Please see attached comments on draft Local Plan, including Brede Valley Landscape Assessment and East Sussex Landscape Assessment.

Parking is not to be seen as a means of raising money. This should be policy.

I think that in a rural area like Rother with limited public transport the concept of people not having parking with a new development just places additional pressure on existing parking areas and will ultimately cause road congestion. In rural villages where there are no road markings (or police ) parking is already a problem for houses without parking. This increases the risk of accidents. Parking in rural developments must be factored in with provision for residents AND visitors.

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.

Please see attached comments from Burwash Parish Council.

Please see attached full submission from Nexus Planning on behalf of their client Devine Homes regarding the Local Plan and HELAA Site SAL0012: Land at Bishops Lane, Robertsbridge

Full representation attached

Full submission attached.

Please see attached document for the full submission from Westfield Parish Council.

See attached full representation

Please see attachment

Please see attached submitted document for full comments.

Please see attached submitted document for full comments.

Please see attached submitted document for full comments.

Please see attached submitted document for full comments.

Please see attached submitted document for full comments.

Please see attached submitted document for full comments.

Please see attached submitted document for full comments.

Thank you for forwarding this document: below are our comments on policies - together with a supporting rationale.

2.13
Q2, Q3
Agree the principles embodied in 2.13.

 A ’green to the core’ approach should deliver better ‘living spaces’ for children and future generations.
 Compact and less ‘car dependent’ developments should flow from this with a strong emphasis on exploring and expanding ‘active travel’ opportunities and integrated public transport measures - bus/rail.
 The greatest efficiencies will fow from integration of ‘transport’ and ‘land use’ policies that will secure benefits for public health (both mental and physical), environment, social equity, economy - while addressing the twin crises facing biodiversity and climate change. Perhaps the greatest benefits would accrue from ‘traffic reduction’.
 We welcome the very sensible approach of having a joint statement from Hastings BC and Rother DC (the ‘wrap round’ authority). The future ‘district-wide’ and ‘neighbourhood’ infrastructure should include and prioritise sustainable/healthy modes of transport with incentives to use them and with an objective to reduce numbers of vehicles. Successful delivery also requires close working with the Transport and Health authority - ESCC.
 Good publicity to apprise residents, visitors and tourists of non-car modes available to access attractions should be standard - it currently is hugely variable from the useless through mediocre to excellent: it should be standard practice that sustainable transport opportunities are featured in well designd and attractive publicity material.


Q4 Q5
Agree principles. Opportunities that arise from reducing traffic (numbers of vehilcles) would include alternative use of land for a multitude of purposes including housing/nature /acquifer replenishment/childrens’ play/economic activity.

Q6/7/8
Given higher standards are ‘coming down the track’ and that we have a new national administration we might hope for re-energising/accelerating more ambitious energy saving solutions so RDC and all of us might well be prepared (and wish for ) a more nimble approach to delivery of ‘best available’ practice.

We note that although a building or larger housing development may be high performing, if it remains ‘car dependent’ it can hardly be described as sustainable.

Q9/10

Support ambitions for ‘retro-fit’ standards. Reduced car use/increased sustainable mode take-up would free land in existing settlements if provision is made for pedestrian/cycle/bus/train facilities.




Q17/18/19

Support expansion of solar/wind generation subject to landscape/heritage considerations. Rooftop solar is perhaps less obtrusive.

Q20/21

Welcome the focus on ‘nature recovery’. 3.39 recognises that securing ‘designated sites’ is insufficient as a means to securing recovery: the wider countryside (and well managed urban areas too) are crucial if populations/species are to thrive. We note that some areas with notional protection (for example semi-natural ancient woodland of which the HWAONB/HWNL has much) is nibbled away at so needs greater protection and monitoring. The entire east Rother catchment with its many streams also needs protection and monitoring.

Q22/23/24

Yes, go above minimum; developers’ intent to create compensatory gains against damage to existing habitat has to be independently assessed by a third party and monitored over time. Noise and light impact should be taken into account.

Q25/26

I have an interest in the HWNL as I am the owner of 6.02 acres of semi-natural ancient woodland (Fleetwood) and grew up in Etchingham between the Limden and east Rother. It was a wonderfulplace in which to spend my childhood. I accumulated quite a bit of knowledge - flora, fauna, geology, secret places and much of this was on my daily walk to school and back. Much of this environmental capital is intact but the lanes are no longer tranquil or safe places to be and the growth of traffic now limits childrens’ opportunties to learn and therefore love what’s there. Lanes have chewed up verges and ruts - restricting refuge - and taking away childrens freedoms. Add to this the sheer power and size of vehicles and the knowledge that mobile phone use while driving is endemic, the HWNL has suffered and quality of life diminished. Noise is often present with driving styles on two or four wheels tailored to maximise it: the noise footprint is up to two miles in radius. The HWNL is still beautiful but tarnished. It’s not OK. The Plan might usefully attempt to address these issues via its officers and elected members.

In the past, the High Weald Heroes inititiative to apprise its children of the elements that make it special seemed to be a good scheme and might now be expanded to include partnership schools in urban areas to spread the understanding and appreciation of such elements more widely so as to recruit more guardians of the future. Education initiatives could be included in the Plan. Health benefits would accrue, particularly for mental health.

In terms of offering safe walking/cycling family holidays, the HWNL doesn’t perform nearly well enough. Bus and rail connections have improved a little through BSIP but not enough. Adding Eurostar again to access via Ashford would help. Bus rail integration south of Tunbridge Wells is under exploited.

Q27/28/29

Agree with principles and threads.

Q33/34/35/36/37/38

Agree with principles. Flared junctions should be avoided. Cycle/pedestrian priority across junctions should be adopted aas policy. Cyclops style roundabouts should become much more commonly adopted as standard.

Q39/40/41

Agree with principles. 20mph default speed in residential streets and streets with strong character/heritage value would all be safer. Burwash example.


Q42/43/44

Agree with principles.

Q45/46/47

Agree with principles. Stimulating and supportive of social cohesion/mental and physical health objectives. Traffic must not dominate. Conversation is ioften impossible if traffic/vehicle noise pervasive.

Q48/49/50

Too much parking is simply more unnecessary road space: there will be induced traffic. Hard standing can contribute to flooding and denies the acquifers natural replenishment.

Q51/52/53

The ‘A21 development corridor’ presumes the road as the key to likely development sites and suggests road based accessiblity will therefore be key to any development’s success. That sounds a little like ‘business as usual’ However, it can’t be allowed to mask under and unexploited opportunities for movement of people by bus and rail and more locally by electric/conventional cycle and via good, safe pedestrian and cycle links.
The first Multi-Modal Study (2000) found that 68% of traffic on the A21 in the morning peak originated from south of Tunbridge Wells. It would be prudent to examine the potential for bus links to and across the Charing Cross - Hastings railway line to broaden the footprint of public transport accessibility. For example, the A265/268 could give access by bus to the train at Etchingham for Hawkhurst - Hurst Green and Burwash residents/visitors/students. This could also reduce car dependency in any village expansion developments, moreso if accompanied by supportive parking policies in urban centres. Your plan envisages the possibility of a future with less land given to car parks (and hopefully an end to free parking). This could follow future road user charging in whatever form it eventually takes.

Cars are getting bigger. Edge of town developments often feature generous parking spaces and these are often occupied by large SUV type vehicles. We strongly feel that these vehicles are not compatible with high quality living spaces and that there should be strong disincentives aimed at reducing their often intimidating presence in our streets and country lanes and anywhere near our schools.

Q54/55/121

General points:

There should be a strong component of public housing for rent; a strong component of truly affordable housing; a comprehensive cycle network that includes chldrens’ routes to school; 20mph default limits in all residential streets and dsitributor roads where appropriate (it will sometimes be appropriate). An absence of flared junctions and ‘cyclops’ roundabouts if a roundabout is deemed necessary.

Bus services under the new administration can be franchised by the transport authority. There could be some creative dialogues around services that RDC/ESCC feels might be improved by new/enhanced or extended routes.

It remains to be seen whether or not developers will still be able to renege on agreements around any form of planning gain. New policies will emerge that might benefit the community.

Q71

The ‘A21 transport corridor’ can only be examined as a multi-modal study. I already commented at Q53 but would add: there’s no bus connection between Etchingham station and Hurst Green which is a problem for locals (Management of The George - Ruth Hardy: theroyalgeorge@gmail.com).

Q72

Rother’s outstanding countryside is impaired by too much traffic with its associated negative impacts not the least of these being noise. The ridges and valleys are features that give much joy: it is hoped that the streams and rivers are unpolluted but reassurances are needed. In the case of the locally important Conquest Hospital, buses are severely delayed by queuing cars blocking access to the hospital entrance from The Ridge.


Q80

Sustainable transport provision should be designed with cumulative impacts and needs of neighbouring developments in mind. Not sure this has happened in north and West Bexhill (bus delays between Little Common and Northeye suggest that priority measures could have been installed ahead of development).

Q93

The ‘cooling effect’ of trees/shade and planted areas within urban settings is known and should be a factor in development plans, along with rainfall retention against flood risk.

Q98

Agree importance for young and old to have access to community facilities. Youth clubs’ demise has left a gap. These should be accessible by public transport/foot/cycle.

Q 104

Agree public rights of way/cycle routes hugely important for utility and leisure/education functions. These can afford great days out and should be part of the tourism leisure strategies and publicised in conjunction with public transport access in mind.

Q107

CVCP straddles the Bexhill - Hastings Link Road. Tranquillity has been lost to a large extent, but a 40mph speed restriction and acoustic cameras to deter noisy two/four wheeled vehicles would go some way to conferring on the valley some of its lost charm. The nationally important Bronze Age site seems to absent from any publicity.