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.

Rother planning executives confirmed at the open day in Fairlight on 11th July 2024 that the proposed CCMA is intended to reflect the existing Environment Agency map which designates this area of coastline in the 2006 Shoreline Management Plan (“SMP”), rather than to create a new area considered more vulnerable to change. Further, the dual intentions of the policy are to protect the coastline and support residents. This should be made clear and explicit in this policy.

The draft Local Plan should make it clear how it intends to protect and support residents. The zone is a broad brush but not every home is in the same situation and the policy and practice should make it clear that each case should be considered on its own merits based on likely impact, particularly where it comes to improvements or changes where there would be little, if any, impact.

The National Trust owns significant agricultural land holdings at Fairlight and Old Marsham Farm, between Fairlight village and Cliff End. This includes land within the proposed Fairlight Cove Coastal Change Management Area at Fairlight Cliffs, also part of the 163-mile Saxon Shore Way footpath. This area has a fascinating geology, and mix of diverse habitats including stunted oak woodland, grassland and thorny scrub, the clifftop offering a sanctuary for several important species. The cliffs are eroding and occasionally the Trust has to move the fence lines inland to allow walkers to continue to enjoy walks along the clifftop with views out over the English Channel and surrounding landscape. The area is looked after by a team of rangers and volunteers.

The Trust supports proposed Policy ENV4: Fairlight Cove Coastal Change Management Area which will restrict new residential development including change of use and soakaway drains within the management area, as well as the requirement for a coastal change vulnerability assessment for all other forms of development. It is important to plan for the long-term, to work with nature and not against nature, and the proper consideration of coastal change and sea level rise as well as environmental, cultural and landscape considerations. We therefore particularly support criterion (v) which requires development to not hinder the creation and maintenance of the King Charles III English Coast Path, or any other public rights of way adjacent to or that benefit from views or access to the coast.

This is too much of a blanket policy for the area it covers, and requires much more detail. The issues at Fairlight and Cliff End are very different, as is the underlying geology, and as such should be treated differently. In Fairlight Cove Central, the policy of Shoreline Management is Hold the Line until 2055, and then Managed Realignment; in FC East, it is Managed Realignment. Between Fairlight and Cliff End, and at Fairlight Cove West, it is No Active Intervention, so three or four different shoreline management policies covered by a single planning policy. Between Cliff End and the Rother the policy is Hold The Line until 2055, but in that single SMP policy the SMP working group is considering dividing the policy unit into two sections as "management in the east and west is different". The same should be applied to Cliff End and Fairlight

SWT supports the inclusion of this policy. We hope that any consideration of coastal erosion data includes the most up to date climate change assessments.

Full submission attached

My family are long term residents of Fairlight and with the benefit of the knowledge gained in that time I have just one area of concern about the draft local plan which I appreciate is a major piece of work and congratulations are due to the officers involved.
My area of great concern is below:

• Figure 41 on page 359 shows the ‘Fairlight Coastal Change Management Area’ but the majority of the village of Fairlight is outside of this area which is extremely vulnerable and is protected by the Berm, which must be protected and maintained by Rother District Council, in line with the original agreement with the Environment Agency
• The bulk of the village is however an area of extreme vulnerability due to the topography meaning that the northern side of the village is a collection area for rainfall from the local hills, the AONB called the High Weald namely Guestling Hills and the Hastings Country Park also known as the Firehills; a look out high enough to see across the whole Weald.
• The ground is usually sodden such that the increase in rainfall due to Global Warming changes AND THE INCREASE Building in the village to date, meaning the wholesale reduction in trees and overgrowth and therefore reduction in absorption of the rainfall.
• This means that the groundwater in the village increases exponentially also causing flooding further east in the low lying village of Pett Level.
• The local water authority, Southern Water are very conscious of the enormous problem such that they are investing serious money and manpower in trying to ameliorate the problem.
• This is important in that there MUST NOT be more concrete in the form of any building in the village which reduces absorption of rainfall and increases the flooding risk especially in areas known locally as flood plains.

I would be most grateful if this huge worry is taken very seriously and the ability to develop any more building in the vulnerable flood plains in Fairlight and the other areas to the East are prohibited.
On the basis that you will take this into account and follow it through I am most grateful,

Please see attached comments from Burwash Parish Council.

As attached in representation

See attached

Please see attached submitted document for full comments.

Representation by Stantec on behalf of Welbeck Strategic Land III Limited in support of Land East of Waites Lane, Fairlight Cove - HELAA site ID FAI0001.

Submission also responds to questions 59, 60, 61, 76, 27 and 191 in the Regulation 18 draft Local Plan.

Please see attached submission for full comments.