11.126

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Object

Proposed Submission Development and Site Allocations (DaSA) Local Plan

Representation ID: 24272

Received: 07/12/2018

Respondent: East Field Action Group

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Any proposals for dealing with surface or foul water will be inadequate & adversely affect many Fairlight residents & their properties, I refer to the report from David Holmes BSc, CEng, MICE, objecting to planning application RR/2018/2726/P.

The proposal fails to meet guidelines in PPS25: Development and Flood Risk.
The Flood Risk Assessment for application RR/2018/2726/P states the intention of draining the proposed site by connecting to the existing public sewerage system and watercourse. Both systems, which rely on gravity flows, are inadequate to deal with the existing situation. Future development will only aggravate and increase the risk of foul and surface water flooding downstream.

A feasibility study to address the lack of capacity in the public sewerage system has been commissioned. However, it is difficult to envisage a gravity scheme which will overcome the inherent physical restraints.

Replacing the existing sewer with a larger capacity will not resolve the problem as it will further restrict the private drains from discharging to the public sewer.

Duplicating the existing sewers will not solve the problem of poor gradients inherent in the topography. The existing sewers, as they silt up, trap organic matter, giving off an unpleasant odour.

Full text:

We find nowhere within the commenting system makes provision for addressing the failure to follow the Statement of community involvement.

East Field Action Group
c/o Keith Jellicoe
St Catherines
Waites Lane
Fairlight

5th December 2018

Ref: DaSa_2018_Proposed Submission

The East Field Fairlight Action Group (EFFAG) was founded in 2012, members joined because they were opposed to the potential development & consequences it would have on the village. EFFAG speaks for its membership of some 130 residents, with the additional support of the Fairlight Preservation Trust (200 Members), the Fairlight Residents Association has some 350 Households, of which the majority are against ANY development of the site. Whilst we cannot speak for the wider Rather community, it may well be that they have also been failed by the consultation process. A Survey carried out by FPC in 2016 found that 78& of residents wished to protect & preserve green space, 76% wished to preserve heritage assets (farmland is a heritage asset) 79% wished to protect & preserve the character of Fairlight, 77% we concerned about traffic issues. Yet RDC excluded most of them from the consultation process.

EFFAG believes that RDC has failed to follow the Statement of Community involvement in that:

Means of involving people

2.5 The Council will seek to choose the appropriate consultation processes that best balance community impact, accessibility and available resources. Greater use is being made of online and social media methods of consultation, while appreciating that they are not accessible for all sections of the population.

The council failed to seek the appropriate means of consultation in that the only methods of publication have been the council website & 1 small advert in the local Observer newspaper. 51% of Fairlight residents have no access to the internet (it may well be a similar figure elsewhere in Rather due to a predominantly older population) & so are fully excluded from knowledge of, or access to plans & documentation, the local shop sells less than 50 copies of the newspaper. Since the majority of Fairlight Residents are over 65 (RDC are aware of this) it should have been anticipated that such restricted method of notice was insufficient & therefore exclusive of certain "Hard to reach groups".

We believe RDC has unfairly discriminated against older people & is therefore ageist.

Who can be involved in plan-making?

3.8 There will be opportunities for everyone to participate in the production of all planning policy documents, as shown above.

Opportunity to participate exists, only where prior knowledge of said opportunity exists, how would people without internet access know that they could participate.