Proposed Submission Development and Site Allocations (DaSA) Local Plan

DEVELOPMENT AND SITE ALLOCATIONS LOCAL PLAN Proposed Submission

I am writing on behalf of The British Horse Society, a charity with over 102,000 members, who represent the UK's 2.7 million riders.

Rider safety has been on the list of subjects at recent parliamentary debates and so I would like to remind the Council of the statistics:
* Equestrians have only 22% of the rights of way network nationally. These are frequently disjointed or 'dead-end' paths (for example bridleways becoming footpaths or connecting to roads which are now unsuitable for equestrians) and so the usable proportion is likely to be considerably lower
* Since the launch of The BHS Horse Accidents website in 2010 there have been:
More than 2,914 reports of road incidents involving horses;
230 horses have died;
39 riders have lost their lives
* The cost of a fatal road traffic collision is around £1.8million per casualty; with even slight incidents around £18,000 per casualty (www.gov.uk/government/publications/reported-road-casualties-great-britain-annual-report-2016) based on medical, police, insurance, lost output and 'human' (distress, suffering, pain) costs. It does not take account of secondary costs to other people affected by a road traffic incident, for whom the consequence of delays could be considerable.

The National Planning Policy Framework, section 8 Promoting healthy and safe communities , 91c
By ensuring that equestrians are included within non motorised route provision the Council will be able to
"enable and support healthy lifestyles, especially where this would address identified local health and well-being needs..." because:
* More than two thirds (68 percent) of questionnaire respondents participate in horse riding and associated activities for 30 minutes or more at least three times a week. Sport England estimate that such a level of sporting activity will help an individual achieve or exceed the government's recommended minimum level of physical activity
* A range of evidence indicates the vast majority (90 percent plus) of horse riders are female
* More than a third (37 percent) of the female riders who took part in the survey were above 45 years of age. Horse riding is especially well placed to play a valuable role in initiatives to encourage increased physical activity amongst women of all ages
* Amongst the horse riders who took part in the survey, 39 percent had taken no other form of physical activity in the last four weeks. This highlights the importance of riding to these people, who might otherwise be sedentary.
Horse riders with a long-standing illness or disability who took part in the survey are able to undertake horse riding and associated activities at the same self-reported level of frequency and physical intensity as those without such an illness or disability ( Research undertaken by the University of Brighton and Plumpton College on behalf of The British Horse Society)

Economy

The most recent BETA National Equestrian Survey (2015) (The British Equestrian Trade Association (BETA) represents more than 800 member companies.) indicated:
* Estimated £3,600 spent on each horse*
* £4.3 billion economic value of the equestrian sector
* 944,000 horses in Britain
* 1.3 million regular riders of 2.7 million total

Non motorised users

When providing for NMUs within the local plan, we urge the Council to make them available to ALL NMUs including equestrians. Even if use by equestrians seems unlikely in the current situation, new access may well provide useful links to keep equestrians off the road, if not immediately then following further change or development. "Behind the hedge" routes alongside developments help protect vulnerable users from the ensuing increased traffic from said developments.

Suppressed demand for bridleways should also not be underestimated. Where there are bridleways/restricted byways provided, equestrians will come, bringing their substantial contribution to the local economy. Where very good routes are available, equestrian tourism is also a good contribution to the economy and is a very good sales point for the Council. Businesses such as Horses Welcome B&Bs and Horse Friendly pubs emphasise the suitability for equestrian (and other NMU) tourism.

Bridleways legally encompass walkers, cyclists and equestrians and restricted byways also include horse and carriage and so making a route a bridleway or restricted byway makes this availability more obvious to all users. Whilst many footways/cycleways "invite" or don't actively "discourage" use by equestrians this is not obvious to horse riders or indeed to other users and so conflict may occur. Where access is provided which is not a public right of way but is nevertheless accessible to all NMUs, the highways sign NP.956.1 makes the intended usage clear and we urge use of this sign in these situations. Segregation is rarely necessary; every PRoW to which equestrians have access is shared with all other users, very few are segregated and conflict is rare (agreed by Ramblers, Cycling UK and BHS at the highest level).

We also strongly urge the Council not to use existing bridleways and restricted byways to provide vehicular access to new development. Even a moderate sized development will increase exponentially the traffic along the route (with household traffic, courier vehicles and other vehicular traffic servicing the houses and development), probably necessitate its surfacing with materials not ideal for horses and render the route no safer than a road for equestrians, effectively eliminating the safety of the off-road access.

With regard to the policy, specific comments follow:

Equestrian Developments 3.20

The BHS produces a leaflet, http://www.bhs.org.uk/~/media/bhs/files/pdf-documents/welfare-leaflets/pasture-managment-april-2017.ashx which indicates that the ratio should be no more than 2 horses per hectare. One horse per hectare seems overly cautious and, whilst Natural England may propose this ratio in an area of AONB (the source from which the statistic has been taken by Rother DC), it would not be necessary otherwise.

Policy DCO2: Equestrian Developments, section v
"Where possible, commercial riding schools, livery stables and other commercial facilities should have satisfactory access to the public bridleway network without the use of unsuitable roads and in all cases not adversely impact on road safety."
Whilst this policy might seem sensible, the definition of "unsuitable" is subjective and we would suggest that the final clause should apply to ALL development, not just equestrian development.

Finally, as an example of a recent local plan which has included equestrians, I attach below an excerpt from the adopted version of the Mid Sussex District Plan 2014 - 2031 which has managed to include equestrians as part of its rights of way considerations. We would urge Rother to include similar policies so that their Rights of Way network will be improved rather than degraded by future development.

The BHS would welcome the opportunity to work with the Council when considering rights of way provision within new developments.

Mid Sussex Local Plan

DP22: Rights of Way and other Recreational Routes
Strategic Objectives: 5) To create and maintain easily accessible green infrastructure, green corridors and spaces around and within the towns and villages to act as wildlife corridors, sustainable transport links and leisure and recreational routes; and 15) To create places that encourage a healthy and enjoyable lifestyle by the provision of first class cultural and sporting facilities, informal leisure space and the opportunity to walk, cycle or ride to common destinations.

Evidence Base: Neighbourhood Plans; West Sussex Transport Plan 2011-2026; West Sussex Rights of Way Improvement Plan, South Downs National Park Access Network and Accessible Natural Green Space Study, Capacity of Mid Sussex District to Accommodate Development Study.

Rights of way, Sustrans national cycle routes and recreational routes will be protected by ensuring development does not result in the loss of or does not adversely affect a right of way or other recreational routes unless a new route is provided which is of at least an equivalent value and which does not sever important routes.
Access to the countryside will be encouraged by:
*Ensuring that (where appropriate) development provides safe and convenient links to rights of way and other recreational routes;
*Supporting the provision of additional routes within and between settlements that contribute to providing a joined up network of routes where possible;
*Where appropriate, encouraging making new or existing rights of way multi-functional to allow for benefits for a range of users. (Note: 'multi-functional will generally mean able to be used by walkers, cyclists and horse-riders).


In accordance with the National Planning Policy Framework (paragraph 75), the District Plan will protect and enhance public rights of way,


DP7: General Principles for Strategic Development at Burgess Hill
Provide new and/or improved and well connected sports, recreation and open space in and around Burgess Hill, including the continuation of the existing 'Green Circle' of linked areas of informal open space around the town along with its associated network of multi-functional ( in this context multi-functional means able to be used by walkers, cyclists and horse-riders) paths, the Green Circle network, and links into the town centre.