I, as do the vast majority of local residents, prefer the site Policy no. BX3 - site ref:
BX124 and feel that there is more feasibility for even more development within the site by also developing options 2/3. This would be more beneficial for all Bexhill residents and those who would be living on the new site.

Because of its location it is much more suitable for development than other areas of
Bexhill and Little Common. It would have a much better access to Schools, GP's, shops and the Conquest Hospital etc without the need to enter on to the A259 saving pollution and congestion either side of Little Common Roundabout.

Employment is very limited in the Little Common Area, the construction of business
areas within BX124 will be able to offer local residents a livelihood close to their homes without the need to clog up the already overstretched A259.

I believe there should not be any further major developments in or around existing
residential areas within Bexhill and Little Common who infrastructures are already under tremendous strain.

I would like to see it amended and it would be more prevalent to include the 50 affordable housing proposed for Spindlewood Drive within the options of 2 or 3 of Policy BEX3 (N BAR) due to better availability to schools, GPs, shopping centres etc and far less Impact on the community as a whole.

The affordable houses would be better developed as under Option 2 on the NBAR development. This would reduce the density on Spindlewood with great effect.

I do not agree with Policy BEX3.

Definitely amendments are required for the affordable housing (50 houses proposed for Spindlewood), to be sited on the North Bexhill Access Road development where there is much better access to infrastructure.

Policy BEX3 - the NBAR development is supported. However, Option 2 (plus development of the Northeye site) or Option 3 should be adopted. This would negate the need to develop less suitable sites (such as BX116 - Spindlewood Drive).

There would be considerable benefits for the residents sited at the NBAR development with better infrastructure access to GPs, schools, shops and pharmacies without having to use the A259.

Social cohesion for families will be far better met by them living in an area better services for schools, shops and easier access to surrounding areas, where employment may be sought.

Therefore the NBAR development would be able to accommodate such needs more satisfactorily than Little Common which is already strained to the limits in terms of school, GP, traffic and parking.

BEX3 DEVELOPMENT

(NBAR) North Bexhill Development,
Looking at this site (Bex3) moving forward it has a far better proposed and constructed infrastructure and is a breath of fresh air for Sidley and surrounding areas, I should know I was born and lived there for 30 years.

Increasing the supply of high quality employment sites, providing for business development in locations that make effective use of rail and water transport opportunities, notably at the Port of Rye; (v) seeking town centre, or edge of centre, sites for offices, including as part of mixed-use developments, for Bexhill it's a good way to move forward but only with good road system.

With the new Coombe valley way link road and easy access to Hastings, St Leonards and importantly onto the main A21.

The main A21 is a more direct route to the M25 the North and Ashford international station, The other access route that would be use is the A269 leading towards the West, because of newly developed link roads this would take some of the strain of the A259 leading through Little Common which at present is overburdened even before the development of Barn Horn Green and the proposed development of Spindlewood and Northeye.

We all know that a bypass starting at Northeye (A259) and leading straight onto the North Bexhill access road and then onto to new Coombe Valley Way is the answer, but this is not going to happen for a long while.

We have to remember that a lot of local business that use the A259 going West are affected by road congestions and at present the A259 is nightmare at Little Common Roundabout and is not looking to improve, in fact it's getting worse even before proposed building.

This is why I believe that BEX3 is going forward and I would amend it because it has far better space to expand, whereas the development like the proposed Spindlewood would only be a contribution to gridlocking the now heavily congested A259 at Little Common.

To whom it may concern,

I am writing to you about the development plans you have for the areas around the north Bexhill access road . I run with my family Cobbs hill farm caravan and camping park that is down Watermill lane and I have lived there most of my life. As for the road and housing I do not know how much this will effect our home/business but I do know how much having a travellers site will, having experienced travellers when they moved to a nearby field 10 year ago . Because we have a footpath that goes through the back of the caravan park when the travellers lived nearby they had easy access to the caravan park and we had lots of problems mostly theft and verbal abuse, I do not want myself, my family or the visitors that come to Bexhill for a holiday to have to experience any of this.

I know you say you have to put traveller sites somewhere but I really would not wish this on anyone.

Do these proposals actually mean anything do the people of Bexhill actually have a say or will you just go ahead and do as you like changing the plans as you go?

In North Bexhill where 3,000 homes are planned, we should consider having a different layout and design, and not have the awful developments we are seeing in the area.

We are finding an increase in mental health and self-harming, coupled with depression. If you see the new estates that are going up, one can see why this is. Those houses at Pebsham are not good for health and well-being.

I enclose my housing and care plan. And also my wish list for County Council elections in May 17. Developers look out.


Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28018

These comments are submitted as a joint response from the Spindlewood Drive Action Group (SPINDAG) and thus represent the majority views of a large number of local residents (c 400) living in and around the Spindlewood Drive proposed development area.

The DaSA Local Plan Policy BEX3 (13.16) relates to land ref. BX124 to the north of Pebsham and Sidley. SPINDAG strongly agrees with this preferred site but considers that there is even more potential for development within BX124 than proposed in option 1 by developing option 3 as well. We strongly suggest that this would be more advantageous to all Bexhill residents and not just those who will be living on the preferred site BX124.

1. The main advantage of development within BX124 is that this is a new site without the physical constraints of an existing environment. Therefore, this offers a rare opportunity for a free and unencumbered approach for the development of homes and business space on a brand new site which would not interfere with or detract from other areas of Bexhill as other preferred sites undoubtedly would.
2. In order to minimise unnecessary car journeys and create a sense of community, it would be essential to provide local amenities within new developments. Site BX124 should enable suitable space for local shops and community facilities as already identified in BX124 option 1.
3. Access to BX124 will be via NBAR so the effect of new development here would not adversely affect the already congested A259 through Little Common.
4. BX124 refers to traffic constraints along St Mary's Lane but if NBAR were to be extended westwards from the A269 out to the A259 near the Lamb at Hooe (thereby creating a Little Common by-pass) , there would be easy access to BX124 from east and west without detriment to the local road network around St Mary's Lane, which has been identified as a key constraint/opportunity.
5. We note that Policy BEX3 option 1 refers to development to the south of NBAR but believe that RDC's housing needs could be better met by additionally adopting option 3 (which includes land to the north of NBAR) rather than putting extra strain on the infrastructure in other areas of Bexhill wherever land can be identified. Should there be a requirement for additional housing post 2028, further development to the north of NBAR could be considered as there is not only ample space but there will already be essential community amenities in place. Road access by bus or car via NBAR would also be possible without further road improvement.
6. In view of its location, BX124 is much better suited for development than any other areas of Bexhill and Little Common. BX124 will enjoy easy access via NBAR to Coombe Valley Way and thence to Ravenside, Conquest Hospital, GP surgeries at Bexhill Old Town and Sidley, Bexhill town centre itself and, indeed, the A21 to Tonbridge and London. None of these journeys would exacerbate the current congestion on the A259 nor add to pollution levels caused by traffic queues at congestion points such as Little Common roundabout.
7. BEX1 and BX113 commercial developments should provide employment for NBAR residents with access directly off NBAR itself which will be beneficial in reducing traffic movements and pollution and again would not contribute to additional traffic flow and congestion on the A259. It is obvious that, geographically and logistically, such advantages could not be readily available to new residents of any other proposed developments in Bexhill or Little Common.
8. Increased development in BX124, rather than elsewhere in Bexhill, would not result in a greater volume of traffic on the A259 with corresponding higher levels of pollution, which has recently been shown to pose a serious potential risk of dementia to local residents.
9. The construction of business areas within BX124 will offer many local residents employment near their homes. This is environmentally more sensible and preferable to building more homes elsewhere in Bexhill and for new residents in those areas having to travel to work in BX124.
10. Employment opportunities are very limited in Little Common so that people living in any new developments in this location would have to travel elsewhere for work. Their children would also have to be driven to schools in other areas. All these extra car journeys would increase congestion along the A259 and its approach roads. Surveys have shown that the A259 currently has to cope with a level of traffic which is already close to that forecast for 2028.
11. In view of this, we believe there should be no further major development in and around existing residential areas within Bexhill and Little Common since this would inevitably cause additional strain on the infrastructure (roads, GP surgeries, primary schools, parking etc.) which is already struggling to cope in many parts of the town.

Conclusion
Development within BX124 offers an exciting opportunity for a sustainable community with appropriate local amenities which would not adversely affect the infrastructure and lives of people in other areas of Bexhill. There is much better access to and from BX124 which would enhance the lives of its residents and not worsen the congestion and pollution on the A259 but improve traffic flow generally. An extension westwards of the NBAR (Little Common by-pass) would make BX124 an even more attractive proposition not only for people living there but also for other residents of Bexhill and indeed anyone using the A259. Should there be a requirement for additional homes post 2028 it would be simpler and far more environmentally friendly to extend BX124 rather than try to find sites in and around existing residential areas where there are no suitable infrastructure facilities or capacity.

We note that there is a Travellers' Site for five vans shown on the Plan. If this goes ahead, could we please have assurances that this number of vans will not be exceeded ?

I strongly agree with RDC's proposed development at BX124 as it is an absolutely ideal site for this purpose. Indeed, there is even more potential for development here by pursuing option 3. This would be beneficial not only to people living in this new development in BX124 but improve the quality of life for those people living elsewhere in Bexhill. The main reasons for this would be less strain on local infrastructure and an easing of congestion on the A259 through Little Common.

1. The main advantage of BX124 is that it is a fresh site so development would not impinge on other people's lives as there is nobody already living there.
2. Local amenities can be built as required for the express use of BX124 residents.
3. Access to and from BX124 via NBAR would not add to but actually relieve the congestion on the A259 nor would it increase traffic pollution on this road.
4. An extension of NBAR from St Mary's Lane westwards to the A259 near the Lamb at Hooe would effectively create a bypass for Little Common with all the benefits involved not only for people living in Little Common but people just using the A259 to travel from east to west and vice versa. This extension of NBAR should be built and paid for by the developer.
5. Development at BX124 could be extended if necessary at future dates even if there are no more suitable sites identified in Bexhill itself.
6. Residents from BX124 requiring amenities (Conquest Hospital, railway stations, shops, GP surgeries) would be able to achieve speedier access via NBAR than if development were to take place in any other areas of Bexhill.
7. Commercial developments in BX124 would provide employment for some of its residents again reducing the need for travel and therefore congestion.
8. A sustainable community with its own amenities could be developed in BX124 with a resulting sense of community and belonging. This would not adversely affect the lives of other Bexhill residents in the way that further development in Little Common or Bexhill would.
9. Environmentally it makes sound sense to develop BX124 option 3 and not build any more large developments in Little Common.

Question 29
Once again we have commented on this question in questions 27 and 35 and would like our comments taken into account here particularly in relation to the North Bexhill Access and Link Road. There are better options particularly for those needing welfare housing on lower incomes to services e.g. closer to schools off Enterprise way, Doctors, shops and Pharmacies at Ravenside and more options to public transport and local routes

Please see my comments with supporting paperwork on:

1. BX124 Boundary
2. BX124 Proposed Pedestrian Link

My comments specifically refer to North Bexhill Development site BX 124 and in particular the encroachment of BX 124 boundary into my property grounds.

I have enclosed Figure 19 (Bexhill North Housing Options Map) and have highlighted within a black rectangle an area that I have expanded in another enclosure (BX124 Expanded Screen Shot - Boundary Comments) to show my property boundary in relation to the BX 124 boundary.

In the BX 124 Expanded Screen Shot I have again highlighted within a black rectangle and highlighted in yellow my property grounds and boundary.

It can clearly be seen that the BX 124 boundary encroaches almost halfway into my grounds.

It is requested that in future iterations of your North Bexhill Development site BX 124 documentation that you amend the BX 124 boundary to respect my property boundary so that the BX 124 boundary does not encroach upon my grounds.

Enclosures:
1. Figure 19 - Bexhill North Housing Options Map
2. BX124 Expanded Screen Shot - Boundary Comments

Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28026

Your Ref. 6.3.5/DaSA OPO Consultation
Rother District Council
Development and Site Allocations (DaSA) Local Plan
Options and Preferred Options Consultation.

I received a letter informing me of the above just before Christmas. I chose not to look at these plans until the new year to minimise impact through the festive period. For the past month, I have been perusing the document in order to respond, I trust you will take the time to read my response in full.

a) For future consideration, I request that the Planning Department does not send out information of such a nature prior to Christmas. I feel it is quite thoughtless to have little consideration for existing inhabitants of the area.

b) Secondly, I discover, however, that there seems to be little knowledge of this document locally and those people it affects in the immediate area of Watermill Lane have not received the communication I received. This can hardly be called a consultation period. Why were letters not received by many existing inhabitants of the area?

c) I can only respond directly to my immediate area but I am sure that many points will be generic in their content.

d) I understand that there are three options, one of which will go ahead regardless of public consultation, and that Option1 is the preferred option. Is this correct?

e) Whilst I am not in favour of any development of this land, I understand the need for housing and can only hope that the council has made every effort to ensure that there is no available housing or sites lying empty which could be utilised within Bexhill and the surrounding area.

With reference to question numbers, I haven't come across any to respond to, I am simply responding to my reading of the document.

3.2 The North Bexhill Access road is identified as necessary to accommodate the scale of planned growth for Bexhill in highways terms.

SA7
Point 6: The timely delivery of the North Bexhill Access Road creates the basis for an accessible new development.

Comment: it would have been more open and honest for the council to have said at the time that the road was part of bigger plans to provide housing etc. in North Bexhill. I object to the way that existing inhabitants have been kept in the dark and have only been able to surmise what would happen. Working in partnership would be a better OPTION.

3.2 Relieving Sidley of significant through traffic.
Comment: The people of Sidley had a dreadful time when the link road was built. I distinctly remember hearing at a meeting that once it was completed Sidley would be showcased and put on the map again. This did not happen.

The access road will indeed take more traffic away from Sidley. Will planners please take a hard look at Sidley and work out ways in which 'The Heart of Sidley' can be supported, as well as being busy planning to urbanise rural areas?

3.2 P24 Restorative works in relation to Access Road
Comment:
Which area of grassland will be returned to the landowners for agricultural use following the completion of the Access Road?

3.3 Existing public footpaths

It is assumed that the potential exists to upgrade the existing footpaths within the study area to create new combined pedestrian/cycle routes in order to accord with the objective of creating a series of new traffic free routes.

Comment
Traffic free routes are good for ramblers, cyclists and dog walkers. Has there been any study to indicate the likely take up of pathways? Unless you belong to one of these groups, what is the likelihood of using these routes? (Certainly not shoppers who rely on vehicles to get them from a to b and carry goods.)

Do walkers and ramblers want to walk through built up areas as looks to be the case to the east of Watermill Lane? There is talk of a corridor of open space (3.6.3) but this does not seem to exist to the immediate north of Chetwynd as plans seem to indicate that land up to the boundary will be used for housing except for a path for walkers and cyclists.

How will the council ensure that existing and new paths will not be used by fun motorbike users?

3.5.2 Business development
Comment

I trust that the council has made sure that all available business floor space is being utilised in Bexhill town centre, Sidley and surrounding areas as the whole area is in need of regeneration regardless of what is being proposed?

I understand that Options 2 and 3 are not favoured because they include business areas which would be sited to the north of the Access Road and to date it is not known how much more business development will be needed.

3.6 'The LPCS requirement for business floor space has potentially been met at Bexhill by existing commitments.' However, I am aware that this land will be earmarked for development at a later date, as will those areas marked for housing in Options 2 and 3. Is this a fair conclusion?

3.5.3 Potential travellers site

Comment
I note that there is reference to a potential travellers' site in all options. This therefore reads as not being an option as with the whole of the plan to develop the rural area into an urban area. Is this correct?

Additional information see comments: page 14
SA3 Reduce crime and the fear of crime.

3.6. Development option 1
3.6.2 Access

Comment
Reference is made to at least one property outside the development area, in Ninfield Road being demolished for vehicular access. Have existing inhabitants been notified of this likelihood because they, like all existing inhabitants of the area, should be entitled to know what is being planned for them?


3.6.3 Green infrastructure

Para 3. 'The principle open space corridor running through the Development Option (1) is focussed along the Combe Haven and the existing watercourse to the west before it becomes Combe Haven. This maintains a substantial corridor of open space running in an east west direction through the study area connecting ... Combe Haven Park'

Comment

If I am reading this correctly the open space corridor is cut short in the vicinity of Chetwynd as the field adjacent is shaded yellow and the key states 'potential residential area.' (p29)

However, on p81 the area is marked protect and enhance wildlife inhabitants. Is housing planned up to the proposed traffic free route on the northern boundary line of the property? Please clarify. If so, why weren't the existing owners of the land notified of this development?

In Dev Option 1 the land to the west of Chetwynd is at present privately owned fields with stables. This is shown as two shades of green on Option 1 plan. On p68 the plan highlights the main part of the land to 'protect and enhance wildlife habitats.' Is this correct and if so what does it mean for the existing owners? Is it proposed that the land will be taken to protect and enhance wildlife habitats? Please clarify.

4.7
A significant increase in public open space in this part of Bexhill will have a positive impact on the health and well-being of both existing and new residents. (SA2)

Comment
Is this fact or opinion? Have existing residents been asked for their views? I object to being included in this statement.

I would like it to be noted that when any development is planned, be it for a road, housing or business that there is something fundamentally wrong with the way in which councils, planners and developers go about their planning. It appears to be devious and underhand and is done to communities, I guess all over the country, causing a great deal of stress and anxiety to existing residents and land owners. It's this tough luck attitude, we're going to make money out of this attitude, we don't care about you attitude. Please put it on an agenda to be discussed.

5.3 Preferred development option
The incoming and existing residents in the area will both benefit from the new infrastructure opportunities ...

Comment

The assumption is made that existing residents will benefit ... I object to being include in this statement. Has any research been carried out?

6.1.4 Quality of architecture
This refers to 'the architectural design of the new dwellings overlooking the NBAR' which will be an extremely important consideration particularly for 'people approaching the town on foot from the existing public footpaths.'

Comment
I suggest that the future inhabitants of these new areas will not mainly be walking into Sidley and Bexhill as implied but to the nearest bus stop if they do not own a car. The distance and the hilly nature of the area will prohibit much walking into town. (fact)

7.2
Comment
I understand that this report by CAS Environmental has been prepared to advise and assist RDC to consider the most appropriate form of development ... that the council should consider the recommendations for inclusion within the forthcoming Development and Site Allocations Plan, which it will need to consult widely on.

I trust that consultation will be widely publicised.

The BX124 NBAR development has the scope to be an exciting and extensive new development where there is great scope for the proposed numbers of properties and more, in certain areas; greater scope, certainly than some sites which attempt to insert new developments into small areas of existing residential areas, so lessening the impact on current residents and enhancing the environment for the new residents.

I believe it should be possible to comfortably accommodate at least the dwellings and business premises development suggested in Option 3. This would ease pressure for higher-density housing developments in some of the other Preferred Sites and the business premises development could potentially offer employment on the doorstep for new residents. This aids RDC with simultaneous progress towards residential development and economic development.

The open space around the NBAR gives good scope for proper development of local facilities, which were lost, for example, in the Barnhorn Green development. Local shops, doctors' surgeries, play areas, a sub-post-office, nurseries and other useful facilities could be incorporated at the planning stage and made mandatory for developers to provide. Development along these lines would not affect such a large number of existing residents as most of the other larger development proposals.

In addition, new residents would have easy access to the services of Sidley and the wider area via the Bexhill-Hastings Link Road and the improved A21 access now under development. Additionally, new residents here have easy access to the north west via the existing A269 and beyond it the A271, further reducing west-bound journeys which would otherwise go along the A259.

Furthermore, if we had a Bexhill western bypass (linking the NBAR to the A259 west of Little Common) it could give BX124 residents easy access to east or west via those link roads without any added load on the A259 through Little Common.

I agree with RDC's proposed development at BX124 as it is an ideal site for this purpose. Indeed, there is even more potential for development here by pursuing option 3. This would be beneficial not only to people living in the new development in BX124 but improve the quality of life for those people living elsewhere in Bexhill. The main reasons for this would be less strain on local infrastructure and an easing of congestion on the A259 through Little Common.

1. The main advantage of BX124 is that it is a fresh site so development would not impinge on other people's lives as there is nobody already living there.

2. Local amenities can be built as required for the express use of BX124 residents.

3. Access to and from BX124 via NBAR would not add to but actually relieve the congestion on the A259 nor would it increase traffic pollution on that road.

4. An extension of NBAR from St Mary's Lane westwards to the A259 near the Lamb at Hooe would effectively create a bypass for Little Common with all the benefits involved not only for people living in Little Common but people simply using the A259 to travel from east to west and vice versa. This should be built and paid for by the developer.

5. Development at BX124 could be extended if necessary at a future date even if there are no more suitable sites identified in Bexhill itself.

6. Residents from BX124 requiring amenities (Conquest Hospital, railway stations, shops, GP surgeries) would be able to achieve speedier access via NBAR than if development were to take place in any other areas of Bexhill.

7. Commercial developments in BX124 would provide employment for some residents again reducing the need for travel and therefore congestion.

8. A sustainable community with its own amenities could be developed in BX124 with a resulting sense of community and belonging. This would not adversely affect the lives of other Bexhill residents in the way that further development in Little Common or Bexhill would.

Environmentally it makes sound sense to develop BX124 option 3 and not build any more large developments in Little Common.

Murphy Associates has been appointed to submit a representation to the Development and Site Allocations Local Plan (DaSA) and for this to be given due weight and consideration in the review of site allocations. Ultimately my client would expect a positive outcome of the representations and for the 'Submission Version' of the Plan to reflect this by including the identified site within the
Allocations for North Bexhill Area.

It is recognized that the Rother District has difficulty in providing a sufficient supply of land to meet the required 5-yr supply and an appropriate buffer, be that 5% or 20%, depending on performance and delivery. The District is constrained by the sea, High Weald AONB, the SSSI and Ramsar Site of the Pevensey Levels but also infrastructure.

The Bexhill Link Road may have provided improved accessibility to the main route network but the DASA indicates a greater amount of new roads and links that will effectively release land for development.

Whilst my client does not object to the general requirements of Policy BEX2, I would advise that the tentative support also includes an objection to the omission of land to the west side of St Mary's Lane.

Figures 23, 24 and 25 depict Preferred Options 1, 2 and 3 for the North Bexhill Area (BX124) along with significant road improvements. An area is shown with the triangle formed by St Mary's Lane and the A269 with a proposed allocation for housing. That area of land is within the High Weald Area of Outstanding Natural Beauty and although previously or currently used for agriculture, is still
considered to be suitable for a large quantum of residential development and associated infrastructure.

The future development of this triangular area will bring The Spinney and the nearest dwelling to the south, closer to, and abutting the new urban edge that would be created.

However, it is inconceivable the all traffic generated by future development would only use the A269. St Mary's Lane which is already used as a local 'rat-run' would see a significant increase in traffic, particularly by those travelling west - east thereby reducing travel along Turkey Road to reach the A269 Ninfield Road junction.

St. Marys Lane is narrow, has a width restriction in place and within a 30 mile per hour zone, both of which are completely ignored. Within the northern half of the road, beyond the recreational ground, there are numerous places where the width does not allow 2 cars to pass. The road is prone to flooding and subsidence due to significant traffic movement. An increase in traffic movement will undoubtedly result in the lane requiring improvement, particularly if one considers a new proposed access from the lane, along my client's southern boundary, to serve additional
housing land to the north west.

With any of the options, there will be a change in character and appearance of the lane. It will no longer read as semi-rural lane but a suburban distributor road and even more so with Option 3. We recognize the concerns regarding Option 3 but note that this would enable Rother District Council to increase its ability to meet it housing shortfall and 5-yr housing land supply as obliged to do so.

Nevertheless, and whilst improvement of the lane is welcomed by my client, on her behalf, we object to the indication in Option 3, that the land upon which her dwelling, the associated ancillary building and the garden area, is indicated 'Proposed Open Space, with Enhanced Green Space'.

Moving forward with positivity, although Option 1 is the LPA's Preferred Option, my client would support Option 1 or 2, subject to the following revisions:

* a new access formed onto St Mary's Lane to serve the residential development envisaged to the east side
* the improvement of the lane
* inclusion of land occupied by The Spinney, and the dwelling to the south including the intervening field.

In justifying this, the land designations in this area are noted, including the High Weald AONB and the Semi-Ancient Woodland to the north, further to the south west and south. However, the site of The Spinney is already developed. It is considered to be previously developed land as recognized by the NPPF in its definition of brownland. This opinion has been reinforced in the judgment of Dartford BC v SSCLG [2016] EWHC 635. It is inconceivable to consider that the LPA would seek
the demolition of two existing dwellings to facilitate the provision of natural open space as well as a link road through to lands to the north west.

These amendments would provide a clear containment demarcated by existing property and field boundaries, creating a natural edge to the proposed extension of the Built Up Area or Urban Fringe. It would afford protection to the Semi Ancient Woodland and access through to a greater area of Proposed 'Natural' Open Space, even if by way of new pedestrian links.

This specific area, including my client's land and that to the south, provides an opportunity for a holistic development of the area, with greater opportunities to evolve a masterplan incorporating a more comprehensive strategy for green space and green networks in a meaningful manner to reinforce the characteristics of the area.

The Spinney, the property to the south and the intervening land would provide the opportunity for a sensitive residential development aligned with the Key Opportunities as set out on page 147 - 148 that have been identified for both existing and new residents.

Question 29:

Therefore and in response to Question 29: Policy BEX3 should be amended to reflect the comments/objections above and therefore BEX3(ii), (xii) and (xiii)). We consider that the criteria at (v) would be enhanced by the inclusion of the lands referred to on the west side of St Mary's Lane; that (vii) and (viii) would not be affected; that (x) could be further improved to the west providing greater east-west movement.

We do not consider that revisions to Options 1 or 2 would cause a coalescence of built form or lessen the value of the High Weald AONB or the broad-leafed Semi-Ancient Woodland.

I understand that the DaSA Local Plan Policy BEX3 (13.16) relates to land ref. BX124 to the north of Pebsham and Sidley. I strongly agree with this preferred site but consider that there is even more potential for development within BX124 than proposed in option 1 by developing option 3 as well. I also strongly suggest that this would be more advantageous to all Bexhill residents and not just those who will be living on the preferred site BX124.

1. The main advantage of development within BX124 is that this is a new site without the physical constraints of an existing environment. Therefore, this offers a rare opportunity for a free and unencumbered approach for the development of homes and business space on a brand new site which would not interfere with or detract from other areas of Bexhill as other preferred sites undoubtedly would.

2. In order to minimise unnecessary car journeys and create a sense of community, it would be essential to provide local amenities within new developments. Site BX124 should enable suitable space for local shops and community facilities as already identified in BX124 option 1.

3. Access to BX124 will be via NBAR so the effect of new development here would not adversely affect the already congested A259 through Little Common village.

4. BX124 refers to traffic constraints along St Mary's Lane but if NBAR were to be extended westwards from the A269 out to the A259 near the Lamb at Hooe (thereby creating a Little Common village by-pass) , there would be easy access to BX124 from east and west without detriment to the local road network around St Mary's Lane, which has been identified as a key constraint/opportunity.

5. I see that Policy BEX3 option 1 refers to development to the south of NBAR but believe that RDC's housing needs could be better met by additionally adopting option 3 (which includes land to the north of NBAR) rather than putting extra strain on the infrastructure in other areas of Bexhill wherever land can be identified. Should there be a requirement for additional housing post 2028, further development to the north of NBAR could be considered as there is not only ample space but there will already be essential community amenities in place. Road access by bus or car via NBAR would also be possible without further road improvement.

6. In view of its location, BX124 is much better suited for development than any other areas of Bexhill and Little Common Village. BX124 will enjoy easy access via NBAR to Coombe Valley Way and thence to Ravenside, Conquest Hospital, GP surgeries at Bexhill Old Town and Sidley, Bexhill town centre itself and, indeed, the A21 to Tonbridge and London. None of these journeys would exacerbate the current congestion on the A259 nor add to pollution levels caused by traffic queues at congestion points such as Little Common roundabout.

7. BEX1 and BX113 commercial developments should provide employment for NBAR residents with access directly off NBAR itself which will be beneficial in reducing traffic movements and pollution and again would not contribute to additional traffic flow and congestion on the A259. It is obvious that, geographically and logistically, such advantages could not be readily available to new residents of any other proposed developments in Bexhill or Little Common Village.

8. Increased development in BX124, rather than elsewhere in Bexhill, would not result in a greater volume of traffic on the A259 with corresponding higher levels of pollution, which has recently been shown to pose a serious potential risk of dementia to local elderly residents.

9. The construction of business areas within BX124 will offer many local residents employment near their homes. This is environmentally more sensible and preferable to building more homes elsewhere in Bexhill and for new residents in those areas having to travel to work in BX124.

10. Employment opportunities are very limited in Little Common Village so that people living in any new developments in this location would have to travel elsewhere for work. Their children would also have to be driven to schools in other areas. All these extra car journeys would increase congestion along the A259 and its approach roads. Surveys have shown that the A259 currently has to cope with a level of traffic which is already close to that forecast for 2028.

11. In view of this, I believe there should be no further major development in and around existing residential areas within Bexhill and Little CommonVillage since this would inevitably cause additional strain on the infrastructure (roads, doctors' surgeries, primary schools, parking etc.) which is already struggling to cope in many parts of the town.

Conclusion

Development within BX124 offers an exciting opportunity for a sustainable community with appropriate local amenities which would not adversely affect the infrastructure and lives of people in other areas of Bexhill. There is much better access to and from BX124 which would enhance the lives of its residents and not worsen the congestion and pollution on the A259 but improve traffic flow generally. An extension westwards of the NBAR (Little Common village by-pass) would make BX124 an even more attractive proposition not only for people living there but also for other residents of Bexhill and indeed anyone using the A259. Should there be a requirement for additional homes post 2028 it would be simpler and far more environmentally friendly to extend BX124 rather than try to find sites in and around existing residential areas where there are no suitable infrastructure facilities or capacity.

Why was it that we first learnt about the new road and building plans from a man who worked for a national building company. He knocked on our door wanting to buy our family house and land to build on. He also told us that a new road was being put in. Why does no one come and talk to the home and land owners before decisions are made to alter our way of life and property.

I do realise that change has to happen. However we have lived here for many years surrounded by country side and you are now going to urbanise us. Not only are you putting in a new road and possible new buildings you are also putting in a bicycle track alongside our property! A traveller camp within metres of us, are you trying to make our lives hell. We had travellers move in the field next to us about 8 years ago and caused us nothing but trouble. I was having confrontations with them regularly to keep them off our property. My wife and children did not want to go across to our fields afraid for their safety. Are we going to put through this hell yet again?

QUESTION 29: Do you agree with the requirements of Policy BEX3? If not, how would you wish to see it amended?

1. THE GOVERNMENT'S EMPHASIS AND URGENCY FOR THE NEED OF A CONSIDERABLY ENHANCED HOUSING STOCK IS NOT DISPUTED. BUT OF THE OPTIONS CONTAINED IN BEX 3, I CONSIDER BX124 TO BE THE MOST SUITABLE BECAUSE:

A. IT HAS MORE DEVELOPMENT POTENTIAL
B. IT HAS FEWER TRAFFIC CONSTRAINTS, PARTICULARLY IF THE A259 AND A269 ARE DEVELOPED.
C. IT WOULD ENJOY EASY ACCESS TO COOMBE VALLEY WAY AND RAVENSIDE, CONQUEST HOSPITAL, GP SURGERIES IN BEXHILL, ITS TOWN CENTRE AND THE A21. THESE JOURNEYS WOULD NOT EXACERBATE THE CURRENT CONGESTION ON THE A259 NOR ADD TO POLLUTION LEVELS CAUSED BY TRAFFIC QUEUES AT CONGESTION POINTS SUCH AS LITTLE COMMON ROUNDABOUT.

BEX3

We agree with the BEX3 Option 2.

* Such a development would be pleasant place in which to live, with easy access to local facilities.

* It already has some of the required infrastructure nearby and there is room for additional affordable housing and a new school.

* It would not have a major impact on the A259.

I have called into the Town Hall on two previous occasions, when I had asked for details about the proposed development. The first time I was told, by the person on the desk, that they knew nothing about it and did not know who would. I was told to go home and phone in. The second time, I was again told that they knew nothing about it, but did make some phone calls and then said that could not find anyone who could help me.

I called again Friday, 17th February, when this time the young girl on the desk gave me this email address and your name, but apologised that no-one would come out to talk to me about it.

My first question has always been is there any point in taking up a objection as for most situations in the past when Rother has put it "to the Public" it seems that they have already made their decision.

Glyne Gap should have been, according to what we were told, a Leisure Complex. What we got was a very small swimming pool, a bowling alley and commercial properties.

The Link Road, despite opposition went ahead costing more that quoted and taking longer to complete.

We were asked about another junction and road to the now existing link road and I know there was a lot of opposition to it, but when the link road was built the junction at the roundabout and the signs for it were built and erected along with the road, even though, as we were told, no decision had been made.

I have just been told of another development where planning was given for houses, a school and a doctors surgery, but without discussion with any members of the public, the school and doctors surgery were dropped in favour of more houses.

Now, with this proposed development, it was released to the public December 22nd 2016, Christmas week, following the governments idea of releasing bad news when the public are distracted by something else. There are over 2,300 pages of the full report with plans of such a small scale and poor quality that it is impossible to see anything in any sort of detail and despite what must have taken a long time to produce, we, the public are given very little time to read, understand and comment on any of it.

One of the access roads into the proposed housing estate seems to go through my property or my neighbours. I have spoken with both of them and they know nothing at all about this.

I only know about the proposed development because my neighbour mentioned it and after talking with my neighbours I would like to know how you can justify saying that you have put it out for public opinion when most of the public know nothing at all about it. Am I wrong or is this gross deception. In my opinion, the council have definitely not tried to inform the public. As I stated the council have been no help when I tried to get information and the amount of paperwork and its quality make it impossible for anyone to make an informed comment in the short time we have been given.

Having just spent a very large amount of money on work to our house to improve access for my wife to the house and garden, this proposal has blighted our property and will cost us far more than I have spent and will continue all the time this is up for consideration and should we wish, I think I will have a problem selling it.

Could I please have a plan of the proposed development area behind me especially showing the places of the access roads.

1. Introduction

1.1 This representation is prepared on behalf of Mr F. Forte in response to Rother District Council's 'Development and Site Allocations Local Plan' preferred options consultation document.

1.2 Mr F. Forte is promoting land at Rialto Hall, St Mary's Lane, Bexhill-on-Sea for residential development. The site plan for each site is contained within Appendix A.
1.3 The comments and objections within this representation relate directly to this site.
1.4 Following its review of this representation, we respectively request that the Council amend its proposed designations to include the whole of this site as a residential allocation.

2. Policy BEX3: Land at North Bexhill

2.1 In principle our client supports Policy BEX3, which relates to land at North Bexhill in so far that it allocates this area for mixed development incorporating approximately 450 dwellings.

2.2 However, our client strongly objects to the site boundary and the North Bexhill detailed maps in Figure 23, 24 and 25. Our Client also objects strongly to a number of the criteria policy elements of Policy BEX3. We will expand upon these objections below.

The North Bexhill Site Boundary

2.3 Our client's land is split across two sites in Figure 19 'Bexhill North Housing Options Map'. These sites have the reference BX124 and BX125. This categorisation is illogical as:

- The site is within single land ownership and forms part of a single
residential curtilage.

- The Council's evidence base assesses our client's land as part of a site to
the west of Ninfield Road. There is no evidence to justify the separation
of our client's land into two separate land parcels for policy purposes.

- The part of the site that falls within BX125 is separated from the
remainder of BX125 by Ninfield Road which acts as physical and visual
barrier to our client's land.

- The part of the site that falls within BX125 has very different visual
character to the remainder of BX125, with it having a residential
character as opposed to the open countryside of the remainder of the
site.

2.4 The North Bexhill Site Boundary, which constitutes BX124 and is shown in red line outline on figure 26, should therefore be amended to include the whole of our client's land, not part of it.

2.5 Paragraph 158 of the NPPF is very clear that each local planning authority should
ensure that the Local Plan is based on adequate, up-to-date and relevant evidence
about the economic, social and environmental characteristics of the area.

2.6 Paragraph 182 of the NPPF expands on this requirement stating that for a local plan to be sound it must be justified i.e. the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.

2.7 The exclusion of our client's land that falls under BX125 fails the test soundness as the Council has either not produced any evidence or published any evidence that justifies the exclusion of this land as a development area. In contrary to the position that the Council has taken under Figure 19, the Council's own evidence actually supports the inclusion of client's land, as a whole, as a development area.

2.8 The North Bexhill Landscape and Ecological study: Report 1, which was published in August 2015 considers our clients land in full under reference 'LDU F'. This land is considered alongside land to the south. There is no suggestion that part of this land forms part of the wider BX125 area. It actually reinforces our point that Ninfield Road acts as a barrier to the land to the east.

2.9 Paragraph 2.4.27 of this land scape report provides a description of the site stating that it comprises of a triangular land parcel that is relatively flat land, containing two properties (one of which is our clients). It is pointed out that there an established hedgerow/tree line along the route of Ninfield Road, separating it from the land to the east. Paragraph 2.4.28 points out that LDU F is well contained in views, although there are localised views from St. Mary's Lane. Paragraph 2.5.32 points out that this site has Moderate Low' sensitivity to change and that the site is separated from the wider rural area by a combination of the local road network and by the surrounding topography.

2.10 Like the majority of the land under LDU F, our client's land in full should be included within BX124 and the red line outline of the North Bexhill development area on figure 26, not BX125.

North Bexhill Detail Map, Options 1, 2 and 3

2.11 Our client strongly objects to the allocations set out in Figure 23, 24 and 25 where they relate to his land to the west of Ninfield Road. Each of these options has split our client's land with the southern part of the land being put forward as a residential area, whilst the northern part of land has been put forward as a new woodland buffer. The Council has not produced any evidence to justify this woodland buffer designation and it appears to have been marked on the plan
as a whim.

2.12 The whole of our client's site should be put forward for residential development.

2.13 The important characteristics concerning this land and the proposed allocation can be summarised as follows:

- The land comprises a residential curtilage in private ownership and our
client has no desire or intention to create a woodland on his garden land.
It is not realistic that the Council will force the loss of this private garden
land and create a woodland buffer in its place.

- The residential allocation on land assumes access is achieved from the
new North Bexhill Access Road roundabout on to our client's land and
yet the vast majority of the residential allocation is on the adjoining land
to the south. This would result in the loss of a large high valued
residential dwelling to serve another site. There is no financial incentive
to encourage our client to make this land available as the number of net
dwellings that can be accommodated on the development site and within
our client's ownership is not enough to make the scheme viable, bearing
in mind an estate road would also need to be provided across his land.
Clearly if access cannot be gained from our client's site due to viability
concerns, then the wider site to the south cannot be delivered.

2.14 As mentioned above, the NPPF requires each local planning authority to ensure that the Local Plan is based on adequate, up-to-date and relevant evidence (paragraph 158). The plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence (paragraph 182). The Council's exclusion of the northern part of client's land has not been justified and indeed the Council's own evidence indicates that our client's land should be considered as a whole and would be appropriate in full as a development site.

2.15 Our client's land is assessed under the reference 'LDU F' in the North Bexhill Landscape and Ecological Study: Report 1. The site, along within the land to the south, was considered as a whole and at no point within this document was it suggested that LDU F needed to be split up between a development area and a new woodland buffer. The key conclusions concerning this land can be summarised as follows:

- Paragraph 2.4.28 - This LDU has few significant landscape features and
has relatively ordinary scenic value. It occupies an area of flat topography
in proximity to Ninfield Road and the northern approach to Bexhill. It is
well contained in views, although there are localised views from St. Mary's
Lane and from the public footpath which extends along the southern
boundary.

- Paragraph 2.4.29 - 'Potential mitigation/avoidance of effects' suggested
as being to retain and enhance the existing landscape framework and
respect the semi-rural setting of St. Mary's Lane.

- Paragraph 2.4.30 - It is stated that this area as a whole has a 'Moderate
High' capacity to accommodate change owing to its relatively ordinary landscape character and limited visual sensitivity.

- Paragraph 2.5.32 - landscape sensitivity was assessed as being 'Moderate Low'. Key features cited as: site shares few characteristics with the wider High Weald; it has few scenic qualities; it is predominantly residential; domestic landscaping acts a detracting element; the site is predominantly flat; it is relatively well related to the existing settlement pattern on the edge of town; the only landscape mitigation suggested as being the retention and management of existing landscape features.

- Paragraph 2.5.33 - Visual sensitivity was assessed as being 'Moderate Low' across the whole site, although only the southern part of the site beyond our client's ownership had high sensitivity due to views from the public footpath. The site is enclosed by the existing wooded embankment and vegetation along Ninfield Road. The only mitigation suggested was the reinforcement and management of existing
vegetation along St. Mary's Lane and Ninfield Road.

Paragraph 2.5.35 - Landscape value was assessed as being 'Moderate Low'. Key features cited as: no designations for landscape or ecological value and no heritage assets which would be directly affected; this area has little scenic value and comprises farmland on the edge of the settlement and the grounds of two dwellings. It was stated that this site as a whole 'Moderate High' capacity to accept change, concluding that This area comprises relatively ordinary farmland and the curtilage of two properties. It has potential to accommodate some development without giving rise to significant landscape and visual effects.

2.16 There is no mention within this document suggesting a need for a large woodland buffer on our client's land, only the reinforcement and management of existing vegetation.

2.17 It would not be unreasonable for a planning application to include a landscape strategy for this site that can address these mitigation measures, however it is excessive to include a large woodland designation on our client's land, particularly when it cannot be implemented and has not been justified through proportionate evidence. This woodland designation amounts to just a whim.

2.18 The 'North Bexhill Appraisal and Recommendation of Development Report 2' was published in August 2016. The plan on page 13 highlighted that our client's land as a whole has moderate high capacity to accommodate new development.

2.19 Paragraph 2.3.3 supported this assessment stating that:
"the Landscape Study concludes that some parts of the Study Area have a better
capacity to accept change than others. The areas to the east of St. Mary's Lane and
Ninfield Road and to the north west of Mayo Lane are found to have the highest
capacity to accommodate new development, with them possessing a moderate high
capacity to accept change, as it would not appear discordant with the existing
settlement pattern on the northern edge of Bexhill and be well related to the existing
edge of the town, with the area being separated from the wider landscape to the north as a result of the intervening topography".

2.20 A plan is introduced on page 33 of this document that shows the northern part of our client's land as being within an area of habitat enhancement. As explained above, neither this document or Report 1 has ever suggested a need for this designation.

Furthermore, this report does not explain or justify the designation, it is only shown on a plan and as such it cannot be used to justify a designation in the Development and Site Allocation DPD.

2.21 In considering development options, a plan on Page 24 shows the North Bexhill Access Road where the approved road will meet Ninfield Road. The new
roundabout adjoins our client's site.

2.22 Paragraph 3.6.2 states that the parcel of residential development to the west of Ninfield Road would be accessed from the new A269 roundabout. However, this access will not be deliverable or viable unless our client's land, in full, is included as a residential development area.

2.23 As set out in paragraph 173 of the NPPF:

173. Pursuing sustainable development requires careful attention to viability and
costs in plan-making and decision-taking. Plans should be deliverable. Therefore, the
sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened.

2.24 The Development and Site Allocations DPD expects the access to the land west of Ninfield Road to be from our client's land, yet the Council has sought to minimise
residential development on this land by drawing the development area tightly and
incorporating a spurious woodland buffer area over the garden land. Our client's
property constitutes a high value residential dwelling. It is unreasonable to expect our client to allow this property and land to be redeveloped with a woodland buffer and estate road that primarily serves another site, without giving consideration to the viability and deliverability of the allocation as a whole. Our client's land is required in its entirety to enable the access road to be achieved. Without this land being included, the preferred option allocation will be undeliverable and unviable.

2.25 Our client seeks to work with the Council to develop the whole of this site. Matters relating to landscape and ecology mitigation and be addressed at the planning application stage. They are inappropriate in this instance as specific designations as there is no justification for them and they would have the effect of sterilising the land, affecting viability and preventing the land west of Ninfield Road from being delivered as a whole and as such it would be contrary to the requirements of the NPPF.

Part (xi) a restriction on the occupation of development until the NBAR is
constructed and open to traffic

2.26 Our client objects to the requirement that prevents the occupation of development until the North Bexhill Access Road is constructed and open to traffic. In the case of land to the west of Ninfield Road, this parcel of land could be delivered independently of the construction of the North Bexhill Access Road.

2.27 There are no site specific constraints that would prevent the development of the whole of our client's land and as such it could form part of the five-year land supply. Development of client's land would also enable access to the wider site to the south.

2.28 A suitable access could be achieved from Ninfield Road to facilitate the development that could in the future be incorporated into the North Bexhill Access Road.

2.29 The NPPF requires local planning authorities to significantly boost the supply of housing and ensure that there is a sufficient supply of housing to maintain a five years worth of housing against their housing requirements. By restricting development at this location, the Council is undermining its housing strategy and preventing some sites from being delivered in a timely manner.

3. Conclusion

3.1 Our client requests that the whole of the land within his ownership to the west of
Ninfield Road be allocated for residential development as:

- This land is required to facilitate access to the preferred residential
allocation at this location. Without a residential scheme the preferred
option would be would be unviable and undeliverable.

- This site could be delivered in advance of the North Bexhill Access Road
and would boost the Council's 5-year land supply.

- The Council's evidence base documents identify this land has having low
landscape qualities and a high capacity to accept development change.

- No evidence has been produced to justify a woodland buffer designation
at this location. This woodland designation would sterilise this existing
residential garden land and in any event, the designation cannot be
delivered and would make the residential allocation to the south
unviable.

- Landscape and ecological mitigation measures are more appropriately
addressed through the planning application process, not through a
spurious woodland buffer designation.

3.2 Our client seeks to work with the Council to develop the whole of this site. Matters relating to landscape and ecology mitigation and be addressed at the planning application stage and are inappropriate in this instance as specific designations as there is no justification for them and they would have the effect of sterilising the land, affecting viability and preventing the land west of Ninfield Road from being delivered as a whole and as such would be contrary to the requirements of the NPPF.

This is the outstanding site for development within Bexhill and needs to be progressed to its fullest extent.

The site offers superb advantages over any other site proposed for Bexhill in that it offers

1. A brand new site location in green fields that will have no impact on other local communities

2. Little or no environmental damage as a result

3. A self-contained community with local shops being provided thereby reducing the need for excessive car journeys

4. Access to excellent local infrastructure facilities without needing recourse to the A259 including
a. Local jobs (being provided along the NBAR) as well as easy access to St Leonards, Hastings and Bexhill
b. 2 GP surgeries close by (old Bexhill and Sidley)
c. Local schools via Enterprise Way including a brand new nursey and primary school
d. Large scale shopping centres at Ravenside, St Leonards, Hastings and Bexhill with a 24 hour pharmacy at Ravenside
e. Good train services to London and elsewhere via Bexhill and St Leonards Warrior Square
f. Excellent car access to most locations via Coombe Valley Way including the A21 and the Conquest Hospital

Option 1 (450 properties) does not go far enough therefore and the site should be extended up to Option 3 (665 houses) with commercial building too to maximise job possibilities for the residents.

Ideally, the NBAR should be extended to link up with the A259 at Hooe (The Lamb Inn) to form a Little Common/Bexhill bypass. This would bring major benefits to the whole of Bexhill in that it would

1. Alleviate the congestion along Barnhorn Road and Little Common Road by a significant factor

2. Improve the productivity of locally based firms based in Hastings, Eastbourne and St Leonards with considerably improved journey times between these areas

3. Open up the possibility for further significant mixed development all along the bypass and along the NBAR helping RDC to meet its housing and commercial targets beyond 2028

It should be noted however that such a bypass would not address the issue of Little Common's lack of basic infrastructure.

Conclusion
1. BX124 is a must for large scale development (both commercial and residential) and should thus be pursued to its maximum extent (Option 3)

2. A Bexhill bypass is also a must in the slightly longer term (unless suitable funds can be arranged) to alleviate the significant congestion along the A259 (and just about to get worse due to Barnhorn Green)

3. Large scale developments should thus be avoided around Little Common until and unless the Bexhill bypass is in place and the problems of local infrastructure constraints have been solved around Little Common.

Wastewater Treatment

As you are aware. Southern Water is the statutory sewerage undertaker in Rother District. In line with paragraph 162 of the National Planning Policy Framework (NPPF) and the National Planning Practice Guidance (PPG), we have updated our site-by-site assessment of the sites with 20 or more dwellings identified in the draft Development and Site Allocations Local Plan (DeSA) to determine whether capacity in the local sewerage network is sufficient to meet the anticipated demand.

That assessment reveals that additional local sewerage infrastructure would be required to accommodate the proposed development, involving making a connection to the local sewerage network at the nearest point of adequate capacity.

a) Insufficient capacity

A lack of capacity is not a fundamental constraint to development however new or improved infrastructure would need to be provided in parallel with the development.

Connection to the sewerage network at the nearest point of adequate capacity is the mechanism by which the development can provide the local infrastructure required to service the sites. Southern Water has limited powers to prevent connections to the sewerage network, even when capacity is insufficient. Planning policies and planning conditions, therefore, play an important role in ensuring that development is co-ordinated with provision of necessary infrastructure.

Unless planning policies support delivery of necessary underground sewerage infrastructure there is a risk that it will not be delivered in parallel with the development, leading to an unacceptable risk of foul water flooding in the area to both new and existing residents. This situation would be contrary to paragraph 109 of the NPPF, which requires the planning system to prevent both new and existing development from contributing to pollution.

It is likely that investment would be required to deliver additional wastewater treatment capacity. This strategic infrastructure, such as extensions to wastewater treatment works, can be planned and funded through the Price Review process, and coordinated with new development. Last year's (2015) price determination will fund the investment programme for the period to 2020. There will be another price review in 2019, covering the investment period 2020 to 2025. Adoption of development plan documents provides the planning certainty required to support investment proposals to Ofwat, the water industry's economic regulator.

We have therefore proposed policy provision below to secure delivery of necessary local sewerage infrastructure in parallel with development. Our proposed policy provision would be in line with paragraph 157 of the NPPF which states that Local Plans should 'plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this framework', and paragraph 177 of the NPPF outlines that it is important to ensure that planned infrastructure is deliverable in a timely fashion.

Furthermore, it is important to give early warning to prospective developers regarding the need to connect off-site, as it could add to the cost of development. Early warning will facilitate delivery of the necessary infrastructure as this infrastructure requirement can then be incorporated into the planning process at an early stage.

b) Underground Infrastructure

Although not strictly a planning policy requirement, where appropriate we would also seek recognition of the need to protect underground infrastructure that cross the site so that this is not built over, and it can continue to fulfil its function. Easements would be required to allow access for future maintenance and upsizing. We have noted which sites this may apply to as an early warning to potential developers.

Proposed amendments

In line with the NPPF and National Planning Practice Guidance and to ensure a sustainable development, we propose that the following criteria are added to the list of considerations for the policy detailed above.

We request additional criteria for this policy relating to utility infrastructure:

* A connection is provided to the local sewerage system at the nearest point of adequate capacity, in collaboration with the service provider.

(Please note that Southern Water requires access to the existing outfall. The need for easements will therefore need to be taken into account in the layout of the site).

We strongly believe that the proposed Spindlewood Drive development be incorporated into the proposed BX124 development. This is because:

* It is on a site that is already earmarked for development as a result of the new roads that are being planned for the area.

* It will have minimal interference with existing residents.

* The required infrastructure can be incorporated within the development. (doctors surgery, schools, etc.)

* Traffic will be directed away from the main areas of congestion within Little Common.

The planned development to the North of Pebsham and Sidley relating to land ref BX124 is a preferred site. There is the possibility of further development. This would be beneficial to all Bexhill residents as this is a new site with no existing residential environment. New homes and businesses on a new site would offer less impact on an already settled community with the opportunity to provide local amenities such as shops/school/doctors etc.

Access to BX124 will not have such an impact on the busy A259, Little Common area. There is mention of traffic going along St. Marys Lane. If NBAR were to be extended from the A269 to the A259 near The Lamb at Hooe, this would take a great deal of traffic away from A259, Little Common.

BX124 is better suited for development with access via NBAR to Coombe Valley Way with easy access to shopping at Ravenside, GP Surgeries and Bexhill Town Centre, taking traffic away from the A259. This will help with the growing levels of air & noise pollution within the A259 areas.

With little employment in Little Common people living in the proposed development BX116 would need to travel to work, putting more pressure on the congestion along the A259 which is already high, this will increase the levels of air & noise pollution on the residents of the Little Common area which should be avoided for everyone's health.

Should additional properties after 2028 be needed it would be environmentally better for the community to extend BX124 than to extend areas where there is not the infrastructure to support new dwellings.

The following comments, related to biodiversity matters, are made on behalf of the Sussex Wildlife Trust.

If a question from the consultation is not included below, please assume that the Trust has no comments to make at this time.

PART B: DEVELOPMENT POLICIES

QUESTION 2: Do you agree that the optional water efficiency standard should be adopted and the proposed policy wording?

We are concerned that this policy appears to limit itself to water efficiency and believe that it should be broader in its approach to water resource management. The policy appears to consider only domestic water efficiency and we question if the policy should also consider commercial use.

QUESTION 3: Where, if anywhere, do you think could be an appropriate location for wind turbine(s) to be sited in the District?

Any proposal for wind turbines and associated infrastructure, such as connections to the grid, needs to ensure that impacts on biodiversity and their placement within the landscape in terms of their potential impacts on ecological networks are assessed before suggestions are made regarding suitable locations.
Therefore changes in policy wording to reflect this should be made.

QUESTION 4: What opportunities do you think there are to encourage biomass/wood fuel from local sources and how should these be reflected in planning policy?

This could be demonstrated through a policy which encourages biomass potential in commercial and possibly residential developments through appropriate design. However, the policy would need to recognise the importance of protecting woodlands so that their biodiversity value is considered and enhanced through the process. Further, the Rother Local Plan currently does not include an ancient woodland policy; if a wood fuel policy is adopted a separate ancient woodland policy is needed.

QUESTION 7: Do you agree with the policy approach to equestrian developments and the proposed policy wording?

We are encouraged to see the supporting text for this policy recognise the sensitivities of equestrian developments in the countryside and the need to ensure that these features are safeguarded. In relation to this we highlight that in paragraph 7.16 the last sentence states 'However, there is scope for equestrian development in the countryside that is limited in scale'. The term 'scale' perhaps needs defining to add clarity.

We are concerned about equestrian developments being proposed on designated sites such as Local Wildlife Sites. Therefore we welcome an approach to more clearly defined acceptable limits of equestrian development in relation to designated sites. The policy could benefit from underlining the need for up to date ecological management plans accompanying proposals, as per National Planning Policy Framework ( NPPF) section 165.

QUESTION 12: Do you agree with the proposed policy approach to external residential areas and the proposed policy wording? If not, what changes would you wish to see?

Creative approaches and orientation should be considered when designing external spaces. Their setting within the green infrastructure aspirations of the District should be looked at during the planning application stage. This would ensure a holistic and considered approach to green infrastructure.

While bullet point (i) gives clarity to the external spaces of dwellings of 3 or more bedrooms, there is a lack of commitment to the amount of space need for flat and complex developments. The last sentence of this bullet point states that, 'an appropriate level of usable community and amenity space should be provided'. We are concerned that this statement does not give the decision maker a clear enough direction for its interpretation.

Bullet point (ii) should reference the need to be permeable and where gardens are being lost efforts should be made to ensure there is no loss to biodiversity reference NPPF section 109. The council may find the RHS advice leaflet useful www.rhs.org.uk/advice/profile?PID=738

We suggest bullet point (iii) uses wording to incorporate green roofs on waste and recycling stores to help add to a developments' contribution to biodiversity as per NPPF section 118 'Opportunities to incorporate biodiversity in and around developments should be encouraged'.

QUESTION 13: Do you agree with the proposed policy approach to extensions to residential gardens and the proposed policy wording? If not, what changes would you wish to see?

This is an interesting policy and we welcome its inclusion. The Sussex Wildlife Trust have concern that an extension to a garden, if allowed, could in time lead to other development within that garden boundary. Therefore, the type of habitat a garden extension would involve needs to be considered.

We remind Rother District Council that the NPPF section 53 highlights the need to resist inappropriate development of gardens. Therefore perhaps wording to this effect is needed within the policy.

QUESTION 15: Do you agree with the policy approaches to boundary treatments and drives and accesses and to the wording of the proposed policies? If not, what changes would you wish to see?

The Sussex Wildlife Trust suggests that policy DHG7 (Boundary Treatments) includes wording to reflect the sentiments of section 118 of the NPPF.

This could be achieved by including a bullet point requiring impermeable boundary features to include gaps or passages beneath them to enable movement of wildlife such as hedgehogs and amphibians.

In addition policy DHG8 (Accesses and Drives) should reflect the need to ensure the proposals for new driveways do not lead to a loss in natural capital delivering ecosystem services. Therefore these should be permeable and look to include biodiversity features. See RHS guidance www.rhs.org.uk/advice/profile?PID=738

QUESTION 18: Do you agree with the policy approaches to maintaining landscape character and the High Weald AONB and to the respective proposed policy wordings?

The Sussex Wildlife Trust supports the policy approach to maintaining landscape character and the High Weald AONB. We recommend that policy DEN2 be strengthened by the addition of wording requiring development to deliver biodiversity gains which meet the AONB objectives.

We are concerned that the wording in the last sentence of the policy 'major development will be resisted' would not allow a decision maker to be clear when determining an application. What is the level of resistance intended?

QUESTION 19: Do you agree with the proposed definition of the Strategic Gaps, and the policy applying to them? If not, what changes would you wish to see?

Figure 7 demonstrates that an area of the existing Bexhill and Hastings/St Leonards green gaps is proposed to be removed from the strategic gap. However the supporting text (10.19 - 10.21) does not indicate the reasons for the exclusion. We feel the supporting text for this section would benefit from a brief explanation for the reason in inclusion or exclusion of areas.

We ask the council to consider the value of the strategic gaps in harnessing the district's natural capital. This natural capital will be delivering vital ecosystem services to the district and potentially to the authorities adjoining Rother District. Therefore we would suggest that this is reflected in the policy wording by:
'Within these gaps development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive, not detract from the openness of the area and ensure that ecosystem services are not compromised.'

We believe this additional wording will reflect the importance of strategic gaps for ecosystems service delivery and will also enable the policy to sit in line with NPPF para 109.

QUESTION 20: Do you agree with the policy approach to supporting biodiversity and green space and to the proposed policy wording?

We are encouraged by the manner in which the supporting text for this policy has been approached. The Sussex Wildlife Trust supports the inclusion of an 'Enhancement Policy' approach, however the wording should be strengthened to better conform to the wording and ethos of Chapter 9 of the NPPF.

Part i - the qualification of 'in principle' should be removed. The proposal is either supported in full or it is not, 'in principle' adds nothing to the policy.

Part ii - the word 'significant' should be removed. All developments should aim to avoid harm to biodiversity.

Part iii - should look to reflect the sentiments of the NPPF section 109. The first sentence should be amended to read:
'In addition to ( ii) above , all developments will be expected to deliver net gain to biodiversity by retaining and enhancing biodiversity in a manner appropriate to the local context ....'

Part iv has a requirement for 'larger developments of more than 2 hectare or 50 dwellings...' to produce a green infrastructure (GI) masterplan'. Looking at the allocations, very few meet this requirement. We recognise that there are some larger allocations around Bexhill where we would certainly support the need to produce GI masterplans but we are concerned about the substantial number of allocations which do not meet these criteria. We suggest that the threshold is lowered to 25 dwellings. We also recommend that the policy requires all development to contribute to the aspirations of Rother's Green Infrastructure Strategy.

We suggest that Rother District Council include an Ancient Woodland policy within the Local Plan. This would reflect the ethos of the NPPF which clearly states in section 117:
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

QUESTION 21: Do you agree with the policy approach to sustainable drainage and the proposed policy wording?

Reviewing the supporting text and policy wording there is no recognition of Pevensey and Pett being low lying areas (below sea level) and the associated risk of sea and ground water flooding. We suggest that this is included.

QUESTION 23: Do you agree with the policy approach to managing environmental pollution through the planning process and with the proposed policy wording?

The policy would be strengthened by ensuring that there is mention of biodiversity within the policy bullet point relating to lighting.

Lastly, although the supporting text highlights that the district is not subject to any Air Quality Management Areas, with increasing development we suggest that the council recognise the natural capital that helps filter and deal with pollutants.

Increased levels of development in the district means resources may come under increasing pressure. It may benefit the council to consider talking to the Sussex Biodiversity Record Centre about their Ecoserve programme. This programme shows where the district's natural capital is delivering ecosystem services such as air purification in relation to population demand.

QUESTION 24: Do you agree with the policy approach to comprehensive development and the proposed policy wording?

We support recognising the importance of a holistic approach to development which considers the three roles of sustainable development. In order to achieve this within the policy wording we suggest that the policy looks to include wording regarding net gain to biodiversity as per section 109 of the NPPF. We feel that this is important as phased development may overlook the cumulative impact on the district's natural capital and the ecosystem services being delivered.

PART C: SITE ALLOCATIONS

General Comments
The Trust recognises that the presence of designated sites and priority habitats and species has been a contributing factor in the assessment of the suitability of site allocations. We very much support the council's approach to exclude designated sites and sites of high biodiversity value for development. However we note that the site assessments were primarily based on desk-top studies. With the exception of North Bexhill and Spindlewood Drive it does not appear that any on the ground assessments have been carried out.

Given the council's commitment in the Core Strategy objectives 'To protect important ecological resources in the district' and in policy EN5 to 'support opportunities for management, restoration and creation of habitats...' we recommend that preliminary ecological appraisals are carried out for the preferred sites before they are officially allocated. This will ensure that any issues relating to ecology are identified before the plan reaches the examination stage.

We are pleased to see that the 'Key constraints/opportunities' sections for many of the preferred site allocations consider ecological impacts. However, these considerations are again inconsistently reflected in policy wording. For example, policy IDE1 requires that an ecological assessment is undertaken and that any impact on protected species mitigated. Further to this, policy MAR1 states that development proposals should be subject to an ecological survey.

By singling out only two of the site allocations, this may give the impression that proposals for other allocations may not require ecological surveys. The NPPF has a clear requirement for planning decisions to be based on up to date information and for development to achieve net gains for biodiversity. It would not be acceptable for proposals to proceed without the inclusion of up to date ecological information, especially given that thus far the sites have only been assessed at a desk-top level. This position needs to be reflected in the Biodiversity Policy (please see comments for QUESTION 20) and in all the site allocation policies. Therefore the following wording should be added to all site allocations:
'Prior to determination:
A site wide landscape and ecological management plan that is informed by up to date ecological information, including information on the site's utilisation and delivery of ecosystems services, will be produced. Mechanisms needed for implementation will be identified and secured. This will be to the
satisfaction of the local planning authority to ensure long term maintenance of retained and newly created habitats.'

We recognise that information regarding a site's utilisation of ecosystem services maybe too onerous for small allocations. However, we take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Ecoserve. This programme uses biodiversity and habitat data to look at the ecosystems services currently provided by an area's natural capital. It also assesses where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider as an aid to helping smaller developments see how they could make a contribution or enhancements to the continued delivery of those services through their site.

Additionally, many of the site allocations are adjacent to ancient woodland. Again whilst this is usually noted in the 'Key constraints/opportunities' section, it is not consistently reflected in the policy wording for the allocation. For example Policy BRO1 part (v) specifies that 'a buffer zone of at least 15 metres is provided to the Ancient Woodland', while the presence of an ancient woodland is not mentioned in, for example, policy BEX1 or BEX2. Conversely policy BEX 9 does specify the need for a buffer to protect the adjacent ancient woodland, but the width of the buffer is not specified.

Core Strategy policy EN1 and NPPF paragraph 118 require the protection of ancient woodland in the district. Additionally, Natural England's Ancient Woodland standing advice is clear that a minimum buffer must be at least 15 metres. We therefore recommend that an Ancient Woodland policy is included in the DaSA and that any site allocation policy with the potential to impact on ancient woodland includes a requirement of a buffer zone of at least 15 metres.

We also note that most of the allocations require the 'retention and enhancement of boundary planting'. We understand that this requirement is primarily to mitigate visual impacts on the AONB, however this is also an opportunity to ensure that each allocation contributes to the creation of an ecological network for the district. We therefore recommend that when boundary planting is specified, additional wording is used, such as:
'Provision is made for the retention and enhancement of boundary planting, for the benefit of biodiversity and for screening purposes'.

The majority of the site allocation policies use the term 'some' when describing the number of dwellings or size of employment space required within a development. This is not a standard planning term and hence we are concerned that its use leaves the policies open to broad interpretation. Given the landscape and ecological sensitivities of many of the site allocations, we recommend that a maximum figure is proposed in each policy. This will provide clarity and ensure that the policy can be robustly applied.

Alternatively, if an approximate value is preferred, we recommend the use of the word 'approximately' rather than 'some' as this is more frequently used in a planning policy context. However, if the council is minded to use this approach, we would ask that an additional requirement is added to the policies to ensure that overdevelopment does not occur. We recommend the following:
'The final number of dwellings/employment size selected must be based on up to date environmental information that demonstrates the current ecosystem delivery of the site and its capacity to absorb the proposed level of development. '

QUESTION 26: Do you agree with the requirements of Policy BEX1? If not, how would you wish to see it amended?

General comment
The Sussex Wildlife Trust supports a plan-led planning process and acknowledges that site BEX1 is included in the adopted North East Bexhill SPD. However, we question whether the district's natural capital can absorb this level of development around Bexhill. All the allocated sites around the north east of Bexhill should be treated holistically and assessed for their impact on ecosystem services (NPPF paragraphs 109, 114 and 117). There must be a strategic approach to the development of these sites to ensure that ecological networks are retained across the sites.

Policy BEX1
We support the protection of the adjacent ancient woodland and the retention of the tree line through the centre of the site, as shown in the detailed map. However, this protection does not appear to be repeated in the policy wording. Additionally, the 'Key constraints/opportunities' section recognises that the land along the Combe stream to the north-west of the site should be retained as an amenity/wildlife corridor. Again, this is not reflected in policy wording. If requirements are not included in the policy, we are concerned that they may be disregarded at the application stage. This could also lead to confusion for developers and inconsistency in the decision making process. Therefore, policy BEX1 should be strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 The retention of the central belt of trees and enhancements to create a robust corridor between the ancient woodland and the wider countryside.
 The retention of the land along the Combe stream as an amenity/wildlife corridor
The Trust supports the retention of the central tree belt; however, the proposed access appears to sever this corridor. We recommend that the access is reconfigured to ensure the corridor is preserved in its entirety. If this is not deemed feasible wording should be added to ensure that the tree belt still functions as and ecological corridor.

It is vital that any green infrastructure within the site connects well to the surrounding area. We recommend additional wording in section (iv) to insure this:
'landscape and woodland belts are developed, implemented and connected to the wider landscape as an integral part of proposals'.

QUESTION 27: Do you agree with the preferred sites for housing development at Bexhill? If not, which site(s) should be preferred?

The Trust questions whether the district's natural capital is able to absorb this level of development around Bexhill. Before finalising site allocations, especially larger greenfield sites around the development boundary, we recommend that the council assesses the capacity of these sites to provide ecosystem services. We take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Eco serve which uses biodiversity and habitat data to look at the ecosystems services the natural capital is currently providing and where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider.
QUESTION 28: Do you agree with the requirements of Policy BEX2? If not, how would you wish to see it amended?

General comment
As per our comments for QUESTION 26, site BEX2 should be assessed strategically with allocation BEX1 and BEX3. Overall, these allocations cover a significant area of greenfield, which will be providing vital ecosystem services to the district. The cumulative impact of these allocations on the district's natural capital needs to be assessed and accounted for to ensure that the expansion of Bexhill is truly sustainable as per the NPPF. Additionally, any green infrastructure strategy should cover all these sites to ensure permeability throughout the developments and multifunctional benefits across the north east of Bexhill are achieved.

Policy BEX2
As per our comments for QUESTION 26, we are concerned that some of the intentions in the 'Key constraints/opportunities' section and the detailed map are not reflected in the policy wording. We recommend that policy BEX2 is strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 Part (ii) should include a requirement for the pond to be retained as an ecological feature with landscaping to connect it to the wider countryside

QUESTION 29: Do you agree with the requirements of Policy BEX3? If not, how would you wish to see it amended?

Notwithstanding our general comments in QUESTIONS 26 and 28, if development is to occur here then option 1 would be preferable. This would retain a larger proportion of greenfield and allow more creative approaches to green infrastructure and ecological enhancements. We recommend that information on the site's utilisation and delivery of ecosystem services should be produced and used to inform the site's layout.

The Trust is concerned that the now approved North Bexhill Access Road severs the ghyll woodland at Kiteye Wood.

Any development in this area should seek to mitigate this impact through appropriate habitat creation and/or management. Additionally, the policy should make reference to the retention of the land along the Combe stream as an amenity/wildlife corridor, as per policy BEX1. These requirements could be included in part (vii) of the policy, which we support.

As with previous comments the wording to protect ancient woodland should be strengthened to include a requirement for a 15 metre buffer.

We also recommend that the policy protects the 'Woodland Complex at Buckholt Farm' Local Wildlife Site, to the north east of the site allocation. Whilst it sits outside the development boundary, this ancient woodland could still be harmed by the indirect impacts of the development. These need to be assessed and avoided at the master planning stage.

QUESTION 33: Do you agree with the requirements of Policy BEX7? If not, how would you wish to see it amended?

The Trust supports the retention of the southern section of the site as an ecology area. However, the wording of section (iv) should be strengthened to include a requirement to enhance the area as per core strategy policy EN5. We recommend:
'The southern section of the site remains undeveloped as an ecology area. Ecological enhancements should be implemented to improve the area for biodiversity. Provision should be made for the long term management of this area.'
QUESTION 35: Do you agree with the requirements of Policy BEX9? If not, how would you wish to see it amended?

The Trust supports the retention of the tree belts in the centre of the site, the designation as a natural green space and the wording of part (vi). However, it is not clear to us how this corridor will be retained intact given that vehicle access is only proposed from the east of the site. This indicates that internal roads will sever the corridor in order to access the residential area in the North West. This should be a consideration in designing the layout of the site. At the very least we recommend wording to ensure that the integrity of the green corridor is maintained.

We support the inclusion of section (vii), however this should be strengthened with a requirement for the ancient woodland buffer at least 15 metres wide.

Additionally, it should be specified that the pond is retained as an ecological feature, rather than as part of any SuDS scheme for the site.

QUESTION 36: Do you agree with the requirements of Policy BEX10? If not, how would you wish to see it amended?

The Trust supports requirement (ii), however this should be expanded to specify that integration includes an integrated scheme of green infrastructure to ensure that the entire site remains permeable and receives multifunctional benefits.
The words 'where possible' should be removed from part (v). The pond should be retained and enhanced; this cannot be seen as unduly onerous given the site of the scheme.

QUESTION 37: Which of the development options for Northeye do you prefer? Should other options be considered?

Any policy for this site must include protections against the potential negative impacts of the creation of sports pitches such as flood lighting and impermeable surfaces. We recommend wording is included to ensure that there are no harmful impacts of this type of development.

QUESTION 38: Do you agree with the requirements of Policy BEX11? If not, how would you wish to see it amended?

This policy should include wording to manage the type of playing pitches which might be suitable on this site. Consideration should be made to the use of artificial pitches and associated lighting. In particular, potential impacts on bats which are likely to be present in the area should be considered.

QUESTION 43: Do you agree with the requirements of Policy BEX15? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that 'a large proportion of the site suffers from surface water flooding'. Therefore, we recommend that an additional criterion is added to the policy to ensure that a SuDS scheme is implemented to rectify this issue. We also recommend that green infrastructure is included to both help with the flooding issue and to connect the site to the wider GI network in the town.

QUESTION 47: Do you agree with the preferred site for housing development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust supports the allocation of brownfield sites of low ecological value over the allocation of greenfield sites. A large amount of development is already proposed for the fringes of Hastings through the Hastings Development Management Plan. We would not support any further urban sprawl into the surrounding countryside without full accounting of the area's natural capital and assessment of the area's utilisation and delivery of ecosystem services.

QUESTION 49: Do you agree with the preferred sites for employment development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust does not support further urban sprawl at the Hastings fringe; however of the four sites recommended, the preferred sites seem to be the least damaging. As stated previously we recommend that preliminary ecological appraisals are carried out before sites are formally allocated to ensure that there is no significant harm to biodiversity.

Additionally, a wider green infrastructure plan should be required, covering both of these sites in conjunction with the adjacent Hasting allocations to ensure a holistic approach.

QUESTION 50: Do you agree with the requirements of Policy HAS2? If not, how would you wish to see it amended?

We recommend that point (iv) is strengthened as follows to ensure net gains to biodiversity as per the NPPF:
'provision is made, in conjunction with the adjoining employment allocations, for the retention, enhancement and long-term future management of woodland to the north of the site for the benefit of biodiversity'.

QUESTION 51: Do you agree with the requirements of Policy HAS3? If not, how would you wish to see it amended?

We support criterion (iv), however any green infrastructure should be integrated into the surrounding employment allocations, to ensure multifunctional benefits are seen across the whole area.

QUESTION 53: Do you agree with the requirements of Policy HAS5, including the boundary as defined in the Policies Map? If not, how would you wish to see it amended?

We recommend an addition to criterion (ii) to ensure net gains to biodiversity as per the NPPF.
'...the Site of Nature Conservation Importance within it, and creates net gains to biodiversity within the Park...'

QUESTION 54: Do you agree with the recommendation regarding the Hastings Fringes development boundaries? If not, please explain how you wish the development boundaries to be applied to this area?

The Trust strongly supports the designation of a strong development boundary which prevents further urban sprawl into the wider countryside. (Please see QUESTION 47).

QUESTION 56: Do you agree with the requirements of Policy BEC1? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 57: Do you agree with the requirements of Policy BEC2? If not, how would you wish to see it amended?

We recommend that the policy is strengthened to better reflect the contents of the 'Key constraints/opportunities' section. In particular, reference should be made to the requirement to keep the remaining area as amenity land and to the retention of the pond as an ecological feature rather than as part of any SuDS scheme deemed necessary.

QUESTION 59: Do you agree with the preferred sites for development at Broad Oak? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value such as BO14. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 60: Do you agree with the requirements of Policy BRO1? If not, how would you wish to see it amended?

The Trust strongly supports the wording of requirement (v) and the specification of a buffer of at least 15 metres. We recommend that this wording is replicated in other policies for sites adjacent to ancient woodland.

We support requirement (iv), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 61: Do you agree with the requirements of Policy BRO2? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 65: Do you agree with the requirements of Policy CAM2? If not, how would you wish to see it amended?

This policy needs to be strengthened to ensure that the adjacent Local Wildlife Site, Local Geological Site, SSSI and Special Protection Area are protected from harm. Whilst the protection and management of the dunes is a key landscape and ecological objective of the SPD, there does not appear to be a specific requirement to protect and enhance these designated sites. This should be addressed in the policy.

QUESTION 66: Do you agree with the proposed development boundary? If not, how would you wish to see it amended?

The Trust strongly supports the deletion of the SSSI from the development boundary. Dungeness, Romney Marsh & Rye Bay SSSI is of national importance to biodiversity and should not be degraded through encroaching development.

QUESTION 68: Do you agree with the requirements of Policy CAT1? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that buffer planting should be informed by ecological surveys, however this requirement is not reflected in the policy wording. Given that the site appears to contain well developed scrub, any application for this site must include a thorough ecological survey to assess if the site can absorb the level of development suggested whilst producing net gains for biodiversity.

QUESTION 69: Do you agree with the requirements of Policy CAT2? If not, how would you wish to see it amended?

Requirement (iii) should be subject to ecological surveys to assess the impact of severing the hedgerow. We also recommend that 'for the benefit of biodiversity' is added to the end of requirement (iv)(b) to ensure that any tree and hedgerow planting contributes to the wider ecological network in Catsfield.

QUESTION 72: Do you agree with the requirements of Policy HUR1? If not, how would you wish to see it amended?

As the stream/ditch that sub-divides the two lower fields is recommended to be retained for both heritage and ecological reasons, this should be reflected in the policy. We recommend that requirement (vii) is amended to:
'...is retained and incorporated within the layout as an ecological feature. Development should ensure that the biodiversity value of the feature is enhanced and that it is integrated into the wider blue/green infrastructure plan for the site...'

QUESTION 73: Do you agree with the requirements of Policy HUR2? If not, how would you wish to see it amended?

This site is adjacent to Hurst Green Meadows and Woodland Local Wildlife Site. This should be acknowledged in the policy and a requirement to protect and enhance the LWS should be included.

QUESTION 76: Do you agree with the requirements of Policy IDE1? If not, how would you wish to see it amended?

We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species. Opportunities to incorporate biodiversity gains throughout the development should be taken.

QUESTION 79: Do you agree with the requirements of Policy NOR1? If not, how would you wish to see it amended?

Enhancements to the existing tree belts should be sought for the benefit of biodiversity.

QUESTION 82: Do you agree with the requirements of Policy PEA1? If not, how would you wish to see it amended?

The Trust strongly supports the protection of the traditional orchard and the aims to bring it into long-term sustainable management. This is a priority habitat and as such its protection and enhancement is fundamental to the council's aims in the Core Strategy. We strongly support requirement (v) and recommend that there is a requirement for a long-term ecological monitoring and management plan for the site.

Requirement (vi) should include 'enhancement' as well as retention to ensure net gains to biodiversity. We also recommend that the requirement for a SuDS scheme is included in the policy.

QUESTION 83: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

The Trust strongly supports the exclusion of the traditional orchard from the development boundary. This will help to protect the site in the long term.

QUESTION 84: Do you agree with the preferred site for development at Rye Harbour? If not, which site should be preferred?

The Trust strongly supports the exclusion of sites designated as SSSI. These would clearly not be suitable for development and their allocation would be contrary to the Core Strategy and NPPF.

QUESTION 85: Do you agree with the requirements of Policy RHA1? If not, how would you wish to see it amended?

The site is also adjacent to the SPA and this should be acknowledged in the policy. We recommend that requirement (iv) is extended as follows:
'...development of RH10 does not adversely impact upon the Rye Harbour SSSI and avoids impacts on the SPA'.

QUESTION 86: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

It appears a typo is included in paragraph 15.98. The reference to Donsmead, Station Road should be removed.

We support the proposed development boundary as it should prevent further development encroaching onto sites designated for their biodiversity value.

QUESTION 87: Do you agree with Policy RHA2 regarding the Harbour Road Industrial Estate and the proposed boundary changes? If not, how would you wish to see it amended?

Given the ecological sensitivity of the land surrounding this allocation, we recommend that requirement (iii) is strengthened as follows:
'...a comprehensive landscaping strategy and an ecological monitoring and mitigation plan to improve the overall appearance and the biodiversity value of development.'

QUESTION 88: Do you agree with the preferred sites for development at Westfield? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 89: Do you agree with the requirements of Policy WES1? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. Further to this, as identified in the 'Key constraints/opportunities' section, the previous ecological appraisals suggested biodiversity gains. The Trust strongly supports the inclusion of wording to support biodiversity gains but seeks that these are not limited to bird and bat boxes. Instead biodiversity gains should be implemented depending on the findings of the up to date ecological surveys submitted at the time of the application. We remind the council that if they are minded to suggest bird and bat boxes as part of the gains for this site in future, wording should be included to highlight the need to incorporate natural features supporting these artificial homes.

QUESTION 90: Do you agree with the requirements of Policy WES2? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. The aerial photograph shows the degraded formal gardens and it would be interesting to see if this allocation could consider how these former gardens might be integrated into the layout of the development site, as it may enable the retention of features of interest.

QUESTION 91: Do you agree with the requirements of Policy WES3? If not, how would you wish to see it amended?

The southern section of the allocations lies within the Hasting Fringes Biodiversity Opportunity Area (BOA). We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species.

Opportunities to incorporate biodiversity gains throughout the development as per the ecological surveys and aspirations of the BOA should be taken.

QUESTION 92: Do you agree with the requirements of Policy WES4? If not, how would you wish to see it amended?

We note this allocation falls outside the 2006 development boundary. However, we are supportive of measures taken to encourage modes of sustain able transport and to interlink those benefits with biodiversity gains. The text accompanying the allocated site states that there are locally present protected species. Therefore we recommend that (iii) reads:
'ecological improvements are based on up to date ecological surveys and are implemented in accordance with these findings and those of the Hasting Fringes Biodiversity Opportunity Area and Rother Green infrastructure Strategy'.

Question 93 - 103

We support the retention of gaps between settlements. While these gaps are often retained for reasons of coalescence and visual sensitivities, we highlight that the Sussex Wildlife Trust also sees the need to recognise the importance of these green gaps in delivering ecosystem services to the local communities (NPPF section 109).

QUESTION 105: Do you agree with the requirements of Policy GYP1, including the boundary as defined on the Policies Map? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per are general comments at the start of this section.

QUESTION 109: Do you agree with the requirements of Policy (MAR1)? If not, how would you wish to see it amended?

We support the requirement for an ecological survey. We recommend that criterion (i) includes 'for the benefit of biodiversity' and the criterion (iv) requires the use of SuDS.

QUESTION 110: Do you agree with a policy to support the continued allocation for the re-instatement of the railway link from Robertsbridge to Bodiam along its original route?

The Sussex Wildlife Trust support sustainable modes of transport. However, we do not have enough information about this particular scheme to offer an opinion on this policy. It is unclear whether the application has been progressed with the consideration of the existing landowners and the level to which biodiversity interests have been considered.

QUESTION 111: Do you have any comments on this scope or content of the new Local Plan that are not covered by other questions?

We highlight the need for a specific Ancient Woodland Policy as per section 117 of the NPPF.
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

We welcome the inclusion of the green infrastructure study as an evidence base for the local plan. We would like to know if this will progress into a clear strategy identifying delivery mechanisms. We suggest that the local plan may benefit from a specific policy on green infrastructure/ecological networks to ensure consistent integration of this infrastructure within development.

Should you have any further questions regarding our consultation response please feel free to contact me.

Yours sincerely,
Laura Brook
Conservation Officer

Designated sites - Combe Haven SSSI; within 'Impact Risk Zone' (IRZ) for the
SSSI.

If the allocation is likely to have a significant effect on the SSSI, appropriate mitigation measures need to be specified.

One example would be hydrological impact; such as increased water levels entering the SSSI and from SuDS/ground water/surface water run-off and pollutants entering the ditch network feeding the SSSI, with potential to harm the botanical,
invertebrate and bird interest of the SSSI.