As a charity working to ensure that everyone enjoys the pleasures and benefits of walking, Ramblers urge Rother Council to provide safe, smooth, step-free Walking, Wheeling and Cycling routes for all communities, with particular priority given to Deprived Urban and Rural Areas. All such routes should optimally be four metres wide.

We support this policy, particularly point iii.

Sport England supports this policy

Please see attached comments from Burwash Parish Council.

Please refer to attachment

Full representation attached.

Individual comments made on specific policies as logged

Full representation attached

Full submission attached.

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

Support for representations made by Ticehurst Parish Council.

Individual comments made on specific policies as logged.

Please also see attached a draft policy for Bewl Water drawn up by the Northern Parishes Group.

Please see attachment

The Kent County Council (KCC) Public Rights of Way and Access Service ('the Service') has been made aware of the Rother Draft Local Plan 2020 - 2040 ('the Plan') at its Regulation 18 consultation stage. As a neighbouring authority, the Service has reviewed the Plan and offers comments as below.
As a general statement, the Service is keen to ensure its interests are represented with respect to its statutory duty to protect and improve Public Rights of Way (PROW) in the county. The Service is committed to working in partnership with local and neighbouring authorities, councils, and others to achieve the aims contained within the KCC Rights of Way Improvement Plan (ROWIP) and the KCC 'Framing Kent's Future' strategy for 2022-2026. KCC intends for people to enjoy, amongst others, a high quality of life with opportunities for an active and healthy lifestyle, improved environments for people and wildlife, and the availability of sustainable transport choices.
Rother District lies in East Sussex and borders the Kent districts of Ashford, Folkestone and Hythe, and Tunbridge Wells. Although outside of Kent, it is felt appropriate to offer comments of a general and informative nature on this Plan given the high likelihood of cross-boundary interactions in the event sites in close proximity to Kent are in future proposed and developed, which could impact on and hopefully enhance access for both Rother District and Kent residents.
1.
The Service notes the Plan does not presently propose site allocations, preferring to first consult on the development strategy and draft Housing and Employment Land Availability Assessment. When sites come forward in due course, the Service will expect to be consulted where access need for future site residents or other occupants could impact existing access facilities in Kent.
2.
The Service notes the Plan's Vision (p19) gives a high profile to 'walking, cycling and public transport' to access facilities and services, and to the need for 'enhanced health and wellbeing'. These statements are welcomed as they provide considerable scope for the PROW networks of both East Sussex and Kent for positive partnership working to Rother District's future.
3.
Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) (p73). It is proposed future major residential proposals will need to ensure Active Travel Infrastructure either by infrastructure delivery or a financial contribution, the timing of which is significant and requires mention, as infrastructure should be provided prior to occupation.
4.
Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) (p73). Recognition of the King Charles III England Coast Path National Trail is welcomed, not least for the wellbeing benefits it delivers to residents and visitors.
5.
Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) (p73). In designing and delivering future new routes, or perhaps upgrading existing facilities, various design guidance is given. It is quite likely the ESCC PROW Service has its own guidance which, as it is the local highway authority, should be recognised; for example, the ESCC ROWIP.
6.
Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) (p73). The proposal to upgrade existing or provide new PROW could be a welcome benefit for both Rother District and Kent residents and visitors. For example, creating new bridleways around Ticehurst and Flimwell that link to the existing (Kent) bridleway network in Bedgebury Forest would not only offer local access benefits but also link to the Wealden Cycle Trail connecting Ashford and Tunbridge Wells. It is recommended any changes to the existing PROW network are undertaken in conjunction with the ESCC PROW Service and ourselves, given the legal processes involved and the need to ensure continuity of standards 'on the ground'.
7.
Vision for the Countryside (p164). The ambition for the countryside and coast to have improved access is supported. It is not specified how this is to be achieved; cross-reference to Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) is suggested.
8.
Proposed Policy HWB1: Supporting Health and Wellbeing (p198). Recognition that access infrastructure can be a key factor in improving and maintaining communities' and individuals' health and wellbeing supports the Service's own view.
9.
Proposed Policy HWB5: Green and Blue Infrastructure (p211). PROW are generally considered an important part of Green Infrastructure, which should be given more clarity within this policy.
10.
Proposed Policy HWB6: Public Rights of Way (p215). The protection of individual PROW and the enhancement of local access networks impacted by proposed development is welcomed. Reference to 'Active Travel' could enhance understanding of this aim. One means to achieve the policy aim is to up-grade the status of Public Footpaths to Public Bridleways, so extending lawful use to cyclists, which can be achieved at comparatively small cost to road network enhancements. Rother District Council is recommended to consult with the ESCC PROW Service on this Policy.
11.
Proposed Policy INF1: Strategic Infrastructure Requirements (p223). As an adjunct to comment in point 3 above regarding the timely delivery of infrastructure so as to establish cultural change in access modes, this Policy and the requirement to deliver new infrastructure 'upfront or early in the development phasing' is welcomed. It is expected this will extend to infrastructure improvement in Kent where this is identified and agreed.
12.
Proposed Policy HOU18: Boundary Treatments and Means of Enclosure (p309). Bullet point 3 on p310 acknowledges 'public footpath or bridleway'; it would be clearer to replace with 'PROW' given a Restricted Byway or Byway Open to All Traffic could conceivably run adjacent to any site.
13.
Proposed Policy ECO10: Equestrian Developments (p351). The proposal to, ideally, site new development close to 'the bridleway system' would likely assist users' and local safety. The ESCC PROW Service should be consulted, and its comments carefully considered before finalising this Proposed Policy.
14.
Glossary (pp440-453). The Service supports the use of a comprehensive glossary, enabling readers who are not familiar with terms used within the Plan to more clearly understand the Plan's ambitions and means. For this reason the Service considers the Glossary should be revised as follows:
A.
'Active Travel': the definition offered within the Plan differs to that adopted by KCC - this can be found at https://www.kent.gov.uk/about-the-council/strategies-and-policies/service-specific-policies/roads-paths-and-transport-policies/active-travel-strategy; the definition should therefore be confirmed with ESCC.
B.
'Infrastructure': this acknowledges 'footpaths'; however, use of the broader term 'PROW' would enhance recognition of the need for improvement across wider access infrastructure;
C.
'PROW': a definition should be included for clarity and understanding. The Service recommends 'PROW is the generic term for Public Footpaths, Public Bridleways, Restricted Byways, and Byways Open to All Traffic. Each are public highways, similar to public roads, and are for public use at any and all times unless formally closed by the relevant local highway authority.'
In closing the Service adds that any future development proposals should reference NPPF Policy (as it then exists). Presently the Service would draw attention to:
•
NPPF (December 2023) para. 96: 'to achieve healthy, inclusive and safe places', which specifically encourage social interaction, minimise crime and disorder and the fear of such, and enable and support healthy lifestyles.
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NPPF (December 2023) para. 97: to 'plan positively for the provision and use of shared spaces... support the delivery of local strategies to improve health, social and cultural well-being...guard against the unnecessary loss of valued facilities and services...and ensure an integrated approach to considering the location of housing, economic uses and community facilities and services'.
•
NPPF (December 2023) para. 102: to be 'based on robust and up-to-date assessments of the need for open space, sport and recreation facilities ... and opportunities for new provision.'
•
NPPF (December 2023) para. 104: 'Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.'
•
NPPF (December 2023) para. 108: 'Transport issues should be considered from the earliest stages of plan-making and development proposals, so that:
...
c) opportunities to promote walking, cycling and public transport use are identified and pursued
...'
•
NPPF (December 2023) para. 110: 'Planning policies should:
...
b) be prepared with the active involvement of local highways authorities, other transport infrastructure providers and operators and neighbouring councils, so that strategies and investments for supporting sustainable transport and development patterns are aligned;
c) identify and protect, where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen transport choice and realise opportunities for large scale development;
d) provide for attractive and well-designed walking and cycling networks with supporting facilities such as secure cycle parking (drawing on Local Cycling and Walking Infrastructure Plans);
...'
•
NPPF (December 2023) para. 116: '... applications for development should:
a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;
b) address the needs of people with disabilities and reduced mobility in relation to all modes of transport;
c) create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards;
This response is made on behalf of Kent County Council Public Rights of Way and Access Service. The views expressed should be considered only as the response of the County Council in respect of public rights of way and countryside access matters relating to the Plan.
Yours sincerely
Kate Beswick
Countryside Access Improvement Plan Officer
Public Rights of Way & Access Service

Please see attached submitted document for full comments.