Q1.

Sadly the vision feels unachievable. Rother Officers avoid dialogue or face to face contact with some residents, who as a result have little trust in RDC’s integrity and competence. Disillusion with poor quality planning includes perceptions of cronyism and corruption. How will an infrastructure baseline be established? For example “Sensitive, sustainable and well-designed development that meets local housing and employment needs will be complemented by the timely delivery of supporting infrastructure.” RDC should revisit past developments that fall short of this criteria, where community complaints have been high. In Fairlight Cove we’ve lost amenity for 2 years caused by a poor quality, cramped, steep development of 16 houses. Residents dispute it’s built to the planning consent approved on appeal by the Planning Inspectorate. Storm overflows cover the lane with sewage, before the 16 new houses are even connected. A resident survey describes the gridlock of parked vehicles on our bus route, obstructing junctions and folk struggling to get on/off their driveways. Over decades there appears to have been no imaginative attempts to meet village overflow parking needs. For example removing wide grass verges to create parking spaces. We can’t see strategic joint working by RDC with our Parish Council. Our precept has increased by 40% in the past few years without extensive consultation and Parish Councillors spend our tax on their high running costs, meetings and social projects for retired people that duplicate existing locally funded voluntary sector provision by professional staff. Accountability and evaluation systems are lacking for Parish Councils to maintain infrastructure. Parts of Fairlight are lanes with high numbers of walkers, no pavements or footpaths, very few seats and signage clutter. A baseline study would show village assets in poor repair, with an increase in vehicle movements. Parking and speeding are increasing problems. Results from the 2023 Parish Council Residents Survey are not in the public domain. In relation to ‘Quality of Life’ residents regularly state a priority is public toilets. The decision by RDC to not cover the cost of public toilets at our local beach and in Rye indicates how removed you are from meeting basic expectations and needs of your residents, visitors to our area and local businesses.

Q2.

‘Conserving and enhancing the significant landscape and environmental quality across the district’ It would help if RDC insisted on professional quality Construction Management Plans or contractors signed up to the ‘Considerate Contractor’ Scheme. Also if RDC Enforcement Officers were resourced and supported to penalise construction sites in the same way they penalise residents or local builders, especially for radios, drug use and aggressive behaviours on site. Planting Management Plans and TPO’s are ignored, trees and hedgerows are cut, with no apparent penalties. Residents are encouraged to provide free labour to report alleged breaches of planning consent, but then Developers break the rules with impunity. The perception is that Rother Officers are too close to Developers, whilst being unwilling to meet with residents. There appears to be no monitoring of what the CIL funds are spent on in parishes in relation to the exisiting Local Plan and no minimum standard of “community consultation”.

Q3.

‘By supporting strong, safe and sustainable communities’ In Fairlight Cove there is a minimal bus service, which unfortunately can be disrupted at very short notice by road closures. Leaving school children or people without mobile phones disorientated and abandoned. Plus there is poor access to travel around our village for people with disabilities. There appears to be no baseline of how many village roads are difficult to use for disabled people, due to issues such as rough surfaces/moonscapes, pavement parking, cracked pavements or speeding traffic. New charges for car parks across RDC and HBC means people now drive into Fairlight Cove to park for free and some camp overnight outside residents homes. HBC is commonly perceived online as having corrupt working practices in relation to planning and development sites.

Q5.

SO 9 feels very important, but unless there are new initiatives in villages, there appears to be no resources to make this happen. It is difficult to get a face to face appointment at Hill Surgery, Hastings, few people can get through to reception. For people on low incomes, without a computer or mobile phone it is especially hard.

Q.27

There seems to be an opt out clause on Density. There seems little point in having policies, if you then create ways for property developers not to meet them.

Q.33

LWL3 Facilities at bus stops and iii Coastal Access This would be very important if it could be implemented.

LWL5

We welcome these policies in terms of height and steep sites, for example if a village is predominantly small low dwellings, very tall buildings stand out. For example at the entrance to Fairlight Cove and in the “transition” of the new Market Garden Site to the south.

LWL6

We welcome these policies in terms of height and steep sites, for example if a village is predominantly small low dwellings, very tall buildings stand out. For example at the entrance to Fairlight Cove and in the “transition” of the new Market Garden Site to the south.

Q45.

Streets For All. We welcome the shared streets policy especially “street furniture, good signage and way finding that is accessible to all to encourage walking and prioritise vulnerable users.” It would be beneficial to identify who currently lives in a ‘street’ or a ‘road’ and whether 4.62 SUDS and 4.64 could be implemented across the District. If RDC had clear design standards and guidelines, this would help Parish Councils who may not have access to professional expertise in planning. Community pride and cohesion is undermined by dirty and deteriorating infrastructure, Pett Level Road, Pett Level Toilets, Highways Pavement repairs, Southern Water sewage etc

Q.48

RDC needs to work with Parish Councils to create Parking Strategies for villages where parked vehicles now dominate the public realm, block footways, crossing points and sight lines.

Paragraph 5.16

Quiet Lanes and Slow Ways should be introduced on the 1066 walk and popular coastal footpaths as a priority.
This is a key issue for Fairlight enabling all generations to stay in rural communities for their lifetime and a source of frustration that new homes have not addressed the housing needs of local residents.

Q.54

The notion of “Hastings Fringes” feels unclear and ‘sensitive growth’ lacks a number, clarification would help.

Q.59

We object to the notion that a minimum of 35 dwellings in Fairlight is “sensitive” growth, we assume the site is East Field. This has been contested so many times over the years and the Field continues to flood, the sewage continues to overflow on Lower Waites Lane and Stream Lane. The increased traffic puts enormous pressure on village lanes which are in a poor state of repair. Pett Level Road is unpassable during the evening time due to the size of the pot holes. Access to a Post Office, Doctors Surgery and Dentists is limited.

Q.72

“Including the undeveloped coast, also has high intrinsic amenity value and is an important resource for nature conservation, leisure and tourism.” This would be more convincing if Pett Level Road were usable as a road, the moonscapes by the road side could be used for parking and the public toilets were open throughout the year.

Q.82

DEV3 The development boundary concept sounds confusing. If Fairlight Cove has a development boundary in the Local Plan surely the boundary of Waites lane is facing the ‘countryside’. Therefore an allocation of East Field for 35 houses would not meet the policy?

Q.90

DEV6 The Strategic Green Gap between Fairlight and Hastings is warmly welcomed, as are all the Gaps in the Plan. There are regular incidents where large vehicles e.g two buses/lorries etc get wedged along the narrow lanes travelling east along Fairlight Road which is claustrophobic and parked vehicles dominate. The areas open character feels essential to demarcate the start of the countryside.

Q.101

HWB5 Green and Blue Infrastructure
There is no minimum length for new development to be built away from a water course. In the case of the Market Garden Site in Fairlight, three new builds are on the banks of the stream and the earth has subsided as a result.

Q.102

A minimum precise measurement length should be insisted upon for all new developments near a water course. There is also no clear mention in Construction Management Plans for Site workers not to litter or pollute a water course. Also to store construction materials such as water proof insulation, glass etc a few metres from the edge so as they don’t fall into the water course.

Q.123

HOU5 Rural Exception Sites
This feels like another ‘get out’ clause. There is no clarity as to what RDC mean by “meaningful community engagement” If RDC has any examples of how this had worked in practice that would be helpful. Otherwise it could be removed.

Q.129

HOU8 Access to Standards Paragraph 8.72 This feels like another ‘get out’ clause

Paragraph 8.137

ESCC parking guidance is an under estimate, for the number of people who actually use a garage. The number of cars owned per household in rural areas and the fact that most dwellings have visitors and delivery vehicles. The car parking spaces are mean on new build developments, causing parked vehicles to over flow onto rural lanes and bus routes.

Q.144

”… private rear garden spaces of at least 10 metres in length will normally be required, other than in exceptional circumstances where this cannot be achieved in an otherwise acceptable development” We strongly object to the wording and opt outs within this Policy. At the Market Garden Site in Fairlight residents allege the 10 metre gardens have not been created. Allowing flexibility on the 10 metre rule makes a mockery of it being a Policy. This allows for Developers to erect cramped buildings on irregular and sloped sites. This is very disappointing. Similarly the policy can be avoided if “future occupiers of the dwellings will have a lesser requirement for amenity space” How can this be proven if properties are sold on the open market, another loophole for allowing dwellings with low amenity. It leaves little room for outdoor washing lines which have an environmental impact if clothes is dried indoors. Also the capacity for play equipment, to plant veg/fruit trees, store bicycles/canoes etc. We object to 8.136.

Q.146

The Policy is inappropriately flexible. Getting away with squashing the tiniest housing units onto a plot seems to be the game for a few Developers and RDC are encouraging it with this type of policy.

Q.166

Like most of our responses our comments relate to balancing new developments with maintaining infrastructure or improving strategic working with ESCC or Parish Councils. If the majority of visits are day trips then the issue of parking, overflow parking and public toilets remain very high on the list of problems to be addressed, which currently fail to meet customer expectations. The poor state of ESCC roads is a major factor in putting off visitors.

Q.180

LAN1 This is very important, especially to the undeveloped coast.

Page 356 (ix) The failure of RDC to stop Developers clearing trees and hedges is depressing.

Q.191

ENV 4 Fairlight Cove Coastal Change Management Area is important to support the work of the Fairlight Preservation Trust.

Yes achieve the objectives by redeveloping out of date building stock, knock down and rebuild dont keep building on greenland and farmland just because its cheaper

Please see attached representation, existing and proposed sites plans.

Please see attached:

- Draft Local Plan Representations
- Site Location Plan
- Existing Site Layout Plan
- Call for Sites Illustrative Layout Plan

I should like to see specific references to building standards in terms of solar energy, insulation etc, water and sewage management, and build quality enforcement.

Southern Water is the statutory wastewater undertaker for the Rother district and the water supplier to parts of the district. Southern Water would support additional climate change objectives that take account of flood risk, enhancing the general policy direction in the draft Plan along the lines of:
• taking account of flood risk and coastal change through development design (as well as location);
• stronger integration of sustainable drainage solutions, to help minimise and control surface water run-off, provide flood storage capacity and improve habitats
• incorporating green infrastructure to help reduce climate change impacts such as flood risk and the overheating of urban environments

As paragraph 2.2 of the draft Plan states:
RDC has declared a climate emergency and this is the defining issues of our times. Local planning authorities have a legal duty to ensure that planning policy contributes to the mitigation of, and adaptation to, climate change.

Paragraph 3.2 goes on to describe this to mean that ‘local plans must set out the district’s baseline carbon dioxide emissions and the actions needed to reduce emissions over time’. However the impacts of climate change also include more extreme weather patterns with associated increases in flood risk from severe storms. Also, paragraph 167(c) of the National Planning Policy Framework (NPPF) (2023) requires:
167(c) using opportunities provided by new development and improvements in green and other infrastructure to reduce the causes and impacts of flooding, (making as much use as possible of natural flood management techniques as part of an integrated approach to flood risk management)

During heavy rain, local sewer networks’ drainage capability can be exceeded by the amount of rainwater entering pipes and storage tanks connected via roads, roofs and paved areas. When these fill up, storm overflows release excess water through outfalls into rivers and the sea to prevent flooding of homes and businesses. Storm overflows are part of the network’s original design and are regulated by the Environment Agency. Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering sewers, resulting in increased releases from storm overflows. As stated in Water UK’s 21st Century Drainage Programme;
“The country’s built environment is constantly changing and “urban creep” – home extensions, conservatories and paving over front gardens for parking – can all add to the amount of water going into our sewers and drains. Green spaces that would absorb rainwater are covered over by concrete and tarmac that will not. In fact, studies show that “urban creep” results in a larger increase in predicted flooding than new housing, because it adds more rainwater to these systems’.

As paragraph 5.1 of the Local Plan references, the National Planning Policy Framework requires all local plans to promote a sustainable pattern of development that seeks to; improve the environment, mitigate against climate change and adapt to its effects. Please see our policy statement on Sustainable Development here:
https://www.southernwater.co.uk/media/ny0nb3qu/our-policy-statement-on-sustainable-development-a4.pdf

As acknowledged in the plan, more resilient and efficient homes are essential – conserving both energy and water. However, with the impacts of climate change we are already seeing, we need better design to help control the rate and volume of surface water run-off, and as noted in the local plan, SuDS can improve existing flood risk as well as water quality.

Southern Water is working across our region to remove surface water from our networks in key areas. Even as we deliver this work, development continues to increase surface water run-off. For more information on our work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force

The Vision, Priorities, Objectives and Issues are sensible but, for the very great part of Rother, achieving them will require the council to use all its powers and levers to improve the existing built fabric, not just their ability to influence planning applications for entirely new development. This applies to the whole of the built environment including in particular, as the standards of new development state, the way in which residential safety and amenity, health and wellbeing and environmental improvement is affected the design and management of the road system and the impact of such factors as speeding through traffic. How the implementation of the plan will enable improvement to the existing fabric and the best response to the considerable challenges presented in the background papers on Infrastructure and Economy, and in the separate State of the District Report, could be made fuller and clearer.

The client considers the overarching objectives to be acceptable. However, we would suggest that a quantifiable housing target should be implemented within these objectives. As mentioned above, there is an identified housing need of 737 dwellings per annum and a history of underdelivering on housing. A target should specifically be included within the overarching strategic targets for the new local plan.

Please see attached comments from Burwash Parish Council.

Please see attached submission.

Full submission attached.

See attached.

Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.