Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 26868

Received: 22/07/2024

Respondent: Fairlight Preservation Trust

I am submitting this response on behalf of the Fairlight Preservation Trust (FPT), a body that works closely Rother District Council (RDC) in matters connected with erosion of the cliffs in the region of Fairlight Cove.
FPT welcomes the measures RDC have implemented in recent months in connection with the threat of coastal erosion. The Article 4 zone requires permission for any development in areas particularly vulnerable, and the larger Coastal Change Management Area (CCMA) which is found on the Local Draft Plan also limits what can be done within 50ft of the cliff edge.
The danger that the FPT sees in such arbitrary boundaries is that there is an implication that anything goes, even a few metres outside the zones. The geology of the region is variable, with some areas on a little rock, and some without any. This makes some areas more susceptible to damage from development than others, which is an issue not reflected in the arbitrary 50ft boundary. Whilst we understand that the area covered by the CCMA was decided upon after professional consultation, we feel it is important to underline that areas close to, but not within the buffer zone might still have to prove that any proposed development will not affect ground stability.
A case in point is the proposed new Bungalow at Bairnsbourne, Sea Road (RR/2023/976/P). This lies some 15m outside of the CCMA buffer zone, but the Planning Application was turned down by RDC because it was felt that the geological investigation of the site had not been sufficiently thorough. The owners of Bairnsbourne have now appealed to the Inspectorate, and it is hoped by the FPT that the State Inspectorate will uphold the decision of the RDC Planning Committee in this matter.
The FPT also notes that all the indications are that this new Labour Government is keen to encourage house-building, and to make the process easier. In an area like Fairlight, widespread development such as that recently sought in the East Field, could have a dramatic effect on the coastline. We would ask that, whatever pressure is applied to RDC by Central Government, the need for a thorough assessment of the effect of such development is borne in mind.
The only other point that the FPT would like to make in connection with the Draft Local Plan concerns the requirement mentioned to ‘Hold the Line’ for 50 years in matters concerning cliff protection. We understand that RDC is duty bound to pay for the costs involved in maintaining the sea defences that were constructed at huge expense. This may well require large sums of money, but it must be done. As RDC is aware, the pumping system is in desperate need of an overhaul, which may have to be carried out by the French firm, TPGEO, that installed the system. In addition, the area in front of the Compressor House has been subject to erosion recently, and it may have to be moved. The FPT will expect RDC to honour its commitment to maintain the sea defences.