Proposed Submission Core Strategy

Not Justified - The inclusion of the reference to 'Development extending west of the A269' is not founded on a robust and credible evidence base, and therefore cannot be confirmed as the most appropriate strategy when considered against the reasonable alternatives. Strategic Growth Locations are proposed to the east of the A269, and are shown on Map 2 Inset Diagram. All that is shown west of the A269 is an area defined as 'Potential Broad Location for Further Development'. This is not a policy designation, but merely one of a number of 'Potential Broad Locations' which have no supporting 'evidence base'. The Rother DC Background Paper to the Core Strategy 'Housing Provision in Rother District August 2011 also echoes the concerns over the timescale for the construction of the Bexhill Hastings Link Road, and is silent on the extension of the 'country avenue' west of the A259.

Not Effective - The proposed 'broad location' for Further Development west of the A269 is not deliverable, as there is no certainty of any 'development road' vehicular access being constructed to serve this location.

Not consistent with National Policy - This is set out in Planning Policy Statements, and in the Draft National Planning Policy Framework (NPPF). Planning Policy 3 (Housing) requires that Broad Locations for development should be on specific sites which are deliverable (para 53). This emphasis on deliverability of Broad Locations for housing is also emphasized in the Draft NPPF. No evidence is put forward in this Core Strategy that the proposed Broad Location west of the A269 is deliverable.

1. Regarding the statement in para.8.59 that the town of Bexhill " may be extended westwards adjacent to the urban area without undue impact on the wider landscape":

(a) Although the nature of the development under consideration is not specified, BALI considers the proposal for "development of Bexhill extending west of the A269" to be unsoundly based and strongly object to it. No such development has previously been planned by Rother District Council nor is any 'development road' across or from the A269 being currently planned or even being considered by the responsible authority, East Sussex County Council, even for the long-term future. It is not for the Core Strategy to pre-empt ESCC Transport policy and, as it were, seek to covertly create a 'Bexhill Ring Road'.

(b) Although the routing of any such development road is not made clear nor the nature of the development envisaged BALI maintains that no development could be achieved west of the A269 "adjacent to the urban area without undue impact on the wider landscape'. The A269 above Sidley has previously been regarded as the western edge of built development in Bexhill and development across it would represent a new dimension of urban sprawl at the expense of fast disappearing countryside fringes of the town, contrary to the Environmental Objectives and Policies detailed in Chapter 17 of the Proposed Submission Core Strategy. (See 6. below)

2. There is no land immediately "adjacent to the urban area" west of the A269 save that already allocated for the expansion of Bexhill Cemetery (See Rother District Planning Application RR/2010/1788R).The area in question is a fundamentally different rural landscape previously described in the Draft Core Strategy Consultation on Strategic Directions (Rother District Council November 2008) as (6.33) "rolling farmland divided by several areas of ancient woodland" and (6.77) "pleasant pastoral country side with a patchwork of fields separated by small woods and strong hedge lines similar to the High Weald". Any development road running westwards of the A269 would simply cut a swathe across this landscape with brickworks traffic supplementing that serving the development.

3. The development road is described as "linking to the Ibstock (Ashdown) Brickworks site." In the Draft Core Strategy (November 2008) this road was justified in terms of "assisting to provide the transport infrastructure essential to the planned landfill use of the Ibstock site" as, at that point, Ashdown Brickworks had been allocated as a potential landfill site in East Sussex County Council's Waste Local Plan (2006). In this case the road, while environmentally unsound, could at least have had some purpose in removing waste traffic from local roads. However, the County Council do not now propose to save the site-specific allocation of Ashdown brickworks in their new draft Waste and Minerals Plan [Proposed Draft Waste and Minerals Plan for East Sussex, South Downs and Brighton and Hove (Shortened Version October 2011) Policy WMP 6(b) pp.88-89].
Since there is already established access to and from the Brickworks for brickmaking materials and products and the site will close when the quarries have been fully excavated, such a road would not be cost-effective in terms of this stated function unless it were subsidized by Ibstock Brick Ltd. However Ibstock have always opposed development in the vicinity of the brickworks valuing (and even buying land) to provide a buffer between it and any neighbours and opposing development plans in this area including that for the expansion of Bexhill Cemetery.

4. The other stated function of development in this area is "to contribute to the extension of accessible green space from the (Pebsham) Countryside Park towards the High Woods Area". However such green space and woodland is already accessible by existing roads and it is a nonsense, if not an oxymoron, to create development-lined roads to extend access to green space that in themselves destroy green space. The development also, depending on its nature
and routing, could adversely affect cherished 'green' local amenities nearby including Chestnut Meadow Caravan Site, Bexhill Cemetery, Highwoods Golf Club and the Highwoods SSSI itself.

5. To position such a road westwards across the A269 in the Core Strategy at this time is, in any case, purely speculative, with no evidence base to support its possible construction. The likelihood of the development being delivered within the plan period is extremely remote and it is therefore both unjustified and ineffective to include it in the Core Strategy.

(a) The Bexhill Country Avenue Western Extension as currently planned (leading to Preston Hall Farm) is a proposed spur road off the proposed Bexhill to Hastings Link Road whose funding itself depends on a government decision expected around the end of 2011. Funding, detailed routing, etc. for the Country Avenue towards the A269 has not even been considered yet alone consulted on.

(b) A further westward extension of the Country Avenue across the A269 as described in para.8.59 is at this stage hardly more than a conjecture. It is true such a road had been vaguely considered in 2002 as part of a "peripheral framework of country avenues around Bexhill and Hastings" in a glossy draft conceptual document commissioned by SEEDA and produced by MBM Arquitectes of Barcelona entitled "Towards a Masterplan for Hastings and Bexhill". (The ESCC Waste Local Plan Inspector in his report (2004) then took the idea up as a possible way of transporting waste to Ashdown Brickworks). However, the delays in starting work on the Link Road have surely pushed such a notion beyond the realms of credibility for the period of the Core Strategy.

Indeed, after detailed studies of the transport infrastructure in this area, the unlikelihood of this road being built in any reasonable timescale was one of the reasons why ESCC has abandoned its allocation of Ashdown brickworks for landfill in its new waste plan. To quote the draft plan:

"Even if funding for the Link Road is provided it is highly unlikely that the whole connection to the A269 would be constructed before at least the mid 2020s. In these circumstances it is therefore considered that landfill at this site could not be delivered during the period of this plan".

6. Whether feasible or not, such a development should not be considered in the light of the Proposed Submission Core Strategy's Strategic Objectives and Policies with regard to the Environment in Chapter 17 as quoted below:

(a) The key objective "to maintain the high quality and improve the long-term stewardship of the natural and built environment...." (6.1. p. 24) amplified by the following objectives in 17.8 namely:
"(i) To conserve, manage and, where appropriate enhance the high quality landscape resources
(ii) To protect important ecological resources in the district and, where, appropriate, enhance these as part of a wider approach to 'green space'"

(b) In 17.10 the Core Strategy reflects on the importance of the landscape for our "sense of identity and well-being and providing inspiration." 17.17 states that a challenge for new development is to "maintain the visual character of settlements in the landscape and in particular settlement edges New development brings the threat of the suburbanization of landscape character....with roads, light pollution... and loss of tranquillity."

(c) Policy EN1 calls for high standards of landscape stewardship ensuring the protection and wherever possible enhancement of the district's locally distinctive landscapes. Such standards of stewardship are not only called for in SSIs or AONBs but (EN1(v)) in the "open landscape between clearly designed settlements including the visual character of settlement, settlement edges and their rural fringes", also in retaining (vii) key landscape features across the district including native hedgerows, copses, field patterns, ancient ditches...

(d) Regarding Biodiversity and Green Space, para 17.38 notes that the "rich and distinctive natural environment" of the district functions as both an important ecological habitat and an attractive visual resource and amenity, important to both the tourism economy and the local community. "Policy EN5 seeks to protect and enhance biodiversity and green space by maintaining and developing "a district-wide network of green infrastructure where possible linking areas of natural green space" and ensuring "that development retains, protects and enhances habitats of ecological interest, including ancient woodland (in which this particular area abounds-sic), water features and hedgerows".
Development west of the A269 in an area of beautiful rolling farmland, virgin ancient meadows and woodland divided by hedgerows is inconsistent with the above environmental policies of the Proposed Submission Core Strategy to the point of anathema. The loss of green space, increased noise and air pollution and increased carbon emissions are completely unacceptable and the suggestion that development in this area could be achieved "without undue impact on landscape character" is clearly nonsense. The proposal represents "urban sprawl" of the worst kind - gratuitous suburbanization of a marginal hitherto rural area with perhaps the hope of eating further into it at the next bite.

7. The above responses largely reiterate representations made by BALI in consultations on previous stages of the Core Strategy particularly the Consultation on Strategic Directions (Rother District Council November 2008) In one of these (Representation ID 20486) BALI proposed, as a long-term strategy or vision for this area towards the end of the plan period (when the Brickworks would likely be closed), a West Bexhill Countryside Park incorporating the land between the A269 and Whydown Road consisting of the pastoral landscape as described above, the ancient woodland of the Highwoods and the probably then infilled Ashdown Quarries.

The Council should bear in mind that restoration of the Ashdown Quarries is progressive and ongoing according to Ibstock's own plans incorporated into its Minerals Extraction License last reviewed in 2002 (Review of Planning Permission, Ashdown Brickworks RR/76/1460(CM)). The mineral workings currently operate on a phased basis, restoration being implemented as each phase of extraction is complete, overburden and interburden having been retained, together with
unusable clay, for this purpose. The plan is to create an attractive 'bowl in the landscape' with a water feature, landscaped and planted as a public leisure amenity.

It is also important to note the growing archaeological importance of the quarry site as a site of rich prehistoric dinosaur remains as a result of which English Nature is currently considering an application that it be made a Site of Special Scientific Interest (SSSI). The nationally important discoveries made, including those of new species are the subject of on-going analysis by experts from the University of Portsmouth and were first published in an article in Wealden News, the magazine of Wealden Geology (February 2010) to which we link as follows: http:/kentrigs.org.uk/w8pdf. Later discoveries, however, for example of the 'world's smallest dinosaur', have hit national headlines.

The response of Rother District Council to BALI's representation (http:/rother.jdiconsult.net/ldf/viewrepresponse.php?repid=20486) was somewhat underwhelming as follows:
"The Inset Map identifies a substantial strategic open space incorporating High Woods. Further linkages could be considered at the site allocations stage in conjunction with any development allocations in the locality."

We appreciate the definition of a substantial strategic open space in West Bexhill on the new Inset Map 2 of the Proposed Submission Core Strategy but the areas which it covers are not at all clear.

We therefore hereby renew our representation in the light of the above that this area west of the A269 until the Whydown Road be excluded from further development and reserved for a Country or Countryside Park. This park , counterpointing the Pebsham Countryside Park to the East would help to create the network of Green Space sought by the Core Strategy, reserving
development in the District (largely) to the North/ Northeast of the District.

Not justified - This Core Strategy correctly states in paragraphs 7.60 - 7.66 and Policy OSSS2 that there is currently no certainty on the delivery of the Bexhill Hastings Link Road. It is therefore not 'sound' to make the assumption in this Core Strategy that it will be constructed. Policy BX3 (iii) does make that assumption, by making reference to future development to the north and west of Bexhill, which will require this Link Road (and additional roads) to be constructed.

Not Effective - In the preceding paragraphs to Policy BX3 there is no explanation on when or whether the roads to service any further new development to the north and west of the town would be constructed.

Not Consistent with National Policy - The reference in this Policy to 'further sites' for housing and business development to the north and west of Bexhill without providing evidence on how these areas would be accessed is contrary to National Policy, as set out in PPS3 and the Draft National Planning Policy Framework.

Not Justified - The inclusion of a 'Potential Broad Location for Further Development west of the A259' is not founded on a robust and credible evidence base, as is fully explained in our submissions on Paragraph 8.59. It therefore should not be shown on this Inset Diagram.

Not Effective - This proposed Broad Location is not effective, as no evidence has been provided to demonstrate its delivery in the period of the Core Strategy. There is no certainty in the area being able to be accessed from a new 'development road'.

Not Consistent with National Policy - Both PPS 3 Housing and the Draft National Planning Policy Framework require that any Broad Locations for Development must be deliverable. No evidence is provided in this Core Strategy that the area west of the A259 is deliverable within the period of the Core Strategy.