Landscape Value is correct at High, this would make the landscape capacity "Low" hence not suitable for any development.

The proposed development will not conserve & enhance natural beauty.

There are errors in the Landscape Assessment.

The OS map of 1883 shows the same boundaries as today with the addition of the houses built along Pett Level Road & Waites Lane, the former boundaries being the roads themselves, the other 2 boundaries (Ghyll stream & hedgerow) remain unchanged. Area B1 was separated from B2 by the still existing hedgerow, it is B2 that has lost its divisional hedge.

Full text:

There has been no case for justification of these "outstanding" 21 dwellings.
The landscape assessment used to justify building on this land has been badly carried out with a predisposed bias towards finding suitability for a development, the open statement makes that clear.

1.1 Study Aims

1.1.1 The Landscape Group of East Sussex County Council was commissioned in May 2018 by Rather District Council to carry out a landscape assessment of Wakeham's Farm, as specified in the project brief (Appendix 1).

1.1.2 The aim of the study is to define the relative capacity of the landscape of the site area to accommodate varying scales of development. The assessment will have regard to the scope for mitigation of potential development without detracting from the existing intrinsic character of the landscape.

The study aim is already biased toward some form of development, rather that defining the Landscape & Visual
Sensitivity per-se, the focus is on what level of development could be sited here, therefore placing the report writer under some pressure to find in favour of development.

Had the Landscape assessment been carried out with a neutral perspective, the outcome would be somewhat different, how is the visual impact low when the site can be seen from more than half of Fairlight Cove village, both from roads & houses, from the National Trust land & from "upper" Fairlight. Landscape sensitivity would be Medium-High not medium-low, Landscape Value is correct at High, this would make the landscape capacity "Low" hence not suitable for any development.

The primary purpose of AONB is to "Conserver & Enhance natural beauty" '"Natural Beauty" is not just the look of the landscape, but includes landform and geology, plants and animals, landscape features and the rich history of human settlement over the centuries'. More recently the Natural Environment and Rural Communities Act 2006 clarified that land used for agriculture, woodlands, parkland or with physiographical features partly the product of human intervention in the landscape, is not prevented from being treated as an area of 'natural beauty'.

Nowhere in this plan is it indicated how this proposed development will conserve & enhance natural beauty, if anything the reverse is true & so it is unsound.

Section 3.2.2 mentions the "virtually continuous ribbon development from Hastings to Cliff end", 3 gaps of 1/2 mile hardly fall into the continuous category.

Section 4.3.4 Landscape Assessment area B2 "The wooded ghyll stream to the south of this site is a key component of the character of which could be affected if this part of the site were to be developed", that same stream runs all the way down from the country park through area B1, how will developing B1 not affect the wooded ghyll in the same way? The stream is not "mainly culverted" it is in fact mainly open save for where it is crossed by a road. The back gardens of Broadway form only a small part of the southern boundary as the road pulls away from the field after a short distance.

"Natural Character" 2 of the major field boundaries are mentioned, then the writer goes on to say the field boundaries are lost? Which is it?

The OS map of 1883 shows the same boundaries as today with the addition of the houses built along Pett Level road & Waites Lane, the former boundaries being the roads themselves, the other 2 boundaries (Ghyll stream & hedgerow) remain unchanged. Area B1 was separated from B2 by the still existing hedgerow, it is B2 that has lost its divisional hedge.