Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 26876

Received: 19/07/2024

Respondent: Fairlight Parish Council

Proposed Policy ENV4 Fairlight Cove coastal change management area
Fairlight Parish Council broadly welcomes this new policy which in conjunction with the Article 4 directive in place for the immediate coastal area at risk provides a useful agent to current planning and should help to inform potential development of the need for extra care in this area. However, in the draft plan the boundaries for this area have been rather broadly drawn and the demarcation between areas potentially difficult and open to interpretation. It is hoped in the final plan, the demarcation lines will be drawn more clearly and will avoid passing through properties.

Whilst we note that this is looking well into the future, we also note that there are requirements on Rother District Council to work with our current coastal defences to hold the line until at least 2050. However, the infrastructure delivery plan seems ambiguous with regard to Fairlight cliffs. It should be made clear in respect of all three berms, including the pumps on Rockmead Road, that the policy is to hold the line until 2050 at the earliest.

Comment

Representation ID: 26877

Received: 19/07/2024

Respondent: Fairlight Parish Council

Flood Risk - Question 61
Section 5.7 of the Plan states:
‘Development will only be acceptable where it does not have an adverse impact on the natural environment.’
The sewage flooding and discharging within Fairlight is historical, escalating and not in question, as the involvement of Southern Water with Fairlight, in the Pathfinder Project, clearly illustrates. However, this is also coupled with significant surface and groundwater flooding, which compounds the overall flooding endured by the catchment.

The cumulative effect of this flooding, along with the growing number of contributions from the Combined Sewer Overflow spills (CSO's) into the local watercourses, has had a considerable impact in Fairlight, on those downstream in Pett; who have also been badly affected by flooding and on the environment in terms of considerable pollution. there was an appeal against the refusal for planning permission on the land east of Waites Lane which is the only potential development site in Fairlight. This appeal was rejected and the grounds that it was dismissed on are still very relevant. Fairlight Parish Council is therefore asking for all the planners to consider de-allocating the site on the land east of Waites Lanes.
Since there has not been a sequential test that has considered flooding from all sources, including groundwater, the site cannot be allocated and the proposal is in breach of section 5.7 of the Rother Local Plan.

Comment

Representation ID: 26881

Received: 19/07/2024

Respondent: Fairlight Parish Council

Sustainable Drainage - Questions 186 and 187 Policy ENV
Any development within the proposed allocation site in the Draft Local Plan would cause additional sewage surcharge and flooding within the catchment. Any further development that occurs will also impact the entire sewer system hydraulically, which as mentioned is ultimately limited by the fixed constraints and capacities inherent within the network. Greater sewage input by further development would also add to more spills in all 4 of the CSO sites and along with longer durations of those spills this would make the flooding issues worse. This would undoubtedly contribute to greater pollution than already currently exists. During active discharge it equates to 85% of the sewage pipe at the CSO, the environmental impact would be considerable and contribute further to the impact on the RAMSAR site downstream. The CSO spills alone within Fairlight are excessive, and the additional contribution with ground and surface water flooding, should not be made worse by any proposed development. The dry weather flow spill from a CSO within the catchment last year; the discharge of which is meant solely for emergency hydraulic relief only, is another indicator of serious concern.
Southern Water‘s failure to take account of the creep, infill and development over the preceding decades by updating their Waste Water Treatment Works is not a quick or an easy issue to resolve, if indeed a remedy is possible.
Southern Water has written in correspondence, that the selection of Fairlight for any upgrades, particularly for upgrades to the works, 'has to be measured against the other assets within its regional catchment', so may not receive the necessary resolution at all. Southern Water also make it clear that, 'Their AMP's are to produce indicative costs and timescales; for planning purposes only, and are not a commitment to fund or delivery any option”

Comment

Representation ID: 26882

Received: 19/07/2024

Respondent: Fairlight Parish Council

The Parish Council appreciate that an application for planning can be submitted despite the allocation status, but we are strongly of the opinion that the proposed site in question should be removed from the RDC Local Plan.

With known sewerage and water problems of this magnitude, it cannot be left to chance or be allowed to become a casualty of indicative plans and timescales that never materialise.

A true resolution needs to be found and its viability needs to be rigorously tried and tested for a considerable period, before any allocation is made.

The Parish Council also feels that Fairlight is not suitable for further development on a large scale due to a number of factors pertinent to the village the roads used to access it, the distance of the current proposed allocated site from the rest of the village, and also the impact of the development would have on the environment and the current dark skies.

Comment

Representation ID: 26890

Received: 19/07/2024

Respondent: Fairlight Parish Council

Section 4.3 and 4.4
The proposed allocated site for Fairlight although it appears to be part of the village could only be accessed from Pett Level Road creating a distance from the village amenities, these distances are not insubstantial being about 1300m to the village pub with similar or longer distance to the Village Hall and the recreation area. Residents would need to traverse a very narrow footpath on Pett Level Road, which is a bus route with double decker buses, making this almost impossible for families with children and pushchairs, or indeed people in mobility scooters to use this footpath safely. Contrary to the outline summary provided by Rother concerning the Draft Local Plan in Fairlight, the village also lacks amenities such as a doctor surgery, a village shop and post office (i.e. no access to banking services etc.), or a local primary school, which is easily accessible by public transport. This doesn’t fulfil Policy LWL3.

Comment

Representation ID: 26895

Received: 19/07/2024

Respondent: Fairlight Parish Council

Live Well Locally – Health/Well-Being and Climate Change
Additionally, it is not possible for people living in Fairlight to access a primary school, secondary school, further education, employment centres, town centres, shops or the local hospital and GP Service; by cycle or on foot, within either 15 or 30 Mins. This not only places heavy reliance on the use of cars to access essential amenities and services, but as indicated by the RTPI, would adversely impact the changes required to people’s day to day living, in order to achieve carbon net zero by 2050
Any proposed allocation would contribute greatly to that reliance on cars.

Fuel poverty (both heating and transport costs) is a known issue within the Village, as the services of the Parish Council’s Drop in Social Hub clearly demonstrate.

Comment

Representation ID: 26902

Received: 19/07/2024

Respondent: Fairlight Parish Council

Green to the Core
As mentioned above the proposed allocated site for Fairlight does not conform with several of the green to the core ideals. Indeed, this proposed site would create an isolated community with in the village, cut off by a busy C Road (Pett level Road), and served by a bus service that is not always reliable, but which is at best once an hour and unable to offer late night workers or early shift worker transport to home or work. The site would also encroach on the AONB.

Comment

Representation ID: 26905

Received: 19/07/2024

Respondent: Fairlight Parish Council

Landscape Character
The proposed allocated site in Fairlight would severely diminish the dark skies which we are currently able to enjoy. The dark skies are not only of importance for humans, in terms of recreational stargazing and the lack of light pollution allowing the natural day/night difference, but also the impact on wildlife.

Comment

Representation ID: 26910

Received: 19/07/2024

Respondent: Fairlight Parish Council

Existing Wildlife Corridors and Dark Skies - Questions 181 and 182
The development itself would interfere with wildlife corridors and evidence has shown that artificial light at night also has a negative and deadly effect on many creatures including mammals, amphibians, birds, insects and plants. Development would also contribute to the identified fauna and flora losses, already featured so far in Rother’s Biodiversity Reports (AMR) (2019-2023)

Being a coastal village next to the English Channel, Fairlight is on migration routes not only for birds but also for many butterfly and moth species. The loss of the dark skies could cause adverse effects on these populations. The lack of street lighting in small villages locally is intended to preserve the dark skies which we have.

Fairlight Cove has a Bortle classification of 4. Skies are classified using the bortle scale and range from 1 to 9, the lower the number, the darker it is. This demonstrates how special this area is. It would take very little additional lighting, especially security lighting and leakage of light from windows particularly Velux windows, to change this scale significantly.

The International Dark Skies Association says ‘the unusual and unique dark skies over the high Weald AONB and surrounding areas have been identified as worthy of conservation’