As a charity which opens the way for everyone to enjoy the pleasures and benefits of walking, and which protects and enhances the areas where we all love to walk, Ramblers welcome the proposed policy on Public Rights of Way.
PRoW are regularly threatened by building developments. Not only large developments can damage a PRoW - sometimes a single dwelling, new outbuilding or access route can impinge on a PRoW in a negative way.
Ramblers recommend that all planning applications are required to demonstrate explicitly how they will meet the Council´s policy where a PRoW runs through the application site, and/or where a PRoW runs in close proximity. Too frequently applications do not even acknowledge the existence of a PRoW - these in particular are plans to watch out for. There needs to be a robust checking process in place both during the initial application phase and in subsequent phases.

Please see attached comments from Burwash Parish Council.

Q2. Council feels that both are key to our Community with equal priority.

Q24. Clarification of "all qualifying development" is sought.
Council would like to prevent pre-emptive works at sites prior to submission of planning applications.

Q28. Agree the principle but very hard to visualise dwellings per hectare. Particularly when looking at rural areas.
Examples in our location would be helpful ie number of properties in Coronation Gardens per hectare, for example.


Q30. Whilst we feel this is a positive ambition, this may be impracticle for a town such as Battle.

Q33. In agreement with proposals, but clear access must be available. Blackfriars access to Battle Railway Station is a point in case of outside site access.

Q34. Council should make developers responsible for access outside site compulsory.

Q35. Applaud this objective but would once again highlight the Blackfriars development not having easy access to the Railway Station which would make walking outside of this 400m proposal.

Q39. This is an important policy and Council would like this enforced. However, it is disappointing that the Blackfriars development has not been approved in accordance with existing Battle Civil Parish Neighbourhood Plan policies.

Q46. Council feels that consideration should be to all disabilities, not only dementia sufferers; such as less ambulant people and those with hearing difficulties etc.
In relation to play areas, these should be sited in an appropriate safe, central location.

Q64. The topography of the central area of Battle town does not lend itself to significant further dwellings to be developed within the development boundary.
There may be very small opportunties for developments outside the development boundary but within the 800m constraint.
Broadly speaking, the number of dwellings suggested seems to be most unachievable.
During the development of the Battle Civil Parish Neighbourhood Plan, despite calls for employment opportunity developments, there was only one response.

Q74. These policies should be strictly adherred to, to protect the environment.

Q75. Subsequent to this Reg 18 document, Council would like to emphasise that the "Fir Tree Cottage" site at Netherfield only has temporary permission for three years and must be returned to agricultural use.

Q76. We do not agree that Battle is placed in the "Greater opportunities for growth" column in figure 35. In main part due to the topography of the Civil Parish and, at best, should be placed in the "Medium growth opportunities".
We are pleased to see that Mountfield and Whatlington in our SDO have been recognised in the column "Limited growth opportunities".

Q104. We welcome this policy.

Q116. For planning applications where affordable housing is approved, following applications to change the conditions will be greatly deplicated.

Q119. Council does not agree with this policy. There should be a mix of housing - 'pepperpotting'.

Q121. We do not wish to see this, as above.

Q183. LAN3 paragrpah 3 should have roof lights added as an example of discouraged glazing.
Planning applicants should be encouraged to use electrochromic glass.

Please see attached submission.

Full submission attached.

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

See attached full representation

Please see attached full representation

Please see attachment

Q1: Re: "1.7 The plan sets twin overall priorities (‘Green to the Core’ and ‘Live Well Locally’)" - I applaud the ambition, but am concerened to see, additionally, a clear statement that BOTH priorities are EQUAL, even if one has to written before the other.

Q6: This is a highly technical policy that really needs another section before ()A) for application to small developments, being undertaken without the benefit of highly qualified experts.

Q9: Agreed a good Policy

Q11: Agreed a good Policy

Q18: Re: "3.36 The opportunity for the development of wind turbines within the district, is extremely limited..." - I beleive very small scale wind power turbines down to single dwelling capability should be considered since technology could deliver economical useful machines within the timescale of this Plan.

Q22/23: RE: "All qualifying development proposals must deliver at least a 20% measurable
biodiversity net gain..." - understood but the metric for qualification is not easy to find?
Agreed a good Policy to go beyond 10%.

Q25: Agreed a good Policy

Q28: Re: "a. Urban areas in Bexhill, Battle and Rye: 60-90+ dph, with higher densities
around transport hubs and town and district centres.
b. Suburban areas in Bexhill, Battle, Hasting Fringes and Rye: 45-75 dph." - it is hard to understand the difference between Urban and Suburban, even with Fig 8? Until 4.15 work is carried out I reserve my judgemment on this Policy.

Q32: In essence a good policy, but some examples e.g. bank have long since gone even from towns within Rother so hardly an OK exemplar. I wonder if 800m is the right parameter - in my road many residents would get their car out for such a distance, few possibly only 20% would walk that distance.

Q33: Whist overall I agree this is a good Policy - I think it needs to be more clearly sectioned, maybe even several seperate Ploicies. Re: "g. Appropriate signage and wayfinding." -this has often or nearly always been overlooked - so a very welcome improvement.

Q35: I particularly like this policy and the 400m parameter, which of course certainly should apply to the Blackfriars development - so a major step forward if it is applied, since previously RDC has in effect only considered on-site access not off-site access.

Q37: I am concerned that no mention is made of former PRoW (FPs) being re-routed through development sites across multiple driveways; rather tah finding contiguous routings through or outside the site connecting to the existing network without having to contend with multiple drive crossings. Though see also Q104 comment.

Q38: Agreed about ixc) Shared Use Routes - the higher age range demographic deprecate shared use, due to (anecdotally) cyclists lack of concern for less ambulant walkers. Very little chance of people buy-in to Demand Responsive Transport, car clubs and car shares!

Q45: Agreed a good Policy; though I note: "inclusively designed so that people with visual, mobility or other limitations will be able to use the street confidently and safely.", so do not see why "iii) Dementia Friendly District" is highlighted, when it would be better to categorise as for example "those with reduced sensory perceptions and mobility"?

Q51: Agreed a good Policy. Crowhurst should be in the Battle SDO; whereas it may be better to exclude Sedlescombe for the battle SDO, due to the decisive split that the A21 causes and Sedlescombe fees more adjacent (connected) to Westfield. Quite evident in Fig 12.

Q62: Re: "5.56 Battle is a small, historic market town." Umm - not a good summary, it should be: "Battle is a small, historic FORMER market town.", since all banks now gone...

Q74: This policy area is so heavily over burdened by national and county council legislation and determination, I recommend the LP only provides for the minimal provision since there is nowadays negligible agricultural seasonal employment upon which much of the legislation appears to be based.

Q76: Fig 35/36 - I do not agree that Battle has " Greater opportunity for growth, since already the constraints discussed show minimal opportunity e.g. NPPF/NL conditions. Furtermore the employment locations expansion in Battle are, as the Neighbourhood Plan Calls showed, almost negligible and certainly not as RDC pushed for when the NP was being developed.

Q84: Agreed a good Policy.

Q90: It is hard to understand why the RDC/Inspector refused to allow the proposed Gap along the Hastings Road at Telham was not allowed in the Battle NP, given these arguments it would have enhanced the protection: "The Gap between Battle and Hastings/St Leonards provides an important function in maintaining the separate identities of Battle and the built-up area of Hastings/St Leonards. The break in the ribbon development between the edge of Telham and the Hastings Borough boundary at Breadsell Farm is highly vulnerable to change particularly in more open areas and the higher ground and ridges."

Q96: In view of the source of this Policy will it now be applied Rother wide?

Q104: Agreed a good Policy. I welcome this new Policy, especially the aspects regarding diversion of FPs within development sites be required to deliver "equivalent" access and "must be replicated" See also comment to Q37.

Q109: Agreed a good Policy.

Q112: Agreed a good Policy.

Q119: I do not favour "100% affordable housing schemes". Surely "pepperpotting" is a better solution?

Q121: Given my comment on Q119, I do not really agree with is Policy, however given the intent for "substantially affordable housing", I would accept the need could be so satisfied.

Q125: Agreed a good Policy.

Q131: I welcome further work on this need.

Q133: Agreed a good Policy.

Q147: I would like to see a strengthening to no permission would be given to changing natural boundary hedges and trees.

Q149: Conversions/extensions of an older wood construction building by using modern brick construction, for example, should not normally be permitted, since they would significantly alter the street scene.

Q153: Agreed a good Policy, however I do not agree that in 8.179 Laurel is preferred - it is too fast growing and likely to over burden other growth.

Q170: Agreed a good Policy. I particularly welcome "xi) Where practicable, the track is opened as a path for permissive public usage or as Public Right of Way, and should be accessible from the existing Public Rights of Way network", since this would make the applicant aware that they could provide a beneficial PRoW spin-off from their operations, not previously or normally offered.

Q178: Agreed a good Policy.

Q180: Agreed a good Policy.

Q182: Agreed a good Policy. Welcomed and for reasons of energy saving an emphasis on PIR use should be paramount.

Q195: Agreed a good Policy. But I am confused by this wording: "vi) For Ancient Woodland, create a development buffer zone of at least 15 metres. An impact assessment will be required where any development is proposed within 25 metres of Ancient Woodland to demonstrate that the proposed buffer zone avoids negative effects on the habitat.", since surely a single buffer zone of 25m would suffice?

Appendix 2: Surely "Market square including Jempsons shop and others should be considered as in the "Battle Town Centre and Primary Shopping Area", even if not contiguously connected? The south-eastern limit of the appears to miss out several shops/cafes of importance...

Q208: "proposed monitoring framework" appears to be a comprehensive methodology to adopt. but i wonder how it will be reported?

Please accept this response to your consultation on the draft local plan for Rother 2020-2040 as your online consultation webpage is difficult to navigate and I became totally lost in the bureaucratic jargon and only managed to reach page 260 before burn-out.

The Draft itself is difficult to decipher what is actually being said, requires much cross referencing with other lengthy, confusing documents and I have had to deal with this draft in a ‘bite-size’ manageable way so may well miss important points, which I hope others will pick up on.

In short, the summary of many hours of reading:
Housing should be confined to brown/grey field sites, in urban surroundings that can cope with the demands of contemporary living, before greenfield sites (especially the HWNL) are even considered.
The Local Plan does not set any limits on anything so cannot possibly have any value as a plan for sustainable development. Development with no limits is unsustainable.
Please provide a map of the development boundary for Catsfield. (For example page 224, DaSA adopted 2019). Maps like this provide clarity for the lay-person rather than struggling through huge documents such as the Draft Local Plan, the HELAA reports, HEDNA etc. but unable to locate any meaningful maps.


RESPONSE TO QUESTIONS:

Q2. What are your views on proposed twin Overall Priorities to be ‘Green to the Core’ and ‘Live Well Locally’?

I have to disagree that RDCs vision is achievable. On the face of it the vision appears to indicate a respect for the environment and the rural communities within, but simply introducing the word ‘green’ does not equal sustainability and, likewise, the word ‘well’ is simply subjective. Therefore, rather than slogans which are open to interpretation or challenge by developers with their eye on today’s profit not tomorrow’s generations, perhaps something a little less open to subjective interpretation would be better. Ie. Today’s priority is tomorrow’s environment. It is clear that we need to protect our environment, both natural and built, because we won’t get a second chance tomorrow. The High Weald National Landscape must be protected as this will be our legacy to following generations – this is sustainability. A climate emergency and protecting our National Landscape is in absolute contrast to the aims of profit-driven developers and speculators, so the question is, how will RDC make developers/speculators adhere to these twin priorities and share their vision?
Regarding Catsfield where I live: The proposed number and design of dwellings on CAT0001 and CAT0016 sites in the HELAA report is really too large for the rural character of the village to subsume into the settlement and should be decreased. Large housing estates will urbanise the rural character - already seen in Ninfield in Wealden district. Therefore, such large housing estates are neither ‘green to the core’ nor beneficial to residents.
Why has Catsfield been singled out to provide 60 new dwellings when other villages have a nil target? How is this figure determined? Is the development boundary for Catsfield being altered without resident’s knowledge?
Q3. What are your views on the key issues (listed at paragraph 2.13) that have been identified and is there anything significant missing?

Simply carving up the country-side will not make houses affordable. Brown/grey field sites must be used before green spaces.
For instance, BEX008 is earmarked for industrial use. Why isn’t the site earmarked for residential buildings if there is a national housing crisis? The infrastructure is already in place.
The site MOU0012 is a vacant industrial site - why is the landowner not incentivised to free up this site? Is he holding out for residential planning?
I understand RDC has a partnership with Hastings. Have they audited empty brownfield sites and properties together, such as the old Post Office, that could be refurbished for residential dwellings?
What is significantly missing is a clear brown/greyfield register for the area if RDC is to conserve its special landscapes such a the HHWNL. Such a register should be in the public domain.

Q22. What are your views on the Council’s proposed policy for Biodiversity Net Gain?

Conserving special landscapes like the HW National Landscape will not be achieved by building more houses over it. By definition house building cannot leave the natural environment in a measurably better state than it was beforehand. BNG can only be achieved on brown/greyfield sites. Brownfield/grey sites should be used first and RDC should make this clear in the Local Plan. Please provide the brownfield maps to the public.

Q25. What are your views on the Council’s proposed policy for the High Weald National Landscape? Q26. Are there any alternatives or additional points the Council should be considering.

Hopefully, these policies will protect the HWNL. However, for the policy to be sustainable there must be clear limits and boundaries and there is not! Therefore, the policy has little value without limits.

Q27. What are your views on the Council’s proposed policy on compact development?

I am unsure what ‘compact development’ means in practice. I assume it means making the best use of infrastructure by building in those areas, predominantly urban, where infrastructure is already in place, which makes sense. In rural villages, like Catsfield, infrastructure is poor. Public transport is non-existent in Catsfield and residents rely on private vehicles to get to work, to shop etc. usually over poorly maintained roads and lanes. No mobile signal is available in the village and no fibre WiFi is available. Drains overflow, water pressure is low or nonexistent and the village regularly suffers from power cuts. This is all down to poor, unmaintained infrastructure but I made the choice not to live in an urban environment with its good infrastructure but enjoy our wonderful countryside of Sussex.
Again, housing should be confined to brown/grey field sites, in urban surroundings that can cope with the demands of contemporary living and if that is what ‘compact development’ means then I support that.

Q28. What are your views on the area types and densities proposed as a key driver to Live Well Locally?

Please advise where the current map of the development boundary around Catsfield can be found? 25-45 dwellings per hectare makes little sense to ordinary residents - please clarify before I can comment.

Q51. What are your views on the Council’s preferred spatial development options? Q52. Do you have any comments on the merits of the alternative Spatial Development Options, that do not form part of the preferred development options – as explained in the background paper? Q53. Are there any other development options that the Council should consider as part of its Local Plan?

These concepts are confusing to the ordinary resident and need to be explained in clear English. I cannot comment on something that is so confusing.

Q62. What are your views on the vision for Battle and surrounding settlements?

RDC’s target of 60 houses for the small village of Catsfield does not correspond with Rother’s vision quoted from Page 140 - 'Sensitive small-scale development will be delivered in villages surrounding Battle, at densities consistent with the surrounding area, where it is sustainable and does not negatively impact the setting of the High Weald NL.’
Needs a total rethink regarding the number of dwellings. However, Page 145 - para 5.60/61 introduces the idea that the target of 60 houses for Catsfield is purely hypothetical!

Q77. Do you agree with the principal identified by the Council of achieving a stepped housing delivery with greater levels of delivery planned for later in the plan period?
How will RDC incentivise developers to adhere to this principal? Without strict limits this principal is unachievable! Page 177 identifies a problem with land-banking by developers - 'there have been significant delays in the build out of sites.’ This practise needs to be penalised as it affects the price mechanism of houses thus pushing up prices. How is RDC tackling the issue of land-banking?

Q82. What are your views on the Council’s approach to development boundaries?
Page 186, para 5.119 - 'This Local Plan will review each settlement’s boundary, especially in relation to potential allocation sites.’ How can residents possibly comment on something they have not seen? Please produce the Development Boundary map for Catsfield so I can make an informed comment.

Q103. Do you feel that this policy is sufficient to protect open space?
No. The policies have no limits so developers will perpetually challenge them - mission creep.

Q104. What are your views on the Council's proposed policy on public rights of way?
PRoWs are a historic right and should remain. Not diverted nor ignored nor moved surreptitiously (which has been seen in Catsfield). New PRoW are always welcome!

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.
•
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.

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.