My wife and I are in the process of moving to Ashley, which is opposite Spindlewood Drive, Little Common. We wish to object to the development of Site BX116 under Policy BEX9.

As newcomers to the area, it is difficult for us to comment on the wider issues of alternative sites and interaction between sites and policies.

We have seen the responses of SPINDAG, which appear completely reasonable in that regard.

What seems clear to us from our frequent visits to Ashley over the last year is that Meads Road and Maple Walk are wholly unsuitable for either construction traffic or the future light vehicles from the residents and servicing of the proposed housing. This applies both to the roads themselves and to the flows at junctions and the on-street parking issues identified by SPINDAG.

From a purely selfish viewpoint, it would obviously be better if the development was served, both under construction and in occupation, directly from the A259. However:


- even on our visits we have experienced the congestion on the A259 road through Little Common and the consequent diversion of traffic onto very minor roads to the north and south of A259.

- Such access would not address the wider issues of inadequate infrastructure, unacceptable environmental impacts and more suitable alternative sites which are raised by SPINDAG and which, although outside our direct knowledge, appear eminently reasonable.

We are opposed to the proposed development of BX116 of Policy BEX9 in its entirety.

We consider this development to be undesirable

1. Due to traffic problems - we moved to our property in April 2014, one of the deciding factors to purchase in this location was the ease of commuting to Hailsham for D Poynter. Since April 2014 the amount of traffic on this route, especially around the Little Common roundabout has increased substantially. The journey originally took 15 to 20 minutes it is now taking at least double this.

We are aware of the development at Barnhorn Green and consider this will already make the traffic position even worse. We feel that the development at the rear of Spindlewood Road should not be further considered until the impact of the additional traffic has been established.

The entry to the site via Spindlewood Road will mean a substantial increase in traffic along Meads Road and Maple Walk. Meads Road itself has a lot of cars parked along it during the day and most of the time it is single file. The exit onto Cooden Sea Road is often difficult due to the cars parked around the junction, we
understand the old Co-op is due to be developed and this will once again make this junction worse.

We already have a problem with the volume and speed of the traffic that uses Maple Walk which outside our property is narrow and further along even narrower after a bend. J Pullen walks along this road most days and is surprised that there has not already been a serious accident, additional volume of traffic using this road we consider will lead to a serious accident.

2. Water table - our property is a split level bungalow, since moving here we established there was a hole underneath the front of our property that had been dug by the builders but not used. When we found the hole it was continually filling with water to a level and then finding a route out. We have taken the steps of having this tanked with a pump in the floor so we can make use of the area, however it demonstrates that there is a water problem in the area.

The area that is due to be developed at the rear of us is very wet and we consider due consideration has not been taken of the impact of the water on the properties that are in Maple Walk and Spindlewood Road or of the new properties themselves.

3. Currently the infrastructure of Little Common / Cooden is just coping with the number of residents, within this we include the primary school and the doctors practise. However, we are unable to see how the infrastructure will be able to cope with the additional residents that 160 more properties will accommodate in addition to the properties already due to be constructed at Barnhorn Green.

We consider that the proposed development is therefore totally unsuitable for the area due to the above considerations and the detrimental impact it will have on the local community.

I am opposed to this development and feel it should not be considered for residential building.

The scheme is ill-considered, is out of character with the surrounding area, is much too high a density and, in particular, the proposed vehicular access shows a total lack of awareness (or total disregard) of local road conditions.

Housing Density Issues

Spindlewood Drive is a quiet, mature cul-de-sac, serving in all about 45 houses. The proposed development suggests that 160 more houses can be inserted into a similar-sized area. If anything, the housing density on Spindlewood Drive is already slightly greater than the mature surrounding roads of Meads Road, Maple Walk and properties on the south side of Barnhorn Road. The construction of 160 more properties in this small area would be completely out of character with the surrounding , established housing.

RDC makes reference in various places on the DaSA document to balancing the density of new developments with existing developments - "modest net density", "bringing the countryside into Sidley" and so on - yet this proposed new estate is wholly out of balance with the area into which it would be forced.

RDC also refers to sharing the benefits of new developments between existing residents and new. There are no benefits whatsoever for existing residents from this proposed plan. This is inconsistent with RDC's declared aim of shared benefits.

It all suggests a determination on the part of the developer to maximise his profit from the site with no regard for the damage done to the surrounding area, since he does not have to live here. It also suggests a determination on the part of RDC to cram as many properties as possible into any site in order to meet central government targets for housing development without consideration for local people. RDC is a LOCAL council, its first regard should be for LOCAL interests and not to support commercial exploitation at the expenses of its residents.

Local Roads

Whilst the current demographics of the Little Common area are tilted somewhat towards the older generation (!) one might expect the new residents of developments such as Barnhorn Green (and BX116 were it to go ahead) to be of a more mixed age range. Many of these households, then, will contain both working age adults and children. It is unlikely that adults from 160 households will find employment within easy walking distance of their homes and one can be certain that children would only be taken to school by car (none of them walk these days!). So it is certain that a great number of vehicle movements will take place each day from this new estate.

As mentioned above Spindlewood Drive has 45 or so properties. The entry to Spindlewood Drive is a narrow downhill slope with a blind bend at the bottom, going on into the small estate. The entry stretch is used at all times of day and night as a car and van park by residents and visitors to properties on Meads Road. This effectively reduces the entry to Spindlewood Drive to a single lane road. Traffic entering must use the right hand side of the road and often finds itself head-on to traffic coming around the blind bend leaving Spindlewood Drive. This is already a dangerous and congested spot. The idea of adding the traffic generated by 160 more houses and having it all enter and leave via the existing access (bounded tightly on both side of the junction by existing properties) is utter madness. There is no way that spin can cope with a quadrupling of the traffic using it.

Furthermore, Meads Road is also a narrow and highly congested road. It has relatively narrow footpaths and also sees almost permanent car parking along much of its length, even on the double yellow line sections (RDC does not believe in any forms of parking control, anywhere in Bexhill). There is nowhere else along Meads Road for its residents and visitors to park. This also means that opposing traffic has to negotiate passing by dodging in and out of spaces along the road, or a stand-off when opposing vehicles both head for the same open stretch. The concrete slab construction of Meads Road is also a limiting factor to this road carrying a huge increase in traffic. This would rapidly become evident once construction traffic started using it: heavy lorries, JCBs, earth-moving equipment, contractors' vans, deliveries, utilities lorries and so on. The road would disintegrate under this loading before any of the residents of 160 more properties started using it. Utter senselessness even to consider it.

What's worse, though, is that the junction where Meads Road meets Cooden Sea Road is also a hazardous bottle neck. There is very limited visibility of traffic on Cooden Sea Road for traffic leaving Meads Road, due to illegally-parked vehicles which are always present on the pavements around this junction, HGVs delivering to Tesco and also due to the narrowness of the junction. It is also now planned that the former Co-op shop on this corner is turned into a development of shops and flats which will only add, permanently, to the parking of vehicles on this corner, from delivery vehicles, residents and shoppers. (Very few motorists can be bothered to use the Pay & Display car park in Little Common, they prefer to park illegally with total immunity on the pavements, on yellow lines, wherever).

Meads Road is also the access road onto Maple Walk, an even narrower, unadopted, road which truly is single lane for some of its length. Residents of Maple Walk are responsible for its maintenance and upkeep. Given the loading on Meads Road would hugely increase after BX116 it is certain that Maple Walk will be used as a rat-run by vehicles seeking to avoid the congestion of Meads Road. This is totally impractical and would make life intolerable for Maple Walk residents. Such rat-run traffic would also end up using Maple Avenue and Clavering Walk, thus further enlarging the area impacted by the BX116 plan.

The proposed developers of BX116 (Bedford Park?) have submitted a Transport Note which supposedly addresses concerns about traffic generation from this development. In fact it does not address local road and access issues at all. It makes an utterly incredible argument that traffic levels at the Little Common roundabout will be barely effected by BX116. Whilst that itself might be open to debate it does not in any way convincingly show that Meads Road, Maple Walk and Spindlewood Drive can cope with the huge increase in traffic that BX116 would create. RDC should demand that a rigorous study is made of the alternatives to access via these narrow local roads.

There is a current planning application under consideration for 31 new houses on the A259 near the Ashridge Court old folks home west of Little Common. Their traffic study predicts certain levels of vehicle movements arising from their 31 properties. If one uses their assumptions for 31 houses and considers what that might mean for Spindlewood Drive & Meads Road, extrapolating it to 160 houses, it suggest something like 800 or 900 more vehicles per day on that narrow little entrance to Spindlewood Drive, entering from Meads Road. I think this is far in excess of what Bedford Park would admit to. RDC needs to look very closely at the developer's attempt to dodge this issue.

Although I oppose this development and hope that it never comes to pass, I also have to wonder where the developer expects all of the contractors' vehicles associated with this development to park during the construction phase. Local residents and through traffic were greatly inconvenienced during the construction of a few McCartney & Stone retirements flats on Little Common Road over 2015/2016, a development much smaller than proposed here. This saw uncontrolled parking of cars and vans along the A259 causing extra delays to all traffic. The scale of parking, deliveries and construction traffic from BX116 would be unimaginable and would overwhelm local roads (and residents).

I see that in RDC's own Adopted Core Strategy document it states in relation to development west of Little Common "Access would need to be created directly off the A259, supplemented by existing estate roads. Whydown Road and Sandhurst Lane are unsuitable access roads." Meads Road, Spindlewood drive and Maple Walk are no more suitable for serving new housing estates than Whydown and Sandhurst Lane. Why the inconsistency?

If a development such as BX116 were to go ahead it should have all vehicular access, during construction and for future residents via direct entry to Barnhorn Road only, with pedestrian and cycle access only from Spindlewood drive.


Local Environmental Issues

Although, regrettably, the BX116 site is not itself subject to special protection measures it does represent a valuable green space and its habitat is worthy of protection and preservation. Furthermore, it does lie adjacent to sites which do have very special characteristics and are designated as such (Ramsar and SSSI classification). Whatever assurances the developers might offer with regard to the scrupulous care and tenderness with which they will approach the development (and how could they say otherwise?) it is hard to believe that the construction work itself and then the permanent presence of a new housing estate will not have lasting detrimental effects on the site itself and the precious surrounding land. Issues of wildlife disturbance, drainage and flood risks are all brushed aside in the developer's Ecological Assessment, assuring us that not a blade of grass will be disturbed, one cannot see how the local environment is in any way enhanced by the presence of 160 new houses.

It is of concern to note that certain sections of the Ecological Assessment have been blacked-out so that they cannot be read. Is the developer hiding something from the public and from RDC? Why can we not see the unedited version of this document? Even then we have to wonder why we should take this and the so-called Transport Note at face value - they are produced by the developer in pursuit of his own financial gain. They cannot be considered to be impartial and truly independent studies.

Reference is made above to traffic levels and in the context of environmental issues we should not discount air pollution increases that any new developments in the area will cause. We know there has been no recent and continuous air pollution monitoring in the Little Common area, although we learn from Mr G Minns at RDC that, belatedly, some is to be set up somewhere nearby. With no awareness of even current air pollution levels how can RDC even suppose that Barnhorn Green and, if it happened, BX116 would not cause local air pollution levels to reach harmful and illegal levels.


Urban Creep
RDC recognises the risk of "urban creep" in the DaSA documents. It is noted that the DaSA plan specifically identifies further sites to the south of Barnhorn Road: BX51, BX109, BX115 & BX61. No plans are outlined for their development, indeed some of the characteristics which are said to make them unsuitable for development can be justifiably applied to BX116. Nonetheless, the mere fact that they are so identified makes them targets for future developers to try their luck with RDC planners. It is all too easy to see greedy landowners and developers seeing ££££ signs if BX116 were to be allowed, then why not infill that whole area? Surely more money can be made by selling land for housing than running a small caravan site. One worries that BX116 might be the thin end of a very wide housing wedge.


Little Common & A259 Traffic Issues

Now, we come to that old chestnut: traffic levels on Little Common roundabout and the A259. Where should we start? RDC, East Sussex County Council and Highways England all seem to think of the A259 as a lightly used local road, able to cope with just a little more traffic with no ill effects. This couldn't be further from the truth. It is the only major road along the whole of the East Sussex and south Kent coastline. It carries huge amounts of through traffic, all squeezing through Little Common, halting at the whim of the school lollipop lady and the pedestrian crossing nearby. Traffic already often comes to a complete standstill along here, not only at rush hours. This will be made worse still when a new set of traffic lights is installed along Barnhorn Road to serve the Barnhorn Green development and a pedestrian crossing is installed near Kites Nest Walk. Each of these new features will cause traffic delays and tail-backs and cause even more pollution.

We are told that Highways England data shows that the A259 is already approaching traffic volumes which were not due to be reached until 2028! The local road infrastructure is already overloaded before any development such as BX116 and many others in the DaSA plan might be implemented.

Urgent measures should be taken to link the North Bexhill Access Road (NBAR) with the A259 well to the west of Little Common in a bypass. Only then should RDC come back to its DaSA, when funds for such a bypass have been found from central government, the ones setting the targets for new housing. These essential infrastructure improvements should be a precursor to residential development. Furthermore, if RDC hopes to attract new employers into the area, so that there are people to buy these new houses, it is vital that such employers are offered suitable infrastructure first.

Additional supporting information was supplied which can be viewed here:

http://www.rother.gov.uk/CHttpHandler.ashx?id=28031

I am opposed to the development of Spindlewood Drive (BEX9) in its entirety.

It is not only superfluous given the availability of more suitable sites, it is, more importantly, in practical terms it is totally inaccessible. The site is entirely surrounded by housing on all sides with the exception of a small agricultural gateway leading into Spindlewood Drive. The site plan suggests that 160 houses are to be built here - this means, at the very minimum, an additional 300 cars using this entrance.

Access to Spindlewood Drive is at the bottom of a hill on a blind bend. It is already hazardous enough, with vehicles parked in the road. Additional traffic will make it even more so. From there access is into Meads Road with restricted visibility.

Meads Road is a small narrow road with resident and commuter parking on both sides reducing it to a single carriageway for most of its length. The road itself, of concrete slab construction is breaking up and in places almost collapsed - clearly unsuited to additional traffic. Meads Road exits into Cooden Sea Road. Again a junction with restricted views in both directions and this will become ever more hazardous with the development of the old Co-op site on the southern corner. This junction will become jammed with tail backs to the Cooden roundabout and impacting on the already overcrowded A259. The suggestion of using this exit way is clearly impractical and will be a danger to both traffic and more importantly to pedestrians.

The only other way of accessing the Spindlewood site would be to demolish houses and access onto the A259. Clearly this would be almost as idiotic.

On a wider aspect the infrastructure of Little Common could not cope with this increase of housing given that Barnhorn Green is already going ahead. There are clearly more suitable areas for these houses than trying to squeeze them on an unsuitable piece of land just because it looks good on paper.

For these reasons and countless others I think that this site should be removed from the development plans.

1. The proposed access to the new development, off Spindlewood Drive, would be unsafe. Currently that access point is opposite a bend in the road and, as vehicles are often parked just beyond it, at the entrance to Spindlewood Drive, it is difficult to see past them when entering Spindlewood Drive. Some people don't take this into account and don't reduce their speed accordingly resulting in some near misses.

2. Meads Road has become increasingly busy and is virtually a one lane road since the parking charges were introduced in the Little Common Car Park. If this development went ahead it would result in a huge extra amount of traffic each day, a large amount of which would be large vehicles e. g. bin lorries, delivery vans, other tradesmen etc. This could result in many people deciding to use Maple Walk and Maple Avenue to access Cooden Sea Road and neither of these roads are suitable for extra traffic.

3. Having managed to negotiate one's way along Meads Road the next problem would be exiting onto Cooden Sea Road. Since Tesco Express was built it has made this more difficult especially as people often park on the double yellow lines at the end of Meads Road and also in the layby outside the old Co-op and it is almost impossible to see traffic coming from the right.

4. All this extra traffic would also surely be detrimental in terms of pollution levels and would result in more visits to the local doctors' surgery which would probably be struggling to cope anyway, especially after Barnhorn Green is built!

5. Finally, I don't think enough thought has been given to the whole traffic problem around Little Common. I believe that a thorough survey should be done , at all times of day but especially at peak periods, to monitor the numbers of traffic and the length of queues and the time it takes to get through Little Common.

1. Spindlewood Drive is a totally inappropriate site for 160 new homes. Access via Meads Road, Maple Walk and Spindlewood Drive would be entirely inadequate and unsuitable for an increased volume of traffic (approx. 300 additional cars from an estate of 160 homes being driven on narrow residential roads with a considerable amount of vehicles regularly parked on them. Access to Meads Road from Cooden Sea Road is also dangerous not only due to the narrow width of Meads Road at the junction with Cooden Sea Road but also poor visibility for drivers exiting from Meads Road. Peak traffic congestion would result in vehicles from a development off Spindlewood Drive backing up Meads Road and probably diverting down Maple Walk which is an unadopted road and maintained by its residents.

2. The A259 and Little Common roundabout are near full capacity and confirmed by Highways England as being close to the maximum capacity levels forecast for 2028. Traffic flow at peak times is 900 vehicles per hour in each direction. Further development at Little Common would have an immensely adverse impact on the problem regardless of the developer's incredible assurances that there would be a "minimal increase" in traffic.

3. To the south of the proposed site there is an area of Special Scientific Interest and a RAMSAR site. Conservation sites would be compromised as a result of further development.

4. Environmentally there would be an increased risk of flooding which is already an issue in this area. Extensive building and concreting over a Greenfield site would increase the risk of flooding and endanger wildlife and the environment.

5. Local infrastructure in Little Common is near to capacity in terms of the GP surgery and the primary school is full. Car parking is a big problem as is illegal on pavement parking. Further vehicles would only exacerbate these problems.

6. Air pollution on the A259 is already high and would be increased as a result of the BX116 development. I understand that monitoring devices are to be installed on Barnhorn Road which will provide up to date information.

7. Given that there is already a considerable amount of development in place or planned for Little Common as well as the Barnhorn Green project, which is proceeding, there is no need for a further 160 homes to be built off Spindlewood Drive. Projected figures for new homes taken from RDC published material (including windfalls) indicate that the RDC target of 3100 homes to be built by 2028 will be accomplished without the need to develop off Spindlewood Drive at all.


8. If, in spite of this, RDC still considers more homes should be built, I strongly suggest further development of BX124 by way of option 3 makes far more sense. This is a new site so obviously development there would not adversely affect any existing residents. Access via NBAR will be good and should also ease congestion on the A259

RE: BX116-LAND OFF SPINDLEWOOD DRIVE, BEXHILL - DEVELOPMENT AND SITE ALLOCATIONS PLAN

In response to the current consultation on the Rother Development and Site Allocations Plan (DaSA), please find below representations on behalf of the landowners of land off Spindlewood Drive, Bexhill, Rother District Council reference BX116.

We wish to commend the Council for the pro-active, collaborative and extensive amount of work which has been taken by Officers in respect of drafting this document and in particular the draft allocation put forward at the 'Land off Spindewood Drive'. A significant amount of survey work has been requested and reviewed by the Council, above and beyond the level of work often carried out in respect of site allocations documents.

Through the extensive pre-application discussions, advice and representations to the adopted Core Strategy Document, SHLAA and now the Development and Site Allocations Document it has been established that the proposals benefit from:

* An agreed access point into the site and all highways matters agreed with Highways England and East Sussex County Council;
* Natural screening provided by established boundary planting which will be maintained and enhanced by the scheme, ensuring that all views of the site and neighbouring amenity are maintained and protected, resulting in an attractive and aesthetically pleasing development;
* Nature enhancements including tree retention, additional planting and green areas which will improve upon the biodiversity and sustainability of the site;
* Situated wholly within flood zone 1 which provides the lowest risk from flooding;
* A natural extension to the established residential area of Little Common;
* Extremely well linked to Little Common and the wider Bexhill area, with a number of public transport options available to residents including Cooden Beach train station which is a short walk from the site;
* All matters identified for consideration at the site, during pre-application discussions and the previous Rother SHLAA assessment (access and retention of tourist facility) fully resolved and agreed with Officers; and,
* No outstanding matters which will prevent the submission of a planning application and delivery of development at the site within the next 12 months.

In addition to the consultation through the emerging Rother Local Plan, Highways England and East Sussex County Council have been consulted, along with the Local Resident's interest group and Ward Councillor. We have sought and we will continue to incorporate comments where feasible, in order to ensure that the best possible scheme can be achieved in this location.

Rather than leave detailed survey work to the planning application stage, the three pertinent areas to development coming forward at this site, namely transport, ecology and indicative layout have been fully addressed and agreed, and indeed detailed transport and ecology reports have been published alongside the DaSA in respect of this site.

This approach ensures that any uncertainty over the minimum number of units that can be delivered has been fully addressed and that there are no outstanding issues that would delay the site coming forward in the short term. It should be noted that the amount of survey work undertaken and published alongside the DaSA consultation for land off Spindlewood Drive exceeds the information published for the other sites in Bexhill, demonstrating the suitability of the site and the commitment to deliver much needed local housing in the near future.

The completed ecological survey work identified that the site is of low ecological value and is developable for residential development as set out on the indicative masterplan for the site. All recommended phase 2 work has been undertaken, this has all been acceptable and confirms the conclusion that the site is developable. All recommendations have been taken on board and have shaped the proposals. On this basis, the proposals are entirely acceptable and indeed beneficial, from an ecological and nature perspective.

The transport work undertaken has been fully signed off by Highways England and East Sussex County Council, demonstrating that the scheme, proposed access solution and local highways network are entirely suitable for accommodating the development.

This front-loaded approach to survey work, will enable a future planning application to run smoothly.

In conclusion, there is certainty that this site has no outstanding issues and sustainable and beneficial residential development can be delivered in the short term. Therefore, we fully concur with the draft allocation for some 160 dwellings and Policy BEX9, for this site as set out in DaSA document.

The allocation of this site as well as other suitable opportunities, will not only assist in meeting housing targets, but will enable Rother District Council to ensure that much needed housing comes forward in sustainable locations; enabling the Council to resist potentially unsuitable sites being pushed forward which could create unsustainable patterns of development to the detriment of local communities.

I am completely opposed to the proposed development BX116 of Policy BEX9

I would like this option to be removed from the list of Preferred Sites and not be considered for any future development as part of the second DaSA consultation process.

* I believe it to be unnecessary: in the light of the capacity of other proposed sites to provide adequate development potential (for employment as well as residential properties) it may even cause Bexhill to even exceed, its development targets without this development, therefore deeming it unnecessary in its entirety. Especially if windfalls are taken into account by RDC.

* I believe it to be totally impractical, likely to have a significant detrimental impact on Little Common along with further burdens on already limited local infrastructure. I am extremely concerned on the negative impact such a development will have on this area.

* Such a large and very dense development in the midst of a beautiful and quiet environment will be highly detrimental to the entire area and to the local residents.

* Wildlife impact

Why do I find this development adverse?

Local traffic problems

This is a high-density development being squeezed into a very small and environmentally-sensitive area with constricted access and in one direction served by an un-adopted road, that being Maple Walk.

Vehicle access to the site will be via Meads Road and Spindlewood Drive. Meads Road is already used as an all-day car park by people that commute to work in the local businesses along with residents, visitors and tradesmen and is effectively a single lane road. Passing traffic has to negotiate a right of way with opposing vehicles. The condition of the road surface in Meads Road is very poor and does not seem to be a priority for repair, or even routine maintenance, by the local authorities. The concrete surface is breaking up under the current heavy usage let alone a continuous use by earth moving vehicles etc.

At present the small Spindlewood Drive estate serves about forty five properties. The initial length of Spindlewood Drive is also used as a car/van park by Meads Road residents and visitors, since Meads Road parking is usually at its capacity. These parked vehicles have nowhere else to go in the whole area. Vehicles entering Spindlewood Drive via Maple Walk west are thus made to approach a blind bend into Spindlewood Drive forcing vehicles to the right hand side of the road, risking running into vehicles leaving the estate.

I am concerned that vehicles will not always turn left out of Spindlewood Drive but due to heavy parking will prefer to turn right onto Maple Walk, which as previously mentioned is an un-adopted road maintained by 'The Maple Walk North Residents Association'. Residents have to contribute an annual payment in order to keep on top of any future road maintenance, resurfacing along with Public Liability Assurance'. I am concerned that with heavier usage the current road surface will not be able to withstand this. The road surface is currently a thin layer of tar and shingle and is not intended for excessive use or to bare heavy loads. At present the road is resurfaced approximately every 5 years, therefore, additional traffic would undoubtedly incur costs to the residents of Maple Walk.

Maple Walk North is a single lane right of way with many of the driveways along Maple Walk being concealed driveways and unfortunately Maple Walk North and south is already used as a cut through to Spindlewood Drive and with the additional traffic if BX116 goes ahead this once peaceful road will become dangerous for pedestrians and local residents exiting their driveways.

Increasing the traffic flows into and out of Spindlewood Drive which is currently forty five properties to in excess of two hundred is absolute madness, especially considering that this traffic is not only private cars but delivery vans, utilities vehicles, emergency services, heavy goods vehicles and others. Which undoubtedly have a negative impact on Maple Walk.

I understand that the former Co-op building at the end of Meads Road could be developed for shopping and residential properties, significantly increasing vehicle density and traffic flows into and out of the east end of Meads Road. This will undoubtedly see delivery vehicles parking at the very entrance to Meads Road, as well as shoppers who will not use the (Pay & Display) car park behind Tesco but prefer to park on double-yellow lines. The junction of Meads Road and Cooden Sea Road will become itself a log-jam even before the Little Common roundabout and A259 come under consideration. This junction is already dangerous, vision towards the south for traffic emerging from Meads Road is severely restricted by vehicles parked outside the former Co-op building, and restricted to the north by vehicles illegally (but with impunity) parked on the pavement to the north. This area currently is an accident waiting to happen let alone with the possibility of an additional 200 cars using this junction along with delivery lorries, refuge collection etc.

Meads Road and Spindlewood Drive are absolutely unsuitable to the level of traffic such a development would generate.

It has been calculated that the traffic flows from this development will be 90 - 1—per hour for the peak periods with a total increase in traffic movement of some 50 vehicles per day. This will result in serious traffic congestion at the end of Meads Road with associated high levels of noise and air pollution. Along with the loss of 'Dark Night Sky', night sky pollution, which I understand to be on a political agenda national at present.

There is a real risk, therefore, that some traffic for the BX116 housing estate will use Maple Walk as a rat-run!

Despite our outright objection to this development it is also worthy of note that the would-be developer, Mr Ellis, stated to SPINDAG representatives in a meeting on 2nd December 2016 that if the development were to go ahead all construction traffic would access the site via an entrance on the A259. If that were to be possible for an extended period for heavy goods vehicles, cranes, diggers and other traffic, why could it not form the permanent access? We have seen no credible Transport Management Plan from the developer which addresses the serious impact any means of development of BX116 would have on the surrounding area, whatever the access. RDC must insist therefore on a Transport Management Plan irrespective of the access point.


Environmental Concerns - Wildlife negative impact

Although the would-be developer has provided an Ecological Appraisal for BX116 many issues remain to be carefully considered and studied further. There are valid questions to be raised about the ease with which their suggested mitigations can be implemented and their likely effectiveness. This site lies adjacent to areas which are designated SSSI and/or Ramsar sites, deserving of especially rigorous protection. These observations and re-assurances do not seem to have been studied and approved by the relevant utilities, environmental protection and wildlife authorities. The study was commissioned by and paid for by the developer with a commercial interest in this site, hardly an uninterested party. Not least are the issues surrounds drainage and flooding risks, SUDS designs and expectations. Nor is it clear who would be held responsible for any future flooding or environmental damage and how they might be sanctioned in the event of any failure of these measures.

The fields are I believe a wet site habitat. This whole area provides for a huge range of different wildlife species including great crested newts, birds, bats and owls. Some of these are on the protected list and of great concern. These will be greatly disturbed or even destroyed should this development go ahead.

The properties to the SE of the proposed development (Maple Walk North) are a natural soakaway for the adjacent field with an open sewer running through the gardens. At no point has anyone inspected or surveyed these gardens/properties to ascertain the capacity of this natural soakaway as to whether it would be able to cope with additional drainage issues from this proposed development. I believe this to be a major issue as our gardens are often water logged if there is excessive rainfall.

I can foresee a serious risk of permanent environmental damage and wildlife disturbance not only on this site but the surrounding sensitive areas. These could never be corrected once their gone they will be gone forever. It is especially concerning that certain sections of the Ecological Appraisal have been redacted - why? By whom? With what objective in mind? This should be investigated and the public made aware of the reasons for this.

The site BX116 has been refused planning permission in the past and I can only comment that nothing has changed since then so why is it thought planning can go ahead now?

Wider local impact:

The road system, local services and infrastructure around Little Common are already due to be overloaded without the added burden which BEX9/BX116 would bring. The doctors' surgery is always packed (the new one proposed for Barnhorn Green having been abandoned), the school is over-subscribed and there are no secondary schools nearby.

The A259 is wholly unsuitable for the traffic levels passing through Little Common and Bexhill overall. Much of it is through traffic which must use the A259 as the only major east-west route along England's south coast. If anything, the new Bexhill-Hastings Link Road has added to traffic pouring through Little Common as it provides an improved route for traffic aiming to bypass St. Leonards and Hastings (partially). The much talked about Bexhill bypass comes to mind in this context - linking the NBAR to the A259 west of Bexhill would alleviate some of this traffic, not to mention bringing a huge area for further housing and business development into play.

There are few local, (in Little Common), employment opportunities for the envisaged residents of Barnhorn Green, not to mention BX116, so it can be certainly assumed that these working residents will use their cars to commute to/from work and to transport their children to the already oversubscribed Little Common school or elsewhere. Surveys have shown that the A259 is already carrying the forecast for 2028 traffic levels.

The lack of any current knowledge of existing air pollution levels is disturbing, given that RDC has already approved substantial new development projects in the area and is anticipating even more - without apparent regard for this serious, health-related issue, and doubly serious considering the increased proportion of children these proposed developments might bring to the area. It is already planned that traffic lights be installed on the A259 for an entrance serving Barnhorn Green which will create yet more standing traffic along that busy road.

The northern end of Cooden Sea Road is currently full of illegal car parking, with not a traffic warden insight, while the Pay & Display car park behind St Martha's church stands mostly empty, and this is before Barnhorn Green it built. Even more housing development in this already congested area will make life very problematic for residents, both current and future. I can only foresee an increase in accidents both pedestrian and vehicles thus putting additional stresses on an already overstrained infrastructure.

I am concerned about the longer-term risk of "development creep". BX116 lies adjacent to other sites which were considered for development (BX51, BX109, BX115 & BX61). These have been ruled unsuitable, often due to recognised flood risk (uncontrolled drainage from BX116?) If BX115 and BX108 are precious and worthy of protection to preserve the area's "character", then so too should be BX116. We should be protecting our green belt areas not destroying them.

When will it end? We will be a suburb of Eastbourne to the West and Hastings to the East if these housing developments continue.

Density of proposed development

The housing estate proposed is far too high a density for the area surrounding it. This area of Little Common consists predominantly of mature detached houses. It has already been noted that the Spindlewood Drive estate has only about forty five houses. It is proposed to pack 160 into an area not much larger than that original development (allowing for trees, play areas, ponds, etc.). This near-quadrupling of housing density is entirely out of keeping with the local area. Parking multiple vehicles per household, probably spilling out onto the surrounding roads causing even more congestion.

Site at Spindlewood Drive (BX116/BEX9) is inappropriate for development because of:-

1) Poor access through small side roads (often used for parking by residents and for local businesses). This is likely to result in traffic congestion and maple walk becoming a rat run for traffic trying to get into and out of the proposed site. Maple walk is a private road with no footpath in places, increases traffic resulting in a clear risk to pedestrians and increased costs to local residents.

2) Inadequate local infrastructure to support such a large scale development (schools, GPs etc.).There are also questions about the local sewers and the structure of the main access road that need to be looked at.

3) Significant effects on local wildlife and possible adverse effect on adjacent important wildlife sites

Also the transport assessments of little common roundabout seem unrealistic. I am still waiting for a response from transport England about assumptions made in the SATURN modelling but the developer lead ARCADY assessment in the transport note is farcical (no HGVs, no pedestrian crossings - there are 2, road capacities set at 99999 vehicles per hour and a current queue of 12 on Barnhorn road at peak times (queue is often actually between 0.5 and 1 mile long)

I am wholeheartedly opposed to development on BX116 of policy BEX9.

I cannot believe that there has been any good research to support this development being appropriate.

There is a lack of suitable infrastructure for this.

The area around Little Common becomes very congested, especially at the roundabout and I have known there to be well over a mile of queueing traffic on several occasions coming from the Eastbourne direction.

This is unacceptable NOW let alone with the proposed extra housing development.

Meads Road access is a small road which ALWAYS has cars parked in it and it is uncommon to be able to drive on Meads Road and not have to wait, back up, give way to traffic in the other direction.

Then there is the Maple Walk direction ultimately leading to Herbrand Walk as an alternative 'rat run' towards Eastbourne. People will very likely try to use this as an alternative to congestion on A259 (a lot do already because of the serious delays the A259 has) and this alternative route is very narrow and unsuitable to take any volume of through traffic.

Maple Walk is a private/unadopted road - it is wholly unsuitable for traffic, and should be used for residents access only.

In Little Common there are limited facilities, it is meant to be a small village and does not have amenities suitable for extra people/housing/vehicles for this development.

What about Doctors/Schools? What there is here already would not take any more residents and put local amenities under extreme stress.

I am also opposed to the development on BX116 from the point of the environment (pollution would be increased enormously).

And from the point of the countryside and wildlife that inhabits that area now. We need more trees and areas of countryside available for the crested newts (endangered species) badgers (protected species) foxes etc which are being forced out of the countryside and into gardens, causing damage and problems for residents as well as the inevitable accidents caused by them crossing roads as they don't have sufficient land.

I would also like it noted that submitting comments and finding a way to do this has certainly not been made an easy task by the council. I was expecting to be able to go onto the website and find reference on how to submit this simply - that has certainly not been the case.


I am hoping for a confirmation that my comments and objections have been received

I understand that the DaSA Local Plan Policy 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 Common Village 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.

QUESTION 35: Do you agree with the requirements of Policy BEX9? 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. HOWEVER, I CONSIDER BEX9/BX116 UNSUITABLE PRIMARILY BECAUSE IT IS A HIGH-DENSITY DEVELOPMENT SQUEEZED INTO A SMALL AREA WITH EXTREMELY CONSTRICTED ACCESS.

A. VEHICULAR ACCESS TO THE SITE WILL BE VIA MEADS ROAD AND SPINDLEWOOD DRIVE. MEADS ROAD IS ALREADY USED AS AN ALL-DAY CAR PARK BY RESIDENTS, VISITORS AND TRADESMEN AND IS EFFECTIVELY A SINGLE LANE ROAD. THE ROAD SURFACE IS VERY POOR AND DOES NOT SEEM TO BE A PRIORITY FOR EITHER REPAIR OR MAINTENANCE - THE CONCRETE SURFACE IS BREAKING UP AND THERE ARE REPORTS OF MOVING SLABS AS HEAVY VEHICLES PASS.

B. AT PRESENT THE SPINDLEWOOD DRIVE ESTATE SERVES ABOUT FORTY FIVE PROPERTIES. THE INITIAL LENGTH OF SPINDLEWOOD DRIVE IS USED AS A CAR & VAN PARK BY MEADS ROAD/MAPLE WALK RESIDENTS AND VISITORS AS MEADS ROAD PARKING IS NORMALLY AT CAPACITY - SO THESE VEHICLES HAVE NOWHERE ELSE TO GO. VEHICLES ENTERING SPINDLEWOOD DRIVE VIA MAPLE WALK WEST/MEADS ROAD EAST MUST APPROACH A BLIND CORNER INTO SPINDLEWOOD DRIVE AND RISK COLLIDING WITH ANY LEAVING THE ESTATE.

C. IT IS PROPOSED THAT THE FORMER CO-OP BUILDING AT THE END OF MEADS ROAD BE DEVELOPED FOR SHOPPING AND RESIDENTIAL PROPERTIES, THUS INCREASING VEHICLE DENSITY AND TRAFFIC FLOWS AT THE MEADS ROAD/COODEN SEA ROAD JUNCTION. THIS WILL SEE DELIVERY VEHICLES PARKING AT THE ENTRANCE TO MEADS ROAD, AS WELL AS SHOPPERS WHO WILL NOT USE THE (PAY & DISPLAY) CAR PARK BEHIND ST MARTHA'S CHURCH BUT WHO PARK ON THE DOUBLE-YELLOW LINES INSTEAD. THE JUNCTION OF MEADS ROAD/COODEN SEA ROAD WILL BECOME A LOG-JAM AHEAD OF THE LITTLE COMMON ROUNDABOUT AND A259. THIS JUNCTION (MEADS RD/COODEN SEA RD) IS ALREADY DANGEROUS AS VISION TOWARDS THE SOUTH FOR TRAFFIC EMERGING FROM MEADS ROAD IS SEVERELY RESTRICTED BY VEHICLES PARKED OUTSIDE THE FORMER CO-OP BUILDING, AND RESTRICTED TO THE NORTH BY VEHICLES ILLEGALLY (BUT WITH IMPUNITY) PARKED ON THE PAVEMENT AND OUTSIDE TESCOS ON THE OPPOSITE SIDE OF THE ROAD. I FREQUENTLY VISITED THE TERMINUS RD POLICE STATION TO POINT OUT THE HAZARDS OF THE COODEN SEA RD/MEADS WALK JUNCTION, ASKING THEM TO TAKE ACTION, AND I EVEN HAD CORRESPONDENCE WITH THE COOP ABOUT IT THEIR DELIVERY TRUCKS, WHICH WERE OFTEN PARKED ON THE JUNCTION. NEITHER HAD ANY SUCCESS, SO WILL THE HIGHWAYS AGENCY BE MORE EFFECTIVE?

D. THERE IS A RISK THAT SOME TRAFFIC FOR THE BX116 HOUSING ESTATE WILL USE MAPLE WALK AS A RAT-RUN ALTERNATIVE TO MEADS ROAD. MAPLE WALK IS AN UNADOPTED ROAD, MUCH OF IT NARROW AND SINGLE LANE, LIKE MEADS ROAD. THE INCREASED TRAFFIC FLOW ALONG MAPLE WALK AND MAPLE AVENUE WOULD BE UNBEARABLE FOR THEIR RESIDENTS, NOT TO MENTION THE ADDED WEAR & TEAR ON ROADS WHICH THEY MUST MAINTAIN AT THEIR OWN EXPENSE.

E. THE ROAD SYSTEM, LOCAL SERVICES AND INFRASTRUCTURE AROUND LITTLE COMMON ARE ALREADY OVERLOADED WITHOUT THE ADDED BURDEN WHICH BEX9/BX116 WOULD BRING. THE DOCTORS' SURGERY IS ALWAYS PACKED, THE SCHOOL IS OVER-SUBSCRIBED AND THERE ARE NO SECONDARY SCHOOLS NEARBY.

F. IT IS CONSIDERED THAT THE A259 IS WHOLLY UNSUITABLE FOR THE TRAFFIC LEVELS PASSING THROUGH LITTLE COMMON AND BEXHILL OVERALL. MUCH OF IT IS THROUGH TRAFFIC WHICH MUST USE THE A259 AS THE ONLY MAJOR EAST-WEST ROUTE ALONG ENGLAND'S SOUTH COAST. THE NEW BEXHILL-HASTINGS LINK ROAD HAS ADDED TO TRAFFIC THROUGH LITTLE COMMON AS IT PROVIDES AN IMPROVED ROUTE FOR TRAFFIC AIMING TO BYPASS ST. LEONARDS AND HASTINGS. THE BEXHILL BYPASS, LINKING THE NBAR TO THE A259 WEST OF BEXHILL WOULD ALLEVIATE SOME OF THIS TRAFFIC, NOT TO MENTION BRINGING A HUGE AREA FOR FURTHER HOUSING AND BUSINESS DEVELOPMENT INTO SCOPE.

G. THE LITTLE COMMON ROUNDABOUT IS A CHOKE POINT AND ALWAYS CONGESTED. THIS IS EXACERBATED AS IT IS ON THE MAIN EMERGENCY ROUTE BETWEEN THE CONQUEST HOSPITAL AND EASTBOURNE D.G.H. AND SO CONSISTENTLY USED BY AMBULANCES. IT WOULD BE INTENSIFED BY THE PROPOSED BARNHORN ROAD TRAFFIC LIGHTS.

H. THE INCREASE IN TRAFFIC BETWEEN THE PEVENSEY ROUNDABOUT AND BEXHILL/HASTINGS WILL INCREASE THE USE OF NORMANS BAY/SLUICE LANE/HERBRAND WALK AS A SHORT CUT/RAT RUN AND THE CONSEQUENT DANGERS THAT WILL RESULT.

I. THERE ARE FEW LOCAL EMPLOYMENT OPPORTUNITIES FOR THE ENVISAGED RESIDENTS OF BARNHORN GREEN, NOT TO MENTION BX116, SO IT IS ASSUMED THAT THESE OCCUPANTS WILL USE THEIR CARS TO/FROM WORK AND PARENTS WILL DRIVE THEIR CHILDREN TO THE (OVERLOADED) LITTLE COMMON SCHOOL, OR ELSEWHERE. SURVEYS HAVE SHOWN THAT THE A259 IS ALREADY CARRYING TRAFFIC LEVELS WHICH WERE FORECAST NOT TO BE REACHED UNTIL 2028.

J. THE NORTHERN END OF COODEN SEA ROAD IS CURRENTLY A FREE-FOR-ALL ILLEGAL CAR PARK, WHILE THE PAY & DISPLAY CAR PARK BEHIND ST MARTHA'S CHURCH STANDS MOSTLY EMPTY {AND THIS IS BEFORE BARNHORN GREEN COMES INTO BEING). THIS CAR PARK SHOULD PERHAPS BE REVERTED TO "FREE" OR PARKING REGULATIONS SHOULD BE ENFORCED.

K. CONSIDERATION SHOULD ALSO BE GIVEN TO THE FACT THAT THIS SITE WILL ENCROACH ON THE RAMSAR SITE.

I am completely opposed to the proposed development BX116 of Policy BEX9

I would like this option to be removed from the list of Preferred Sites and not be considered for any future development as part of the second DaSA consultation process.

* I believe it to be unnecessary: in the light of the capacity of other proposed sites to provide adequate development potential (for employment as well as residential properties) it may even cause Bexhill to even exceed, its development targets without this development, therefore deeming it unnecessary in its entirety. Especially if windfalls are taken into account by RDC.

* I believe it to be totally impractical, likely to have a significant detrimental impact on Little Common along with further burdens on already limited local infrastructure. I am extremely concerned on the negative impact such a development will have on this area.

* Such a large and very dense development in the midst of a beautiful and quiet environment will be highly detrimental to the entire area and to the local residents.

* Wildlife impact




















Question Number 35

Why do I find this development adverse?

Local traffic problems
This is a high-density development being squeezed into a very small and environmentally-sensitive area with constricted access and in one direction served by an un-adopted road, that being Maple Walk.

Vehicle access to the site will be via Meads Road and Spindlewood Drive. Meads Road is already used as an all-day car park by people that commute to work in the local businesses along with residents, visitors and tradesmen and is effectively a single lane road. Passing traffic has to negotiate a right of way with opposing vehicles. The condition of the road surface in Meads Road is very poor and does not seem to be a priority for repair, or even routine maintenance, by the local authorities. The concrete surface is breaking up under the current heavy usage let alone a continuous use by earth moving vehicles etc.
At present the small Spindlewood Drive estate serves about forty five properties. The initial length of Spindlewood Drive is also used as a car/van park by Meads Road residents and visitors, since Meads Road parking is usually at its capacity. These parked vehicles have nowhere else to go in the whole area. Vehicles entering Spindlewood Drive via Maple Walk west are thus made to approach a blind bend into Spindlewood Drive forcing vehicles to the right hand side of the road, risking running into vehicles leaving the estate.

I am concerned that vehicles will not always turn left out of Spindlewood Drive but due to heavy parking will prefer to turn right onto Maple Walk, which as previously mentioned is an un-adopted road maintained by 'The Maple Walk North Residents Association'. Residents have to contribute an annual payment in order to keep on top of any future road maintenance, resurfacing along with Public Liability Assurance'. I am concerned that with heavier usage the current road surface will not be able to withstand this. The road surface is currently a thin layer of tar and shingle and is not intended for excessive use or to bare heavy loads. At present the road is resurfaced approximately every 5 years, therefore, additional traffic would undoubtedly incur costs to the residents of Maple Walk.
Maple Walk North is a single lane right of way with many of the driveways along Maple Walk being concealed driveways and unfortunately Maple Walk North and south is already used as a cut through to Spindlewood Drive and with the additional traffic if BX116 goes ahead this once peaceful road will become dangerous for pedestrians and local residents exiting their driveways.

Increasing the traffic flows into and out of Spindlewood Drive which is currently forty five properties to in excess of two hundred is absolute madness, especially considering that this traffic is not only private cars but delivery vans, utilities vehicles, emergency services, heavy goods vehicles and others. Which undoubtedly have a negative impact on Maple Walk.

I understand that the former Co-op building at the end of Meads Road could be developed for shopping and residential properties, significantly increasing vehicle density and traffic flows into and out of the east end of Meads Road. This will undoubtedly see delivery vehicles parking at the very entrance to Meads Road, as well as shoppers who will not use the (Pay & Display) car park behind Tesco but prefer to park on double-yellow lines. The junction of Meads Road and Cooden Sea Road will become itself a log-jam even before the Little Common roundabout and A259 come under consideration. This junction is already dangerous, vision towards the south for traffic emerging from Meads Road is severely restricted by vehicles parked outside the former Co-op building, and restricted to the north by vehicles illegally (but with impunity) parked on the pavement to the north. This area currently is an accident waiting to happen let alone with the possibility of an additional 200 cars using this junction along with delivery lorries, refuge collection etc.

Question Number 35

Meads Road and Spindlewood Drive are absolutely unsuitable to the level of traffic such a development would generate.

It has been calculated that the traffic flows from this development will be 90 - 1—per hour for the peak periods with a total increase in traffic movement of some 50 vehicles per day. This will result in serious traffic congestion at the end of Meads Road with associated high levels of noise and air pollution. Along with the loss of 'Dark Night Sky', night sky pollution, which I understand to be on a political agenda national at present.
There is a real risk, therefore, that some traffic for the BX116 housing estate will use Maple Walk as a rat-run!

Despite our outright objection to this development it is also worthy of note that the would-be developer, Mr Ellis, stated to SPINDAG representatives in a meeting on 2nd December 2016 that if the development were to go ahead all construction traffic would access the site via an entrance on the A259. If that were to be possible for an extended period for heavy goods vehicles, cranes, diggers and other traffic, why could it not form the permanent access? We have seen no credible Transport Management Plan from the developer which addresses the serious impact any means of development of BX116 would have on the surrounding area, whatever the access. RDC must insist therefore on a Transport Management Plan irrespective of the access point.





























Question Number 35

Environmental Concerns- Wildlife negative impact
Although the would-be developer has provided an Ecological Appraisal for BX116 many issues remain to be carefully considered and studied further. There are valid questions to be raised about the ease with which their suggested mitigations can be implemented and their likely effectiveness. This site lies adjacent to areas which are designated SSSI and/or Ramsar sites, deserving of especially rigorous protection. These observations and re-assurances do not seem to have been studied and approved by the relevant utilities, environmental protection and wildlife authorities. The study was commissioned by and paid for by the developer with a commercial interest in this site, hardly an uninterested party. Not least are the issues surrounds drainage and flooding risks, SUDS designs and expectations. Nor is it clear who would be held responsible for any future flooding or environmental damage and how they might be sanctioned in the event of any failure of these measures.

The fields are I believe a wet site habitat. This whole area provides for a huge range of different wildlife species including great crested newts, birds, bats and owls. Some of these are on the protected list and of great concern. These will be greatly disturbed or even destroyed should this development go ahead.

The properties to the SE of the proposed development (Maple Walk North) are a natural soakaway for the adjacent field with an open sewer running through the gardens. At no point has anyone inspected or surveyed these gardens/properties to ascertain the capacity of this natural soakaway as to whether it would be able to cope with additional drainage issues from this proposed development. I believe this to be a major issue as our gardens are often water logged if there is excessive rainfall.

I can foresee a serious risk of permanent environmental damage and wildlife disturbance not only on this site but the surrounding sensitive areas. These could never be corrected once their gone they will be gone forever. It is especially concerning that certain sections of the Ecological Appraisal have been redacted - why? By whom? With what objective in mind? This should be investigated and the public made aware of the reasons for this.

The site BX116 has been refused planning permission in the past and I can only comment that nothing has changed since then so why is it thought planning can go ahead now?


















Question Number 35
Wider local impact:
The road system, local services and infrastructure around Little Common are already due to be overloaded without the added burden which BEX9/BX116 would bring. The doctors' surgery is always packed (the new one proposed for Barnhorn Green having been abandoned), the school is over-subscribed and there are no secondary schools nearby.

The A259 is wholly unsuitable for the traffic levels passing through Little Common and Bexhill overall. Much of it is through traffic which must use the A259 as the only major east-west route along England's south coast. If anything, the new Bexhill-Hastings Link Road has added to traffic pouring through Little Common as it provides an improved route for traffic aiming to bypass St. Leonards and Hastings (partially). The much talked about Bexhill bypass comes to mind in this context - linking the NBAR to the A259 west of Bexhill would alleviate some of this traffic, not to mention bringing a huge area for further housing and business development into play.

There are few local, (in Little Common), employment opportunities for the envisaged residents of Barnhorn Green, not to mention BX116, so it can be certainly assumed that these working residents will use their cars to commute to/from work and to transport their children to the already oversubscribed Little Common school or elsewhere. Surveys have shown that the A259 is already carrying the forecast for 2028 traffic levels.

The lack of any current knowledge of existing air pollution levels is disturbing, given that RDC has already approved substantial new development projects in the area and is anticipating even more - without apparent regard for this serious, health-related issue, and doubly serious considering the increased proportion of children these proposed developments might bring to the area. It is already planned that traffic lights be installed on the A259 for an entrance serving Barnhorn Green which will create yet more standing traffic along that busy road.

The northern end of Cooden Sea Road is currently full of illegal car parking, with not a traffic warden insight, while the Pay & Display car park behind St Martha's church stands mostly empty, and this is before Barnhorn Green it built. Even more housing development in this already congested area will make life very problematic for residents, both current and future. I can only foresee an increase in accidents both pedestrian and vehicles thus putting additional stresses on an already overstrained infrastructure.

I am concerned about the longer-term risk of "development creep". BX116 lies adjacent to other sites which were considered for development (BX51, BX109, BX115 & BX61). These have been ruled unsuitable, often due to recognised flood risk (uncontrolled drainage from BX116?) If BX115 and BX108 are precious and worthy of protection to preserve the area's "character", then so too should be BX116. We should be protecting our green belt areas not destroying them.

When will it end? We will be a suburb of Eastbourne to the West and Hastings to the East if these housing developments continue.













Question Number 35


Density of proposed development
The housing estate proposed is far too high a density for the area surrounding it. This area of Little Common consists predominantly of mature detached houses. It has already been noted that the Spindlewood Drive estate has only about forty five houses. It is proposed to pack 160 into an area not much larger than that original development (allowing for trees, play areas, ponds, etc.). This near-quadrupling of housing density is entirely out of keeping with the local area. Parking multiple vehicles per household, probably spilling out onto the surrounding roads causing even more congestion.

BEX9

* We do not agree with any development at all off Spindlewood Drive. It would be an erosion of the countryside around Little Common, which is the entrance to the town of Bexhill. Little Common does not have the roads or facilities to cope with yet more houses and is already suffering major traffic congestion and consequent pollution, which is harmful to health.

* There are more suitable sites elsewhere:

BX124 Option 2 where the necessary infrastructure can be built
BX101 after a northern access road has been built.
The area behind Bexhill Police station instead of more retail sites.

This is an extremely badly conceived proposal on several different fronts but primarily on account of the lack of suitable infrastructure around Little Common.

Little Common will never cope with a development of this size on top of the approved sites at Barnhorn Green (342), the former Nat West Bank (8) and 45/47 Barnhorn Road (8) as well the probable sites at Ashridge Court Care Home (31) and the former Co-Op building (9). In all, 398 dwellings, c 800-900 residents and a similar number of cars/vans etc.
Little Common has no suitable infrastructure to cope even with these; namely

1. A GP surgery close to capacity
2. Little Common primary school at capacity now (10 vacancies out of 630)
3. No nearby secondary schools
4. No job prospects
5. No good nearby train services to London
6. No good larger scale shopping centres nearby
7. The A259 that is already close to capacity and about to get far worse once the traffic lights and zebra crossing are installed as a result of Barnhorn Green let alone the increase in traffic in and out of Barnhorn Green.

To contemplate adding another 160 properties with 300+ residents and 300+ vehicles would indeed be an act of folly that would push Little Common's infrastructure to a point of crisis causing untold misery and complications for all Little Common's residents.

Other issues with the Spindlewood proposal include:

1. Access to site - a totally unsuitable access point via Spindlewood Drive itself. This road along with a small section of Maple Walk and all of Meads Road are all no wider than 5.5 mtrs narrowing to 5.4mtrs at the BT exchange site along Meads Road. I understand that this type of spine road should be a minimum of 6.1mtrs wide. Furthermore, Meads Road is a permanent car park for residents and visitors/tradesmen alike for long stretches of the road on either side. Consequently, the road is reduced to a single lane for more than 50% of its length for most of the day. To contemplate very wide and heavy construction traffic using these roads for a period of up to 3 years during the construction phases would be utter madness and will result in chaos.

2. It should be noted that RDC's Core Strategy document dated Sept 2014 quite clearly states that any residential construction to the West of Little Common roundabout must be effected via Barnhorn Road and this is precisely what should happen for the Spindlewood site were it to proceed.

3. Density - 160 houses is too high a density for the size of this site (taking account of green designated areas). Such a density would be totally out of keeping with all other local roads and properties. Furthermore, looking at the footprint for Spindlewood Drive and superimposing it on BX116 results in no more than 80-90 properties and this is the number of properties that should be considered as viable for this site.

4. Conservation and aesthetics - BX116 site is a very pleasant, semi-rural quiet location that is full of wildlife giving it a unique aspect around Little Common and the very reason that the vast majority of residents have chosen to live there (paying a premium for their properties as a result). Great crested newts are on the field as are numerous badgers who live in a massive sett behind 16 Spindlewood Drive. Whilst the developer says he will take mitigating measures to ensure all wildlife is treated in accordance with the law, there will inevitably be a detrimental impact on this wildlife and the quality of life for all locally based residents will be damaged forever.

5. SSSI and Ramsar - BX116 abuts an SSSI and thence onto a RAMSAR (973). Despite assurances from the developer that suitable SuDS will be deployed to avoid unnecessary flooding and consequent potential damage to the SSSI and Ramsar, this site has a history of flooding along the bottom of the field and abutting Maple Walk. Concreting over a field will almost certainly result in excessive flooding at some stage due to deluges that cannot be predicted and which could well result in contaminated water flooding the SSSI and onto the Pevensey Levels. Who will be held responsible once the developer has walked away from the site?

Conclusion

Site BX116 must not be developed for all the reasons given above but primarily because Little Common's infrastructure will not cope.

An alternative and far better site would therefore be site BX124 (NBAR) where there is very good locally based infrastructure and which would have no adverse effect on either the environment nor any local communities.

My wife and I wish to record our strongest possible opposition to the proposed development of land in the vicinity of Spindlewood Drive - BX116.

RDC should already be aware that the traffic volumes in and around the Little Common are already at dangerously high levels following the traffic surveys it undertook prior to and instrumental in securing funding for the Bexhill relief road. At peak times, the queue of traffic travelling west along Barnholm Road approaching Little Common roundabout frequently exceed 2 miles in length. This problem will be further exasperated when the lights and zebra crossing are introduced at the Barnholm Green development. Notwithstanding the fact that this represents a clear demonstration, if that were needed, that the road infrastructure in the vicinity of Little Common Roundabout is totally unsuited to the present volume of traffic, it also brings into question the issue of the damage to air quality to those Barnholm Road residents unfortunate enough to live in close proximity to the frequent standing traffic.

The proposed development would simply add to the problems of both traffic volumes and seriously impact further on air quality and which may already contravene EU directive EC2008/50/EC.

I dispute that the Highways Department can make a comprehensive and accurate assessment of the development would impact on the area. This is precisely due to the fact that 1631 dwellings in Bexhill have planning permission yet are not built yet. Please provide the information that was used by the highways department to make their assessment. Also when making their assessment did they calculated the impact that the 1631 dwellings would make to the A259 Barnhorn Rd? Many of which are part of the 'Barnhorn Green' development and exiting directly on the A259.

The entrance to the Spindle Drive proposed development land is incomprehensible. The traffic that would flow directly onto the centre of the village particularly during rush hours would cause the traffic to come to a complete standstill. The village would become a no go area. We already struggle with the village traffic during mornings and evenings. This is not even considering the additional traffic the Barnhorn Green development is going to bring.

Since the early 90's there has been a demand from the volume of traffic on the A259 that a By Pass is required to divert traffic from Barnhorn Rd. How can any further large developments be approved in the area until after the completion of Barnhorn Green, to see how Barnhorn Road will cope without a bypass. The other developments that are already approved yet not built will also be using Barnhorn Rd to travel. This large additional volume of traffic is going to cause disruption if not gridlock to Barnhorn Rd therefore, must not be overlooked when approving further developments. Every individual in Bexhill, Hastings and through traffic would benefit enormously by a Little Common By Pass.

The 'Existing Use' of 'Grazing Land' falls short! The fact is this land is part of Barnhorn Farm which is in fact, a working Dairy Farm and the cattle of this dairy farm graze on this land most days. It is also my understanding from the late Mrs Ward Jones, that Barnhorn Farm is mentioned in the doomsday book as a farm that the monks from Battle Abbey used to farm. In addition it is the only existing working farm mentioned in the
Doomsday Book. The proposed West boundary of the proposed site is directly up against the historic farm buildings of the working farm including the 'Dairy'. Highly unacceptable to the wellbeing of the cows. The undesirable odour of dairy farming will also have a negative impact on the occupants of the houses.
It is vital that the council consults with Natural England, DEFRA & English Heritage before any final decisions to determine this site Figure 38 BX116 Land off of Spindlewood Drive is acceptable for any kind of development.

Regarding Policy BEX9 iv - We would require far more than retention of existing boundary planting and any enhancements would need to be substantial in width & height. The existing hedge line which was once hawthorn trees have been damage and destroyed from past storms. We have not had a problem with this as our house looks over the fields with grazing Jersey cows. Unlike other properties backing onto this development our houses are very close, one approx 7M from the boundary. To have a development/road running so close to them would be detrimental to our peace, enjoyment, privacy and value of the properties. Particularly since both have large south facing balconies and large windows to all living accommodations on
ground & 1st Floors of the properties. Completely unsuitable for a development so close. Bedrooms and living area would be completely overlooked.

The OS maps do not accurately show the boundaries of our property. as we have a chain link badger proofing fence licensed under DEFRA that sits 1.35 M INSIDE our Boundary of 55A.

BX124 (North Bexhill Access Road - question 29) is by far and away the most suitable site for extra development over and above that proposed in DaSA Option 1 - 450 houses, and that an additional 100-150 houses should be built on this site as part of Option 3.

There is inadequate infrastructure around the Little Common Area. The infrastructure around the NBAR is fundamentally superior to Little Commons with minimal environmental impact - so need to build even more houses there rather than anywhere else in Bexhill.

I noticed in Question 36 that it has been determined that a primary school is not required and that plans are to abort the previously proposed primary school and build houses instead. Please explain how this determination was made. Did the department in charge of this decision, give due consideration to the fact that further property developments in the area will have primary school aged children living at them? Where will all
these children go to school? I am in walking distance to Little Common Primary yet my son was not given a place, as the school was over its intake. I ended up having to drive my son to Herstmonceux Primary for 5 years.

It is also vital that all trees on the site be assessed for TPO's by the appropriate department.

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 (DaSA) 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) Proximity to treatment works and requirement for odour assessment

A few of the sites identified in the DeSA are in close proximity to our treatment works. Southern Water endeavours to operate its wastewater and sludge treatment works efficiently and in accordance with best practice to prevent pollution. However, unpleasant odours inevitably arise as a result of the treatment processes that occur.

New development must be adequately separated from wastewater treatment works to safeguard the amenity of future occupiers/users. Paragraph 109 of the National Planning Policy Framework (NPPF) requires that the planning system should prevent new development from being put at unacceptable risk from, or being adversely affected by unacceptable pollution. Annex 2 of the NPPF established that pollution includes odour and noise. Paragraph 120 of the NPPF states that 'To prevent unacceptable risks from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account'. Paragraphs 4.3.1 and 4.3.1 of the National Policy Statement for Wastewater state that 'Odours from waste water infrastructure can have a significant adverse impact on the quality of life of individuals and communities. Waste water infrastructure generates odour emissions during all stages of conveyance, treatment and storage. At waste water treatment works odours may arise from the inlet works; primary settlement tanks; during secondary treatment; and particularly from sludge treatment, transfer and storage'.

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.

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

This site is in close proximity to Spindlewood Drive, Bexhill Wastewater Pumping Station.

* The masterplanning of the site should take account of nearby wastewater pumping stations to minimise land use conflict.

We do not agree with all of the content of BEX 9 for the following reasons:-

* The housing density proposed is out of proportion with the current housing stock in the area.

* The infrastructure within the Little Common area is already stretched to capacity and that is without the inclusion of the Barnhorn Green development. This includes but is not limited to doctors, schools, local employment and pharmacy services.

* The fields as they currently stand provide a refuge for a wide variety of wildlife that would be severely affected by the development. There are badgers, foxes, slow worms, a rookery as well as many other birds that would be displaced.

We have a 100ft boundary adjacent to the proposed development site. Our current standard of living would be adversely affected by any development due to the increased noise, light pollution, traffic increase, etc. We moved here as a final place to live because it offered peace and tranquillity in a village setting and as such we paid over the odds for our property.

I disagree with the requirements of BEX9. I think it is totally unsuitable, therefore do not have any amendments in mind that would make it suitable to me. However, there are options that could possibly lessen the load on Little Common and its surrounding roads.

1/ Wait for a period of time, a year or so after the Barnhorn Green site is completed, in order to see what effects this has on the Little Common area. Once Barnhorn Green is open, RDC can truly gauge the effects caused by the extra vehicles rather than pre-empting it based on figures that refer to a survey done nearly two years ago.

2/ Do not develop BEX9 at all, instead increase the numbers of houses proposed at BEX124/BEX3. Both of these sites are more suited to large scale developments with less of an impact on the lives of existing residents

3/ If BEX9 must be given the go ahead, do not progress unless it features a direct access road to the A259 Barnhorn Road. Also, do something about Little Common Roundabout, which is a bottleneck even now, let alone once traffic from Barnhorn Green hits us.

4/ Ask for councillors that make decisions to come and explore the area themselves, rather than go by surveys done by independent companies based tens or hundreds of miles away. Come and experience the problems we have now, rather than add to them.

5/ Conduct noise and pollution level tests - surely these are a pre-requisite of any new development. Does RDC plan to do this and publish the reports?

We are opposed to the development BX116 of Policy BEX9

Taking into account the other proposed sites for development within the Bexhill area, the proposed planning development for Spindlewood/Maple Walk BX116 is detrimental to the local environment. RDC should take into account the number of windfall sites built on over the last few years, there is no reason why this should not continue in the next few years. This could make up a substantial additional properties in the Bexhill for RDC to achieve the target of new housing and making the BX116 unnecessary. The impact on the local community of Little Common will be immense. The proposed 160 dwellings within the small community is out of character, The plan shows 116 dwelling "roofs" this must mean that some of the dwellings are multiple occupancy, which is not in keeping with the local housing/community around the border of the proposed development and better suited in other proposed planning areas. The bordering properties are detached houses/bungalows. The proposed 160 dwellings in the area proposed is too small and the residents will find themselves living on top of each other. Most families have two cars and possibly and works van, campers van etc. Where are they going to park?

The entrance to the proposed development shows to be off Spindlewood Drive, The entrance area is narrow and on a bend, already the residents are having to drive round this blind bend on the other side of the road as some residents of Meads Road/Maple Walk park in Spindlewood Drive are parking at the entrance. The increase of traffic in and out of Spindlewood which having 45 dwellings increased to over 200 all make the road congested and dangerous. This will not only be cars from the area but delivery trucks, working vans, deliveries and emergency services making the limited visual turning into and out of Spindlewood Drive. Vehicles driving out of Meads Road onto Little Common Road is already a problem with cars double parked and on the entrance makes the view be limited, With the additional traffic more the doubling this will only get worse.

The road surface for Meads road is already showing signs of disrepair and will suffer from heavy duty usage. With cars parked on one side of the road this makes Meads Road very narrow. Maple Walk is at one point a single track, with no pavements. People choose to walk along Maple Walk for safety as the main road from Cooden Beach have no pavements on part of the road and already has a large volume of traffic, Maple Walk is un-adopted, with the up keep being met by the residents not by RDC. Who will be responsible for the repairs to these roads, the developer or RDC??.

The fields for the proposed development soak up a lot of water. What provision will be put in place to protect the houses when the fields become concrete. Within the plans of the properties in Spindlewood have notice to flooding in their immediate area.

On the RDC pack regarding planning the part that has mention the badgers set has been blocked out, why are the developers not being transparent about what is going to happen, Badgers require a 2 mile radius to forage for food, they will require special care when development nearby takes place. There is a large wild life community within the proposed area. They need to be protected. RDC have a responsibility to all great and small wild life within the proposed building area.

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

BX116
BEX9
European designated sites - Pevensey Levels Ramsar site: supporting habitat.

Our records show that this site may form functional habitat for the bird species of the Ramsar and therefore detailed surveys/survey data will be required. If the site is confirmed as supporting habitat, it is given the same level of protection as the
Ramsar.

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

If the allocation is likely to have a significant effect on the SSSI (e.g. from run-off and pollutants entering the ditch network harming the botanical, invertebrate
and bird interest of the SSSI), appropriate mitigation measures need to be specified.

Designated sites - Pevensey Levels SSSI hydrological catchment area.

Development proposals within the Pevensey catchment should include SuDS that deliver multiple benefits for the water environment, wildlife and people, and to achieve the greatest benefits, SuDS should be joined up at a landscape scale.
Note: Natural England would welcome the opportunity to work with the lpa and other partners to achieve this, and implement the related policies in the Rother District Local Plan.

I am opposed to the proposed development BX116 of Policy BEX9 in its entirety.

I ask for it to be removed from the list of Preferred Sites and not be considered for any future development as part of the second DaSA consultation process.

I must now insist that the bases upon which RDC proposes the Spindlewood site BEX09/BX116 as a Preferred Site. are ill-founded, and that there is absolutely no need to include BEX09/BX116 in the DaSA plans/proposals.

Some simple studies of RDC's records by a group of neighbours - whose integrity and findings I support - has shown that the Spindlewood Site development proposal (and others around Little Common) is superfluous.

Each and every year over the past 10 years, RDC has approved an average of 70 small development applications, which has allowed Bexhill to expand at a manageable rate, without crises or critical infrastructure problems. In the next 11 years there is every reason to expect these 'windfall' increases to continue, resulting in a further 770 homes across Bexhill, irrespective of any resulting from the DaSA processes.

I understand that RDC has stated that it is not willing to take projected small windfall properties into account when estimating their target figure of 3100 for Bexhill. This is illogical, and morally wrong. It amounts to ignoring information which they cannot be bothered to consider, which, if they did ignore would be incompetent. If only half the likely windfall numbers WERE taken into account, RDC could still avoid the risk of making decisions on development sites that need not be developed (such as BX116) in order for RDC to meet (and perhaps) beat their target of 3100.

By acting wisely, RDC could avoid making such errors from which peoples' lives and quality of life would be irrevocably damaged. That unnecessary consequence would be both tragic and unforgivable.

This further information explains with more detail, my point - and probably the same point being presented by other residents.

Using the figures contained in RDC's Housing Land Supply document dated as at April 2016 and making allowance for projected small and large site windfalls over the period 2016 - 2028 as well as the recently proposed developments in and around Little Common as detailed in 3(a) above, it is estimated that Bexhill will be able to achieve approximately 3315 properties by the end of 2028. This exceeds by 215 the target set by RDC of 3100 and excludes the following sites
BEX6 - Turkey Road
BEX7 - Fryatt's Way
BEX9 - Spindlewood Drive
BX101 - Northeye

Consequently, I request that Spindlewood Drive, be removed from the second DaSA consultation process.

Why BEX9/BX116 is completely undesirable and unsuitable

Appalling Site access and local traffic problems

I believe the Spindlewood Drive development proposal is undesirable. It is wholly impractical, likely to have a significant detrimental impact on Little Common, it would further burden the already stretched local infrastructure, is out of character with Little Common and its feasibility is based on highly suspect traffic predictions.

The proposal is for a high-density development being squeezed into a very small and environmentally-sensitive area with ridiculously constricted access.

As proposed, vehicular access to the site will be via Meads Road and Spindlewood Drive. Meads Road is already used as an all-day car park by residents, visitors and tradesmen and is effectively a single lane road. Passing traffic has to negotiate a right of way with opposing vehicles. Furthermore, the condition of the road surface in Meads Road is very poor and does not seem to be a priority for repair, or even routine maintenance, by the local authorities. The concrete surface is breaking up and residents report being aware of moving slabs as heavy vehicles pass their properties.

At present the small Spindlewood Drive estate serves about forty five properties. The initial length of Spindlewood Drive is also used as a car/van park by Meads Road residents and visitors, since Meads Road parking is usually at its capacity. These parked vehicles have nowhere else to go in the whole area. Vehicles entering Spindlewood Drive via Maple Walk west are thus made to approach a blind bend into Spindlewood Drive forcing vehicles to the right hand side of the road, risking running into vehicles leaving the estate. A similar hazard greets drivers 50 yards further into Spindlewood drive, precisely at the access point proposed for the Development, where vehicles travelling towards Meads Road also have a blind corner approaching a single-lane passage.

Increasing the traffic flows into and out of Spindlewood Drive from that associated with forty five properties to in excess of two hundred is absolute madness, especially considering that this traffic is not only private cars but delivery vans, utilities vehicles, emergency services, heavy goods vehicles and others. Not to mention the fact that there is very limited visibility for traffic on Meads Road to see into Spindlewood Drive and vice versa due to the tightness and narrowness of the junction and the afore-mentioned parked cars and vans on both roads.

It is proposed that the former Co-op building at the end of Meads Road could be developed for shopping and residential properties, significantly increasing vehicle density and traffic flows into and out of the east end of Meads Road. This will undoubtedly see delivery vehicles parking at the very entrance to Meads Road, as well as shoppers who will not use the (Pay & Display) car park behind Tesco but prefer to park on double-yellow lines. The junction of Meads Road and Cooden Sea Road will become itself a log-jam even before the Little Common roundabout and A259 come under consideration. This junction is already dangerous, vision towards the south for traffic emerging from Meads Road is severely restricted by vehicles parked outside the former Co-op building, and restricted to the north by vehicles illegally (but with impunity) parked on the pavement to the north.

Meads Road and Spindlewood Drive are wholly unsuited to the level of traffic such a development would generate.

The would-be developer of BX116 has provided a barely credible "Technical Note" predicting an "immaterial" impact from increased BEX116 traffic on the Little Common roundabout (available on the DaSA web site, presumably with RDC's endorsement). It studiously avoids addressing traffic flows along Spindlwood Drive and Meads Road. This self-serving document seems to have been accepted at face value by RDC but should be re-assessed on a more realistic and analytical basis in terms of the impact on Meads Road, Maple Walk and Spindlewood Drive.

For example, the Transport Statement for the proposed development of only thirty one properties near Ashridge Court (RR/2016/3206/P) offers a far more thorough analysis of traffic flows into and out of that site and the impact that these will have on the A259. This document and its underlying model and assumptions would seem to be acceptable to the relevant transport authorities. Therefore, it would be entirely reasonable and enlightening to use the same models and assumptions to extrapolate the potential traffic flows for the 160 houses of BX116.

On this basis the following will be seen on Meads Road:

Peak traffic flow (08:00 - 09:00 & 17:00 - 18:00) of between 90-100 vehicles each hour along Meads Road & Spindlewood Drive

Total traffic movements of c 850 per day

RDC planners should view the BEX9/BX116 Transport Note with some scepticism and should seek a rigorous revision by an uninterested party.

There is a real risk, therefore, that some traffic for the BX116 housing estate will use Maple Walk, running south-west towards the coast, as a rat-run alternative to Meads Road. Maple Walk is an unadopted road, much of it very narrow, effectively single lane with NO footpaths, worse than Meads Road. The increased traffic flow along Maple Walk and Maple Avenue would be unbearable for their residents, not to mention the added wear & tear on roads which have only a gravel foundation and which they must maintain at their own expense.

It should be noted that RDC's own Adopted Core Strategy (Sept 2014) states in para 8.56 that "access (to the west of Little Common both north and south of Barnhorn Road) would need to be created directly off the A259". This alone would seem to prohibit the proposed access to BX116 from using Meads Road and Spindlewood Drive.

Despite my outright objection to this development it is also worthy of note that the would-be developer, Mr Ellis, stated to representatives of our residents in a meeting on 2nd Dec ember 2016 that if the development were to go ahead all construction traffic would access the site via an entrance on the A259. If that were to be possible for an extended period for heavy goods vehicles, cranes, diggers and other traffic, why could it not form the permanent access point for the estate? Serious commitment by the developer or pillow talk? We residents have seen no credible Transport Management Plan from the developer which addresses the serious impact any means of development of BX116 would have on the surrounding area, whatever the access. RDC must insist therefore on a Transport Management Plan irrespective of the access point.

Density of proposed development

The housing estate proposed is far too high a density for the area surrounding it. This area of Little Common consists predominantly of mature detached houses. It has already been noted that the Spindlewood Drive estate has only about forty five houses. It is proposed to pack 160 into an area not much larger than that original development (allowing for trees, play areas, ponds, etc.). This near-quadrupling of housing density is entirely out of keeping with the local area and even residents of the proposed estate would find themselves with very a cramped environment with certain problems for parking multiple vehicles per household, probably including vans, caravans and camper vans.

Environmental Concerns

Although the would-be developer has provided an Ecological Appraisal for BX116 many issues remain to be carefully considered and studied further. There are valid questions to be raised about the ease with which their suggested mitigations can be implemented and their likely effectiveness. This site lies adjacent to areas which are designated SSSI and/or Ramsar sites, deserving of especially rigorous protection. These observations and re-assurances do not seem to have been studied and approved by the relevant utilities, environmental protection and wildlife authorities. The study was commissioned by and paid for by the developer with a commercial interest in this site, hardly an uninterested party. Not least are the issues surrounds drainage and flooding risks, SUDS designs and expectations. Nor is it clear who would be held responsible for any future flooding or environmental damage and how they might be sanctioned in the event of any failure of these measures.

One can foresee major disturbance to the land under development during the construction phase before these mitigating facilities can be put in place. There is, therefore, a serious risk of permanent environmental damage and wildlife disturbance not only on this site but the surrounding sensitive areas. These could never be corrected and the developer would have built his houses anyway. It is especially concerning that certain sections of the Ecological Appraisal have been redacted - why? By whom? With what objective in mind? This should be investigated and the public made aware of the reasons for this.

Wider local impact:

The road system, local services and infrastructure around Little Common are already due to be overloaded without the added burden which BEX9/BX116 would bring. The doctors' surgery is always packed (the new one proposed for Barnhorn Green having been abandoned), the school is over-subscribed and there are no secondary schools nearby.

It is a widely held view across the whole Bexhill district that the A259 is wholly unsuitable for the traffic levels passing through Little Common and Bexhill overall. Much of it is through traffic which must use the A259 as the only major east-west route along England's south coast. If anything, the new Bexhill-Hastings Link Road has added to traffic pouring through Little Common as it provides an improved route for traffic aiming to (partially) bypass St. Leonards and Hastings. The much talked about Bexhill bypass comes to mind in this context - linking the NBAR to the A259 west of Bexhill would alleviate some of this traffic, not to mention bringing a huge area for further housing and business development into play.

There are few local (in Little Common) employment opportunities for the envisaged residents of Barnhorn Green, not to mention BX116, so it can be certainly assumed that these working residents will use their cars to go to/from work and that parents will drive their children to the (overloaded) Little Common school or elsewhere. Surveys have shown that the A259 is already carrying traffic levels which were forecast not to be reached until 2028.

We have learnt that no recent air pollution monitoring has been taking place along the A259 in Little Common (though a lamp-post mounted unit is soon to be installed). The lack of any current knowledge of existing air pollution levels is disturbing, given that RDC has already approved substantial new development projects in the area and is anticipating even more - without apparent regard for this serious, health-related issue, and doubly serious considering the increased proportion of children these proposed developments might bring to the area. It is already planned that traffic lights be installed on the A259 for an entrance serving Barnhorn Green which will create yet more standing traffic along that busy road.

The northern end of Cooden Sea Road is currently a free-for-all illegal car park, while the Pay & Display car park behind St Martha's church stands mostly empty, and this is before Barnhorn Green comes into being. Even more housing development in this very congested area will make life insufferable for residents, both current and future. Enough is enough.

Development creep

We have concerns about the longer-term risk of "development creep". BX116 lies adjacent to other sites which were considered for development (BX51, BX109, BX115 & BX61). These have been ruled unsuitable, often due to recognised flood risk (uncontrolled drainage from BX116?) and for the sake of views from elsewhere in the area, mainly from the west and so judged to be "out of character" with the local area. We believe that the current assignment of these sites to the unsuitable category would be put in jeopardy if the BX116 development took place. There would certainly be further pressure from land-owners and developers keen to cash in on the sprawl that an extended development south of Barnhorn Road would facilitate. If BX115 and BX108 are precious and worthy of protection to preserve the area's "character", then so too should be BX116. As they say in the sales: When it's gone, it's gone.

I am a member and strong supporter of the Spindlewood Action Group - SPINDAG -whose members have conducted extensive research, held public meetings and surgeries amongst local residents and found the vast majority of respondents to believe this proposed development to be wholly unnecessary and undesirable. We ask that it be removed from the second DaSA consultation process and not to be considered for any future development.

I am opposed to the proposed development BX116 of Policy BEX9 in its entirety.

I ask for it to be removed from the list of Preferred Sites and not be considered for any future development as part of the second DaSA consultation process.

I must now insist that the bases upon which RDC proposes the Spindlewood site BEX09/BX116 as a Preferred Site. are ill-founded, and that there is absolutely no need to include BEX09/BX116 in the DaSA plans/proposals.

Some simple studies of RDC's records by a group of neighbours - whose integrity and findings I support - has shown that the Spindlewood Site development proposal (and others around Little Common) is superfluous.

Each and every year over the past 10 years, RDC has approved an average of 70 small development applications, which has allowed Bexhill to expand at a manageable rate, without crises or critical infrastructure problems. In the next 11 years there is every reason to expect these 'windfall' increases to continue, resulting in a further 770 homes across Bexhill, irrespective of any resulting from the DaSA processes.

I understand that RDC has stated that it is not willing to take projected small windfall properties into account when estimating their target figure of 3100 for Bexhill. This is illogical, and morally wrong. It amounts to ignoring information which they cannot be bothered to consider, which, if they did ignore would be incompetent. If only half the likely windfall numbers WERE taken into account, RDC could still avoid the risk of making decisions on development sites that need not be developed (such as BX116) in order for RDC to meet (and perhaps) beat their target of 3100.

By acting wisely, RDC could avoid making such errors from which peoples' lives and quality of life would be irrevocably damaged. That unnecessary consequence would be both tragic and unforgivable.

This further information explains with more detail, my point - and probably the same point being presented by other residents.

Using the figures contained in RDC's Housing Land Supply document dated as at April 2016 and making allowance for projected small and large site windfalls over the period 2016 - 2028 as well as the recently proposed developments in and around Little Common as detailed in 3(a) above, it is estimated that Bexhill will be able to achieve approximately 3315 properties by the end of 2028. This exceeds by 215 the target set by RDC of 3100 and excludes the following sites

BEX6 - Turkey Road
BEX7 - Fryatt's Way
BEX9 - Spindlewood Drive
BX101 - Northeye

Consequently, I request that Spindlewood Drive, be removed from the second DaSA consultation process.

Why BEX9/BX116 is completely undesirable and unsuitable

Appalling Site access and local traffic problems

I believe the Spindlewood Drive development proposal is undesirable. It is wholly impractical, likely to have a significant detrimental impact on Little Common, it would further burden the already stretched local infrastructure, is out of character with Little Common and its feasibility is based on highly suspect traffic predictions.

The proposal is for a high-density development being squeezed into a very small and environmentally-sensitive area with ridiculously constricted access.

As proposed, vehicular access to the site will be via Meads Road and Spindlewood Drive. Meads Road is already used as an all-day car park by residents, visitors and tradesmen and is effectively a single lane road. Passing traffic has to negotiate a right of way with opposing vehicles. Furthermore, the condition of the road surface in Meads Road is very poor and does not seem to be a priority for repair, or even routine maintenance, by the local authorities. The concrete surface is breaking up and residents report being aware of moving slabs as heavy vehicles pass their properties.

At present the small Spindlewood Drive estate serves about forty five properties. The initial length of Spindlewood Drive is also used as a car/van park by Meads Road residents and visitors, since Meads Road parking is usually at its capacity. These parked vehicles have nowhere else to go in the whole area. Vehicles entering Spindlewood Drive via Maple Walk west are thus made to approach a blind bend into Spindlewood Drive forcing vehicles to the right hand side of the road, risking running into vehicles leaving the estate. A similar hazard greets drivers 50 yards further into Spindlewood drive, precisely at the access point proposed for the Development, where vehicles travelling towards Meads Road also have a blind corner approaching a single-lane passage.

Increasing the traffic flows into and out of Spindlewood Drive from that associated with forty five properties to in excess of two hundred is absolute madness, especially considering that this traffic is not only private cars but delivery vans, utilities vehicles, emergency services, heavy goods vehicles and others. Not to mention the fact that there is very limited visibility for traffic on Meads Road to see into Spindlewood Drive and vice versa due to the tightness and narrowness of the junction and the afore-mentioned parked cars and vans on both roads.

It is proposed that the former Co-op building at the end of Meads Road could be developed for shopping and residential properties, significantly increasing vehicle density and traffic flows into and out of the east end of Meads Road. This will undoubtedly see delivery vehicles parking at the very entrance to Meads Road, as well as shoppers who will not use the (Pay & Display) car park behind Tesco but prefer to park on double-yellow lines. The junction of Meads Road and Cooden Sea Road will become itself a log-jam even before the Little Common roundabout and A259 come under consideration. This junction is already dangerous, vision towards the south for traffic emerging from Meads Road is severely restricted by vehicles parked outside the former Co-op building, and restricted to the north by vehicles illegally (but with impunity) parked on the pavement to the north.

Meads Road and Spindlewood Drive are wholly unsuited to the level of traffic such a development would generate.

The would-be developer of BX116 has provided a barely credible "Technical Note" predicting an "immaterial" impact from increased BEX116 traffic on the Little Common roundabout (available on the DaSA web site, presumably with RDC's endorsement). It studiously avoids addressing traffic flows along Spindlwood Drive and Meads Road. This self-serving document seems to have been accepted at face value by RDC but should be re-assessed on a more realistic and analytical basis in terms of the impact on Meads Road, Maple Walk and Spindlewood Drive.

For example, the Transport Statement for the proposed development of only thirty one properties near Ashridge Court (RR/2016/3206/P) offers a far more thorough analysis of traffic flows into and out of that site and the impact that these will have on the A259. This document and its underlying model and assumptions would seem to be acceptable to the relevant transport authorities. Therefore, it would be entirely reasonable and enlightening to use the same models and assumptions to extrapolate the potential traffic flows for the 160 houses of BX116.

On this basis the following will be seen on Meads Road:

Peak traffic flow (08:00 - 09:00 & 17:00 - 18:00) of between 90-100 vehicles each hour along Meads Road & Spindlewood Drive

Total traffic movements of c 850 per day

RDC planners should view the BEX9/BX116 Transport Note with some scepticism and should seek a rigorous revision by an uninterested party.

There is a real risk, therefore, that some traffic for the BX116 housing estate will use Maple Walk, running south-west towards the coast, as a rat-run alternative to Meads Road. Maple Walk is an unadopted road, much of it very narrow, effectively single lane with NO footpaths, worse than Meads Road. The increased traffic flow along Maple Walk and Maple Avenue would be unbearable for their residents, not to mention the added wear & tear on roads which have only a gravel foundation and which they must maintain at their own expense.

It should be noted that RDC's own Adopted Core Strategy (Sept 2014) states in para 8.56 that "access (to the west of Little Common both north and south of Barnhorn Road) would need to be created directly off the A259". This alone would seem to prohibit the proposed access to BX116 from using Meads Road and Spindlewood Drive.

Despite my outright objection to this development it is also worthy of note that the would-be developer, Mr Ellis, stated to representatives of our residents in a meeting on 2nd Dec ember 2016 that if the development were to go ahead all construction traffic would access the site via an entrance on the A259. If that were to be possible for an extended period for heavy goods vehicles, cranes, diggers and other traffic, why could it not form the permanent access point for the estate? Serious commitment by the developer or pillow talk? We residents have seen no credible Transport Management Plan from the developer which addresses the serious impact any means of development of BX116 would have on the surrounding area, whatever the access. RDC must insist therefore on a Transport Management Plan irrespective of the access point.

Density of proposed development

The housing estate proposed is far too high a density for the area surrounding it. This area of Little Common consists predominantly of mature detached houses. It has already been noted that the Spindlewood Drive estate has only about forty five houses. It is proposed to pack 160 into an area not much larger than that original development (allowing for trees, play areas, ponds, etc.). This near-quadrupling of housing density is entirely out of keeping with the local area and even residents of the proposed estate would find themselves with very a cramped environment with certain problems for parking multiple vehicles per household, probably including vans, caravans and camper vans.

Environmental Concerns

Although the would-be developer has provided an Ecological Appraisal for BX116 many issues remain to be carefully considered and studied further. There are valid questions to be raised about the ease with which their suggested mitigations can be implemented and their likely effectiveness. This site lies adjacent to areas which are designated SSSI and/or Ramsar sites, deserving of especially rigorous protection. These observations and re-assurances do not seem to have been studied and approved by the relevant utilities, environmental protection and wildlife authorities. The study was commissioned by and paid for by the developer with a commercial interest in this site, hardly an uninterested party. Not least are the issues surrounds drainage and flooding risks, SUDS designs and expectations. Nor is it clear who would be held responsible for any future flooding or environmental damage and how they might be sanctioned in the event of any failure of these measures.

One can foresee major disturbance to the land under development during the construction phase before these mitigating facilities can be put in place. There is, therefore, a serious risk of permanent environmental damage and wildlife disturbance not only on this site but the surrounding sensitive areas. These could never be corrected and the developer would have built his houses anyway. It is especially concerning that certain sections of the Ecological Appraisal have been redacted - why? By whom? With what objective in mind? This should be investigated and the public made aware of the reasons for this.

Wider local impact:

The road system, local services and infrastructure around Little Common are already due to be overloaded without the added burden which BEX9/BX116 would bring. The doctors' surgery is always packed (the new one proposed for Barnhorn Green having been abandoned), the school is over-subscribed and there are no secondary schools nearby.

It is a widely held view across the whole Bexhill district that the A259 is wholly unsuitable for the traffic levels passing through Little Common and Bexhill overall. Much of it is through traffic which must use the A259 as the only major east-west route along England's south coast. If anything, the new Bexhill-Hastings Link Road has added to traffic pouring through Little Common as it provides an improved route for traffic aiming to (partially) bypass St. Leonards and Hastings. The much talked about Bexhill bypass comes to mind in this context - linking the NBAR to the A259 west of Bexhill would alleviate some of this traffic, not to mention bringing a huge area for further housing and business development into play.

There are few local (in Little Common) employment opportunities for the envisaged residents of Barnhorn Green, not to mention BX116, so it can be certainly assumed that these working residents will use their cars to go to/from work and that parents will drive their children to the (overloaded) Little Common school or elsewhere. Surveys have shown that the A259 is already carrying traffic levels which were forecast not to be reached until 2028.

We have learnt that no recent air pollution monitoring has been taking place along the A259 in Little Common (though a lamp-post mounted unit is soon to be installed). The lack of any current knowledge of existing air pollution levels is disturbing, given that RDC has already approved substantial new development projects in the area and is anticipating even more - without apparent regard for this serious, health-related issue, and doubly serious considering the increased proportion of children these proposed developments might bring to the area. It is already planned that traffic lights be installed on the A259 for an entrance serving Barnhorn Green which will create yet more standing traffic along that busy road.

The northern end of Cooden Sea Road is currently a free-for-all illegal car park, while the Pay & Display car park behind St Martha's church stands mostly empty, and this is before Barnhorn Green comes into being. Even more housing development in this very congested area will make life insufferable for residents, both current and future. Enough is enough.

Development creep

We have concerns about the longer-term risk of "development creep". BX116 lies adjacent to other sites which were considered for development (BX51, BX109, BX115 & BX61). These have been ruled unsuitable, often due to recognised flood risk (uncontrolled drainage from BX116?) and for the sake of views from elsewhere in the area, mainly from the west and so judged to be "out of character" with the local area. We believe that the current assignment of these sites to the unsuitable category would be put in jeopardy if the BX116 development took place. There would certainly be further pressure from land-owners and developers keen to cash in on the sprawl that an extended development south of Barnhorn Road would facilitate. If BX115 and BX108 are precious and worthy of protection to preserve the area's "character", then so too should be BX116. As they say in the sales: When it's gone, it's gone.

I am a member and strong supporter of the Spindlewood Action Group - SPINDAG -whose members have conducted extensive research, held public meetings and surgeries amongst local residents and found the vast majority of respondents to believe this proposed development to be wholly unnecessary and undesirable. We ask that it be removed from the second DaSA consultation process and not to be considered for any future development.

Transport Strategy & Economic Development
BEXHILL Page 128

-Policy BEX9 Land off Spindlewood Drive, Bexhill

BEX5, 6, 7, 9, 10 will be taken into consideration when a cycle network for this part of the town is being developed.

Transport DC

The County Council's Transport Development Control team has previously provided comments on the assessed sites and preferred sites that appear in the DaSA. This has been primarily through the site assessment process (generally the SHLAA). We are aware that the planned levels of development and the broad distribution has already been set out in the Rother Core Strategy.

Aside from the site subject to Policy BEX4 (see below), we are content that our previous comments and concerns have been suitably addressed both in terms of the sites identified as preferred sites, and the relevant policy criteria that would apply.

We are aware that concerns have been raised by local residents, in terms of the potential impact upon the local highway network as a result of the proposed housing allocation at Spindlewood Drive (subject to Policy BEX9). However, based on the supporting transport evidence we are content that the proposed allocation can be considered acceptable in terms of its impact upon the local highway network that falls within the jurisdiction of East Sussex County Council. The traffic impact upon the strategic network (A259) will also need to be considered, but this will be for Highways England to do. We do recognise that certain mitigation measures are likely to be required, such as potentially restricting parking along certain parts of Meads Road, but we would expect these to be identified, agreed and implemented at the formal planning application stage.

Landscape


BEXHILL Page 128

Yes to all Bexhill development polices

Archaeology

Please note that for most answers in this section a Red, Amber or Green rating has been assigned. In providing these responses, regard has been had to paragraph 169 of the NPPF. We are of the view that in order to satisfy this part of the NPPF, some of the proposed site allocations should be subject to archaeological assessment prior to the Pre-Submission version of the DaSA being published - these particular sites are identified below. For all the proposed allocations there will be a requirement for the subsequent planning applications to satisfy paragraph 128 of the NPPF.

BEXHILL Page 128

-Policy BEX9 Land off Spindlewood Drive, Bexhill

The site has high potential for prehistoric and Roman archaeological remains, so should be subject to archaeological assessment before being allocated.
-AMBER

Ecology

BEXHILL Page 128

Yes