Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

Rother is one of the most wooded areas within England and therefore has a large
resource of biomass that could be exploited for wood-burners and small scale biomass boilers and Combined Heat and Power (CHP) plants. We would support any policies that encourage the use of this sustainable resource. Bringing back large areas of woodland into active management has the potential to be very positive to biodiversity as evidenced by the work of the Wildlife Trusts, Natural England, The Forestry Commission and the Butterfly Conservation Trust, all of which are actively working with landowners to this effect.

Planning policies should be put in place that not only encourage the householder e.g.
chimneys/flues on all new properties for wood burners; but also to make it easier for
landowners to set up wood fuel businesses e.g. buildings, storage facilities etc.

The current system of asking for all new developments over a certain size to explore the use of biomass / CHP does not seem to be working as developers tend to show that they are not viable. Often it is the public sector that has to lead the way and therefore it is suggested that all new public buildings of a minimum size should have a system installed. This would kick start a local market for fuel. Consideration should also be given to retro-fitting existing public assets. Swimming pools would be a prime target as they have a year round need for heat.

The policy wording for larger developments to 'consider' biomass is not strong enough. There is a need for a proper viability analysis to be undertaken and for RDC to employ their own consultants to review rather than accepting the results.

In conclusion, there is a need to strengthen use of biomass as suitable for smaller
developments and public buildings so that this form of energy is given more serious
consideration.

It should also be borne in mind that adequate insulation saves more energy than can be generated by householders. It is essential therefore that the highest standards are sought.



6.20 Comments on solar paragraph as no question for response

There needs to be a DRM2- to encourage where appropriate wind and solar, and to
make solar mandatory on all commercial and industrial buildings; and any application to alter/extend industrial building needs to carry an obligation to fit rooftop solar.

Encourage:
* Solar thermal panels for "family" properties.
* Community solar schemes.

The National Grid needs updating so that the above average generation rates achieved within Rother can be utilised fully. In the meantime, where there are grid problems, smart meters should allow neighbours to share.

Could RDC council monies be used to improve the grid?

The document from Maidstone BC which in turn was borrowed from Cornwall CC and
Ashford BC gives detailed guidance and it would be helpful for RDC to provide similar
guidance:

Reference; Maidstone Borough Council: Planning Policy Advice Note:
Domestic and Medium scale solar PV arrays (up to 50kw) and solar thermals
Jan 2014

Items 6.21 & 6.22 of the DaSA are deeply flawed. The 'unduly onerous' (para 6.22) is dubious to whom? Any developer will always say such is 'unduly onerous'. CS SRM(i) does not contain a target for energy reduction proposals. Without, such it is not effective. Target should be to cut predicted C02 emissions by the equivalent of 20% over and above what current building regulations require.

The validation checklist referred to in paragraph 2.21 of the Renewable Energy
background paper is inadequate and in urgent need of updating. Other local authorities, such as Maidstone Borough Council, include the following condition for ALL new build houses (threshold 1 dwelling): 'Prior to any development above damp proof course level, details of proposed renewable energy sources shall be submitted to and approved in writing by the local planning authority. The approved details shall be implemented prior to the first occupation of any dwelling.' This clearly demonstrates that RDC can, if it so chooses, impose much tighter and binding rules, for ALL new build development. The difficulty in applying the current policy is due to a lack of will by RDC. As it is, rather than relaxing Core Strategy Policy SRM1, it should be tightened.

Reference: RDC Development and Site Allocation Local Plan, Renewable and Low
Carbon Energy - Background Paper. November 2016
Examples of criteria RDC should be setting:

* Are as many as possible of the sloping roofs oriented as much as possible to the
South and West in order to be fitted with solar panels?

* Are locations for solar panels included in the design of the roofs - even if not
fitted?
* Where solar panels can be fitted have you considered providing space in the
dwelling for batteries?
* Are heat pumps being considered?
* If so have you included in the design suitable locations for them?
* Have you considered installing under floor heating?
* Are electric charging points being included for electric vehicles?
* All new commercial and industrial roofs over (100) sq. m. must install solar panels
on south or south west facing roofs.
* All new developments should consider specific on-site positioning to maximise the
possibility of installing solar roof panels and for increasing passive solar gain.

6.23 Praise to RDC for this clause as this applies to every development/dwelling.

Policy DEN1: Agreed.
It is good that RDC has a policy on lighting but it needs to have a specific policy fleshed out to preserve dark night skies. Such policy needs to restrict lighting to its intended purpose and avoid any light spill.

Consider solar street lighting and shields to stop lighting dwellings

Policy DEN2
The proposals 10.1 - 10.11 should take account of (a) the HWAONB advice note
published October 2016, 'Legislation and Planning Policy in the HWAONB', and (b)Policy EN3 of the Robertsbridge Neighbourhood Plan.

All development will be considered with regard to any negative impact it may have on the landscape character of any adjacent countryside. Proposals which preserve the open character of any gap between settlements and, as a minimum, is not detrimental to the Green Infrastructure Network (as identified by RDC) will be supported. Development will only be permitted where it conserves or enhances the natural beauty of the immediate area in which the development sits.

In particular all opportunities must be taken to:

* restore the natural function of rivers, streams and other watercourses to improve
water quality, to prevent flooding and enhance wetland habitats;
* respect the settlement pattern of parishes or towns, use local materials and wood
fuel systems that enhance the appearance of development;
* relate well to historic route ways and not divert them from their original course or
damage their rural character by loss of banks, hedgerows, verges or other
important features;
* not result in the loss or degradation of Ancient Woodland or historic features
within it and, where appropriate, will contribute to its on-going management;
* conserve and enhance the ecology and productivity of fields, trees and
hedgerows, retain and reinstate historic field boundaries, and direct development
away from medieval or earlier fields, especially where these form coherent field
systems with other medieval features.

BEC1 - Land East of Hobbs Lane, Beckley.

The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

BEC2
Shows a large area set aside for amenity use, which is welcome, but the policy should set out more criteria so that it is also maximised for biodiversity enhancement and thus becomes multi-functional green space. This would be in line with the aims for Policy DEN4: Biodiversity and Green Space.

BRO1 - Land West of A28, Broad Oak
The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

BEC1 - Land East of Hobbs Lane, Beckley.

The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

BEC2
Shows a large area set aside for amenity use, which is welcome, but the policy should set out more criteria so that it is also maximised for biodiversity enhancement and thus becomes multi-functional green space. This would be in line with the aims for Policy DEN4: Biodiversity and Green Space.

BRO1 - Land West of A28, Broad Oak
The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

BEC1 - Land East of Hobbs Lane, Beckley.

The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

BEC2
Shows a large area set aside for amenity use, which is welcome, but the policy should set out more criteria so that it is also maximised for biodiversity enhancement and thus becomes multi-functional green space. This would be in line with the aims for Policy DEN4: Biodiversity and Green Space.

BRO1 - Land West of A28, Broad Oak
The aerial photo indicates that the site has the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to
accommodate the biodiversity on site. It is suggested that the policy be amended to
highlight this potential and that any plans submitted should incorporate a biodiversity strategy.

We have identified further points that need consideration.

1 A policy is needed to promote sustainable construction.

2 Rivers and watercourses - to permit a proposal only if it conserves or enhances
water quality and/or biodiversity and incorporates measures to prevent pollution to rivers and watercourses.

3 Transport Policies in the Core Strategy

The transport policies in the Core strategy need improving cf 'Notes on Core Strategy with policy references' at the end of this document.

Proposals must be designed where possible to reduce the need for travel by incorporating connectivity and door to door opportunities for walking and cycling.

Policies TR1 and TR2 are essentially supine and not proactive. The DaSA can strengthen them

TR1 for distance has as aim (iii) investment in providing transport choice, but does not suggest anything specific, and (iv) talks of working with agencies to upgrade capacity of East Coastway and Hastings to London rail corridors, but needs more flesh on these bones. And the alternative Bexhill to London corridor as well?

TR2 is about integrated transport but is high level with no specific ideas noted or criteria adopted. For example, it says in (iii) 'support the provision of a high quality cycle network to encourage a modal shift away from the car' but no specific ideas, such as 'any development in Bexhill more than 10 houses shall contribute to a fund to improve walking and cycle routes'.

Walking and Cycling Routes. New Developments should take the opportunity to create areas where active travel can be the preferred way to get around for short journeys (2 miles or less) by considering walking and cycling routes above those of motorised forms of travel. Connectivity of walking and cycle routes need to high on the agenda when at the pre-planning and planning stage.

We are pleased to note that a number of the site allocation policies incorporate the need to connect the development to the local footpath network.

TR3: Electric Charging points for vehicles: In Core Strategy Policy TR3 Access and
New Development" iii) Provision of Electric vehicle charging infrastructure"

We would suggest that this needs to be more specific. eg At residential properties there needs to be space for overnight parking adjacent to the property where charging can take place. Charging points need to be provided in car parks, office car parks and communal areas.

Historic rural roads including those within villages must be protected for their intrinsic value and any new access points to this network must not detract from the character and appearance of the locality, especially the need to retain banks, hedges, walls and roadside trees

4 Footways
There is precious little in the current Core Strategy. Nothing in the Transport chapter and the only oblique references are in the Rural Areas chapter - Policy RA1 (vi) 'improved access to basic day to day services...by public transport, walking and cycling...', and RA2 (vi) '..support enjoyment of the countryside and coast through improving access..' These are not very strong or helpful to promote what I call below in official speak MUNMRs!

So we suggest a policy along these lines:

Footways Policy

We support:
*The development of a network of high quality multi-user non-motorised routes
with appropriate signage throughout the District.
*Access points across major roads and railways for the public rights of way network and other strategic MUNMRs will be protected and proposals for new crossings will generally be supported. (This is to stop people like Network Rail blocking off footpaths where they cross railways).
*Residential developments should wherever possible, incorporate attractive links,
accessible to all, to the nearest point on the public right of way network and local
foot way networks.
*Where Rights of Way (footpaths and bridleways etc) are removed, or
compromised by development, there will be a loss of the visual amenity and
probably safety concerns with new local traffic. Alternative Rights of Way need to
be found which will create opportunities with new visual amenities with access
and connectivity with local Rights of Way.
*Development proposals that would have an unacceptable adverse impact on the
amenity value of public rights of way, other public non-motorised routs and access
land will be refused.

NOTES ON CORE STRATEGY DOC WITH POLICY REFERENCES:

EN 4
Reduce street clutter - should be expanded to include cars parked on bus stops - an
endemic problem in Rother. Battle High Street has cars parked on bus stops "100% of the time" according to an interviewed bus driver. Sackville Road Bexhill has cars
frequently parked on the westbound side.

EN 5 vii/EC 6 i
' increase accessibility to the countryside from urban areas'. Good idea but bus services have declined. In the last two years, Bodiam Castle has had no Sunday buses on summer Sundays. In that period visitor numbers have risen by 28,000: the most popular days are Sundays (see attached chart). Most visits are by car on roads not well suited to high volumes of traffic. Even the Sundays that sit within a Bank Holiday have no bus. The Battle - Robertsbridge summer Sunday service is also now absent on summer Sundays. This policy is not implemented.

EC6 i The Sunday bus service (if restored) has the potential to reduce traffic, which in the case of Bodiam Castle, detracts from its setting and excludes sections of the
population. This will become increasingly important as tourism from abroad continues to rise due to weakness in the £ and, for the same reason, the 'staycation' market also grows. This is the prediction of 'Visit England'.

It also has implications for policy CO 4 (young people who often have to get to work at weekends); CO 5 Older citizens whose physical and mental health would benefit from independence afforded by a bus service, and CO 6, safety which is offered by the bus (professional drivers) and more broadly through challenging the primacy and status given to car travel by transport policies and measures that flow from these which marginalize all other modes.

EN 6 On flood risk, a halt to the practice of replacing gardens by hard standing for cars. Tens of thousands of gardens have been lost with consequent flood risk increase through runoff. See below:
*Large areas of tarmac and concrete for car parks and road space, including loss of
gardens for hard standing increase the risk of flooding. In flood risk areas of
Southampton, a 23% increase in this garden loss has led to a 26% increase (this may increase) in flood storage needs. There is also of course biodiversity loss.

Negative effects include a reduction in water available to recharge aquifers and greater inefficiency in the operation of 'sustainable drainage systems' (suds), undermining policy SRM 2.

Essentially, this is also an increase in 'road space' with rising traffic levels the result.
There are obvious negative health impacts.

In LHN section, I can't see a reference to the pre-requisite to have high quality public transport access to housing sites. An example in an 'urban fringe' would be the need for bus priority measures from Barnhorn (east of Little Common) to Little common roundabout to offer high quality bus links into Bexhill and Hastings on the 99 route. But the principle of public transport access should apply comprehensively to new developments and expanding villages/towns.

Transport measures - and the mechanisms for analysis of problems, need and
implementation of appropriate measures - are confusingly the responsibility of a whole range of bodies from parishes, Districts and ESCC (the statutory authority) through to LEPs and in the near future, the SE 'sub-national transport body' (SNTB). We need to know more about this from ESCC who - along with other SE authorities - have put up £20,000 to form a 'shadow SNTB.

EC 1 vi
Support for local economies (which function on Sundays - see comments on Sunday
buses and the needs of the young to get to work).

TR1
i Costs of the BHLR continue to rise - with the acknowledged possibility of further threat of more increases, and benefits questionable and yet to be delivered.

ii Traffic on the 'strategic transport corridors' and its 'origin/destination' is sufficiently
understood to warrant a more sophisticated response in terms of appropriate measures pursued to meet need. For instance, most traffic on the A21 moving north-south in Rother is beginning/ending south of Tunbridge Wells, yet the bus services operating in this patch, linking villages with towns- and where advantageous, railway stations - and employment/education destinations are diminishing. All too often, the emphasis is on major road expansion: this is simplistic and ultimately damaging to local economies, environment and public health.

iii Outside of bus 'trunk routes' such as the 99/100 services, investment in bus services has diminished. In the case of the Bexhill - Hastings bus priority measures,
implementation is significantly delayed, reducing the congestion relief function of the
BHLR. Bus priority measures are now needed between Barnhorn and Little Common, as well as traffic restraint that challenges the parking 'free for all' in Rother District.

The relegation of the new railway station at Ravenside/Glyne Gap to a 'maybe at some future time' facility, further reduces the 'value for money' (already poor) of the BHLR. The new signalling regime on the east Coastway, would permit a sufficiently good service for Ravenside/Glyne Gap station. This removes a key justification of RDC/ESCC in removing the station from plans.

Progress on expanding opportunities for walking and cycling is far too slow and the
potential health benefits far too great to ignore or to regard as a 'peripheral issue'. Crisis in our hospitals and pressure on GPs requires a far greater emphasis on 'pro-active' healthcare, and 'active travel' to deliver short, medium and long term benefits, coupled with efforts to tackle poor air quality at every level of government.
iv Include specific mention of support for proposals to re-open the Uckfield - Lewes,
Eridge - Tunbridge Wells railway line to expand 'car free' accessibility opportunities for all travellers.

TR2 IM1
Quite sound policies: a shockingly slow pace of implementation.

The primacy of the car is far too strong an element of policy and implementation. It is electoral suicide to even gently challenge the 'rights of the motorist'. We need
courageous politicians and better education of the public.

Robust monitoring please (IM1)

TR3 ii
In Wealden, this strand of policy hasn't worked 'on the ground' with public transport,
walking and cycling infrastructure not sufficiently in place to serve accessibility needs of developments north of Eastbourne.

TR4/IM2 iii
Suggest that for the urban areas of Bexhill, together with Hastings, a 'workplace parking levy' be introduced to help fund a whole range of 'sustainable and healthy transport measures'.

That the 'laissier faire' attitude to illegal and anti-social parking be exchanged for a
system fairer to pedestrians and bus users and a policy statement be included to reflect this.

Footnote:
18.41
Given the limitation to existing public transport infrastructure, a car is seen as a
necessity in many rural parts of the district.

So let's have some more support for local bus services!

WES4
Q92. Agree. It is good to see this green corridor provision. More are needed across the district e.g. the woodland running alongside the railway in Rye Potential biodiversity issues with site allocations.

A number of the sites have the potential to have populations of protected and priority species using them but this does not appear to have been taken into account. The aerial photos in the document indicates that the following sites have the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to accommodate this biodiversity.

WES4
Q92. Agree. It is good to see this green corridor provision. More are needed across the district e.g. the woodland running alongside the railway in Rye Potential biodiversity issues with site allocations.

A number of the sites have the potential to have populations of protected and priority species using them but this does not appear to have been taken into account. The aerial photos in the document indicates that the following sites have the potential for reptiles, bats, great crested newts or birds due to the presence of scrub and rough grassland. Under the biodiversity and green space policy all developments will be expected to retain and enhance biodiversity but the developed area indicated does not leave much space to accommodate this biodiversity.

We have identified further points that need consideration.

1 A policy is needed to promote sustainable construction.

2 Rivers and watercourses - to permit a proposal only if it conserves or enhances
water quality and/or biodiversity and incorporates measures to prevent pollution to rivers and watercourses.

3 Transport Policies in the Core Strategy

The transport policies in the Core strategy need improving cf 'Notes on Core Strategy with policy references' at the end of this document.

Proposals must be designed where possible to reduce the need for travel by incorporating connectivity and door to door opportunities for walking and cycling.

Policies TR1 and TR2 are essentially supine and not proactive. The DaSA can strengthen them

TR1 for distance has as aim (iii) investment in providing transport choice, but does not suggest anything specific, and (iv) talks of working with agencies to upgrade capacity of East Coastway and Hastings to London rail corridors, but needs more flesh on these bones. And the alternative Bexhill to London corridor as well?

TR2 is about integrated transport but is high level with no specific ideas noted or criteria adopted. For example, it says in (iii) 'support the provision of a high quality cycle network to encourage a modal shift away from the car' but no specific ideas, such as 'any development in Bexhill more than 10 houses shall contribute to a fund to improve walking and cycle routes'.

Walking and Cycling Routes. New Developments should take the opportunity to create areas where active travel can be the preferred way to get around for short journeys (2 miles or less) by considering walking and cycling routes above those of motorised forms of travel. Connectivity of walking and cycle routes need to high on the agenda when at the pre-planning and planning stage.

We are pleased to note that a number of the site allocation policies incorporate the need to connect the development to the local footpath network.

TR3: Electric Charging points for vehicles: In Core Strategy Policy TR3 Access and
New Development" iii) Provision of Electric vehicle charging infrastructure"

We would suggest that this needs to be more specific. eg At residential properties there needs to be space for overnight parking adjacent to the property where charging can take place. Charging points need to be provided in car parks, office car parks and communal areas.

Historic rural roads including those within villages must be protected for their intrinsic value and any new access points to this network must not detract from the character and appearance of the locality, especially the need to retain banks, hedges, walls and roadside trees

4 Footways
There is precious little in the current Core Strategy. Nothing in the Transport chapter and the only oblique references are in the Rural Areas chapter - Policy RA1 (vi) 'improved access to basic day to day services...by public transport, walking and cycling...', and RA2 (vi) '..support enjoyment of the countryside and coast through improving access..' These are not very strong or helpful to promote what I call below in official speak MUNMRs!

So we suggest a policy along these lines:

Footways Policy

We support:
*The development of a network of high quality multi-user non-motorised routes
with appropriate signage throughout the District.
*Access points across major roads and railways for the public rights of way network and other strategic MUNMRs will be protected and proposals for new crossings will generally be supported. (This is to stop people like Network Rail blocking off footpaths where they cross railways).
*Residential developments should wherever possible, incorporate attractive links,
accessible to all, to the nearest point on the public right of way network and local
foot way networks.
*Where Rights of Way (footpaths and bridleways etc) are removed, or
compromised by development, there will be a loss of the visual amenity and
probably safety concerns with new local traffic. Alternative Rights of Way need to
be found which will create opportunities with new visual amenities with access
and connectivity with local Rights of Way.
*Development proposals that would have an unacceptable adverse impact on the
amenity value of public rights of way, other public non-motorised routs and access
land will be refused.

NOTES ON CORE STRATEGY DOC WITH POLICY REFERENCES:

EN 4
Reduce street clutter - should be expanded to include cars parked on bus stops - an
endemic problem in Rother. Battle High Street has cars parked on bus stops "100% of the time" according to an interviewed bus driver. Sackville Road Bexhill has cars
frequently parked on the westbound side.

EN 5 vii/EC 6 i
' increase accessibility to the countryside from urban areas'. Good idea but bus services have declined. In the last two years, Bodiam Castle has had no Sunday buses on summer Sundays. In that period visitor numbers have risen by 28,000: the most popular days are Sundays (see attached chart). Most visits are by car on roads not well suited to high volumes of traffic. Even the Sundays that sit within a Bank Holiday have no bus. The Battle - Robertsbridge summer Sunday service is also now absent on summer Sundays. This policy is not implemented.

EC6 i The Sunday bus service (if restored) has the potential to reduce traffic, which in the case of Bodiam Castle, detracts from its setting and excludes sections of the
population. This will become increasingly important as tourism from abroad continues to rise due to weakness in the £ and, for the same reason, the 'staycation' market also grows. This is the prediction of 'Visit England'.

It also has implications for policy CO 4 (young people who often have to get to work at weekends); CO 5 Older citizens whose physical and mental health would benefit from independence afforded by a bus service, and CO 6, safety which is offered by the bus (professional drivers) and more broadly through challenging the primacy and status given to car travel by transport policies and measures that flow from these which marginalize all other modes.

EN 6 On flood risk, a halt to the practice of replacing gardens by hard standing for cars. Tens of thousands of gardens have been lost with consequent flood risk increase through runoff. See below:
*Large areas of tarmac and concrete for car parks and road space, including loss of
gardens for hard standing increase the risk of flooding. In flood risk areas of
Southampton, a 23% increase in this garden loss has led to a 26% increase (this may increase) in flood storage needs. There is also of course biodiversity loss.

Negative effects include a reduction in water available to recharge aquifers and greater inefficiency in the operation of 'sustainable drainage systems' (suds), undermining policy SRM 2.

Essentially, this is also an increase in 'road space' with rising traffic levels the result.
There are obvious negative health impacts.

In LHN section, I can't see a reference to the pre-requisite to have high quality public transport access to housing sites. An example in an 'urban fringe' would be the need for bus priority measures from Barnhorn (east of Little Common) to Little common roundabout to offer high quality bus links into Bexhill and Hastings on the 99 route. But the principle of public transport access should apply comprehensively to new developments and expanding villages/towns.

Transport measures - and the mechanisms for analysis of problems, need and
implementation of appropriate measures - are confusingly the responsibility of a whole range of bodies from parishes, Districts and ESCC (the statutory authority) through to LEPs and in the near future, the SE 'sub-national transport body' (SNTB). We need to know more about this from ESCC who - along with other SE authorities - have put up £20,000 to form a 'shadow SNTB.

EC 1 vi
Support for local economies (which function on Sundays - see comments on Sunday
buses and the needs of the young to get to work).

TR1
i Costs of the BHLR continue to rise - with the acknowledged possibility of further threat of more increases, and benefits questionable and yet to be delivered.

ii Traffic on the 'strategic transport corridors' and its 'origin/destination' is sufficiently
understood to warrant a more sophisticated response in terms of appropriate measures pursued to meet need. For instance, most traffic on the A21 moving north-south in Rother is beginning/ending south of Tunbridge Wells, yet the bus services operating in this patch, linking villages with towns- and where advantageous, railway stations - and employment/education destinations are diminishing. All too often, the emphasis is on major road expansion: this is simplistic and ultimately damaging to local economies, environment and public health.

iii Outside of bus 'trunk routes' such as the 99/100 services, investment in bus services has diminished. In the case of the Bexhill - Hastings bus priority measures,
implementation is significantly delayed, reducing the congestion relief function of the
BHLR. Bus priority measures are now needed between Barnhorn and Little Common, as well as traffic restraint that challenges the parking 'free for all' in Rother District.

The relegation of the new railway station at Ravenside/Glyne Gap to a 'maybe at some future time' facility, further reduces the 'value for money' (already poor) of the BHLR. The new signalling regime on the east Coastway, would permit a sufficiently good service for Ravenside/Glyne Gap station. This removes a key justification of RDC/ESCC in removing the station from plans.

Progress on expanding opportunities for walking and cycling is far too slow and the
potential health benefits far too great to ignore or to regard as a 'peripheral issue'. Crisis in our hospitals and pressure on GPs requires a far greater emphasis on 'pro-active' healthcare, and 'active travel' to deliver short, medium and long term benefits, coupled with efforts to tackle poor air quality at every level of government.
iv Include specific mention of support for proposals to re-open the Uckfield - Lewes,
Eridge - Tunbridge Wells railway line to expand 'car free' accessibility opportunities for all travellers.

TR2 IM1
Quite sound policies: a shockingly slow pace of implementation.

The primacy of the car is far too strong an element of policy and implementation. It is electoral suicide to even gently challenge the 'rights of the motorist'. We need
courageous politicians and better education of the public.

Robust monitoring please (IM1)

TR3 ii
In Wealden, this strand of policy hasn't worked 'on the ground' with public transport,
walking and cycling infrastructure not sufficiently in place to serve accessibility needs of developments north of Eastbourne.

TR4/IM2 iii
Suggest that for the urban areas of Bexhill, together with Hastings, a 'workplace parking levy' be introduced to help fund a whole range of 'sustainable and healthy transport measures'.

That the 'laissier faire' attitude to illegal and anti-social parking be exchanged for a
system fairer to pedestrians and bus users and a policy statement be included to reflect this.

Footnote:
18.41
Given the limitation to existing public transport infrastructure, a car is seen as a
necessity in many rural parts of the district.

So let's have some more support for local bus services!

We have identified further points that need consideration.

1 A policy is needed to promote sustainable construction.

2 Rivers and watercourses - to permit a proposal only if it conserves or enhances
water quality and/or biodiversity and incorporates measures to prevent pollution to rivers and watercourses.

3 Transport Policies in the Core Strategy

The transport policies in the Core strategy need improving cf 'Notes on Core Strategy with policy references' at the end of this document.

Proposals must be designed where possible to reduce the need for travel by incorporating connectivity and door to door opportunities for walking and cycling.

Policies TR1 and TR2 are essentially supine and not proactive. The DaSA can strengthen them

TR1 for distance has as aim (iii) investment in providing transport choice, but does not suggest anything specific, and (iv) talks of working with agencies to upgrade capacity of East Coastway and Hastings to London rail corridors, but needs more flesh on these bones. And the alternative Bexhill to London corridor as well?

TR2 is about integrated transport but is high level with no specific ideas noted or criteria adopted. For example, it says in (iii) 'support the provision of a high quality cycle network to encourage a modal shift away from the car' but no specific ideas, such as 'any development in Bexhill more than 10 houses shall contribute to a fund to improve walking and cycle routes'.

Walking and Cycling Routes. New Developments should take the opportunity to create areas where active travel can be the preferred way to get around for short journeys (2 miles or less) by considering walking and cycling routes above those of motorised forms of travel. Connectivity of walking and cycle routes need to high on the agenda when at the pre-planning and planning stage.

We are pleased to note that a number of the site allocation policies incorporate the need to connect the development to the local footpath network.

TR3: Electric Charging points for vehicles: In Core Strategy Policy TR3 Access and
New Development" iii) Provision of Electric vehicle charging infrastructure"

We would suggest that this needs to be more specific. eg At residential properties there needs to be space for overnight parking adjacent to the property where charging can take place. Charging points need to be provided in car parks, office car parks and communal areas.

Historic rural roads including those within villages must be protected for their intrinsic value and any new access points to this network must not detract from the character and appearance of the locality, especially the need to retain banks, hedges, walls and roadside trees

4 Footways
There is precious little in the current Core Strategy. Nothing in the Transport chapter and the only oblique references are in the Rural Areas chapter - Policy RA1 (vi) 'improved access to basic day to day services...by public transport, walking and cycling...', and RA2 (vi) '..support enjoyment of the countryside and coast through improving access..' These are not very strong or helpful to promote what I call below in official speak MUNMRs!

So we suggest a policy along these lines:

Footways Policy

We support:
*The development of a network of high quality multi-user non-motorised routes
with appropriate signage throughout the District.
*Access points across major roads and railways for the public rights of way network and other strategic MUNMRs will be protected and proposals for new crossings will generally be supported. (This is to stop people like Network Rail blocking off footpaths where they cross railways).
*Residential developments should wherever possible, incorporate attractive links,
accessible to all, to the nearest point on the public right of way network and local
foot way networks.
*Where Rights of Way (footpaths and bridleways etc) are removed, or
compromised by development, there will be a loss of the visual amenity and
probably safety concerns with new local traffic. Alternative Rights of Way need to
be found which will create opportunities with new visual amenities with access
and connectivity with local Rights of Way.
*Development proposals that would have an unacceptable adverse impact on the
amenity value of public rights of way, other public non-motorised routs and access
land will be refused.

NOTES ON CORE STRATEGY DOC WITH POLICY REFERENCES:

EN 4
Reduce street clutter - should be expanded to include cars parked on bus stops - an
endemic problem in Rother. Battle High Street has cars parked on bus stops "100% of the time" according to an interviewed bus driver. Sackville Road Bexhill has cars
frequently parked on the westbound side.

EN 5 vii/EC 6 i
' increase accessibility to the countryside from urban areas'. Good idea but bus services have declined. In the last two years, Bodiam Castle has had no Sunday buses on summer Sundays. In that period visitor numbers have risen by 28,000: the most popular days are Sundays (see attached chart). Most visits are by car on roads not well suited to high volumes of traffic. Even the Sundays that sit within a Bank Holiday have no bus. The Battle - Robertsbridge summer Sunday service is also now absent on summer Sundays. This policy is not implemented.

EC6 i The Sunday bus service (if restored) has the potential to reduce traffic, which in the case of Bodiam Castle, detracts from its setting and excludes sections of the
population. This will become increasingly important as tourism from abroad continues to rise due to weakness in the £ and, for the same reason, the 'staycation' market also grows. This is the prediction of 'Visit England'.

It also has implications for policy CO 4 (young people who often have to get to work at weekends); CO 5 Older citizens whose physical and mental health would benefit from independence afforded by a bus service, and CO 6, safety which is offered by the bus (professional drivers) and more broadly through challenging the primacy and status given to car travel by transport policies and measures that flow from these which marginalize all other modes.

EN 6 On flood risk, a halt to the practice of replacing gardens by hard standing for cars. Tens of thousands of gardens have been lost with consequent flood risk increase through runoff. See below:
*Large areas of tarmac and concrete for car parks and road space, including loss of
gardens for hard standing increase the risk of flooding. In flood risk areas of
Southampton, a 23% increase in this garden loss has led to a 26% increase (this may increase) in flood storage needs. There is also of course biodiversity loss.

Negative effects include a reduction in water available to recharge aquifers and greater inefficiency in the operation of 'sustainable drainage systems' (suds), undermining policy SRM 2.

Essentially, this is also an increase in 'road space' with rising traffic levels the result.
There are obvious negative health impacts.

In LHN section, I can't see a reference to the pre-requisite to have high quality public transport access to housing sites. An example in an 'urban fringe' would be the need for bus priority measures from Barnhorn (east of Little Common) to Little common roundabout to offer high quality bus links into Bexhill and Hastings on the 99 route. But the principle of public transport access should apply comprehensively to new developments and expanding villages/towns.

Transport measures - and the mechanisms for analysis of problems, need and
implementation of appropriate measures - are confusingly the responsibility of a whole range of bodies from parishes, Districts and ESCC (the statutory authority) through to LEPs and in the near future, the SE 'sub-national transport body' (SNTB). We need to know more about this from ESCC who - along with other SE authorities - have put up £20,000 to form a 'shadow SNTB.

EC 1 vi
Support for local economies (which function on Sundays - see comments on Sunday
buses and the needs of the young to get to work).

TR1
i Costs of the BHLR continue to rise - with the acknowledged possibility of further threat of more increases, and benefits questionable and yet to be delivered.

ii Traffic on the 'strategic transport corridors' and its 'origin/destination' is sufficiently
understood to warrant a more sophisticated response in terms of appropriate measures pursued to meet need. For instance, most traffic on the A21 moving north-south in Rother is beginning/ending south of Tunbridge Wells, yet the bus services operating in this patch, linking villages with towns- and where advantageous, railway stations - and employment/education destinations are diminishing. All too often, the emphasis is on major road expansion: this is simplistic and ultimately damaging to local economies, environment and public health.

iii Outside of bus 'trunk routes' such as the 99/100 services, investment in bus services has diminished. In the case of the Bexhill - Hastings bus priority measures,
implementation is significantly delayed, reducing the congestion relief function of the
BHLR. Bus priority measures are now needed between Barnhorn and Little Common, as well as traffic restraint that challenges the parking 'free for all' in Rother District.

The relegation of the new railway station at Ravenside/Glyne Gap to a 'maybe at some future time' facility, further reduces the 'value for money' (already poor) of the BHLR. The new signalling regime on the east Coastway, would permit a sufficiently good service for Ravenside/Glyne Gap station. This removes a key justification of RDC/ESCC in removing the station from plans.

Progress on expanding opportunities for walking and cycling is far too slow and the
potential health benefits far too great to ignore or to regard as a 'peripheral issue'. Crisis in our hospitals and pressure on GPs requires a far greater emphasis on 'pro-active' healthcare, and 'active travel' to deliver short, medium and long term benefits, coupled with efforts to tackle poor air quality at every level of government.
iv Include specific mention of support for proposals to re-open the Uckfield - Lewes,
Eridge - Tunbridge Wells railway line to expand 'car free' accessibility opportunities for all travellers.

TR2 IM1
Quite sound policies: a shockingly slow pace of implementation.

The primacy of the car is far too strong an element of policy and implementation. It is electoral suicide to even gently challenge the 'rights of the motorist'. We need
courageous politicians and better education of the public.

Robust monitoring please (IM1)

TR3 ii
In Wealden, this strand of policy hasn't worked 'on the ground' with public transport,
walking and cycling infrastructure not sufficiently in place to serve accessibility needs of developments north of Eastbourne.

TR4/IM2 iii
Suggest that for the urban areas of Bexhill, together with Hastings, a 'workplace parking levy' be introduced to help fund a whole range of 'sustainable and healthy transport measures'.

That the 'laissier faire' attitude to illegal and anti-social parking be exchanged for a
system fairer to pedestrians and bus users and a policy statement be included to reflect this.

Footnote:
18.41
Given the limitation to existing public transport infrastructure, a car is seen as a
necessity in many rural parts of the district.

So let's have some more support for local bus services!