Two documents, Transport Assessment and Travel Plan have been provided in the application.

These documents list many theoretical assumptions which are unlikely to be believed by the local community as they are being used to drive a conclusion that this site can be considered as suitable for a development with minimal car usage.

Despite all the “data”, which contains numerous errors and inaccuracies the core message is that this development is going to be sustainable on the basis of providing;

·      A Travel Pack to be given to all residents

o  Showing how many facilities are available within walking / cycling distance

o  Encouraging them not to use cars

·      Appointing a travel co-ordinator for a period of time to talk to residents

o  No commitment is made as to timing

o  No commitment is made as to how this is funded

Clearly this is woefully inadequate given the following points;

·      In looking at the theoretical data there is no recognition of the topography of the area.

o  It is all very well saying people can walk into Hastings Town centre to do their shopping as it is within a recommended distance, the reality of walking back up very steep hills carrying shopping bags is totally impractical and will not happen

o  The same applies to cycling with the topography making those journeys significantly more arduous and unlikely to be achievable by irregular riders

o  The requirement for the return journey appears to be ignored

·      There are significant errors and omissions in the data provided, for example;

o  The document lists 2 nurseries as being well within the 3.2km so called acceptable walking distance.

o  In fact one of those is about 1.6km away and would require young children walking along the busy Ridge road and Elphinstone Road with it’s very steep hill.  What risks to health and safety? How many accidents resulting in harm to nursery age children would be acceptable?

o  The other nursery is based at the Conquest hospital and is only for employees of the NHS.

o  The diagram showing facilities within a radius of the development has a category shown as Doctors/Pharmacies and has 3 marked. However these are all pharmacies and the nearest doctor surgery is approximately 2.5km away. This clearly masks the fact there is no accessible surgery within reasonable access.

o  Sandown Primary school is listed at 1.8km, again requiring very young children to walk along a busy road.

o  Accessible – NO!

·      The Services & Facilities sections refer to public transport, car clubs and parking management.

o    There is limited public transport during the day but not 24 hours so does not provide for a location without the requirement for cars

o    Car Clubs are not covered in the plans but are not visible in Hastings currently so unlikely to develop just for this development

o    Parking has been addressed in a separate section of this website but with inadequate parking space provision parking management is going to be impossible.

·      The location of key facilities such as supermarkets are not accessible on foot and suggest the use of convenience stores which are expensive options for basic necessities.

The Transport Plan notes the following;

·      Car parking will comply with current council standards, however the wider community knows that this is always inadequate leading to parking in surrounding areas

·      2.7.2 – states there is no detrimental impact to the public highway but nowhere is this proven

·      The NPPF requires making transport considerations an important part of early engagement with the community – it has been minimal to date

·      3.2.2 states it needs to be sustainable – this is not the case due to limited facilities and local topography

·      3.2.4 requires that residual cumulative impacts on the road network should be considered – no evidence is presented to show this has been done

·      3.3.10 states access to the South of the site is not practicable – no support evidence for this statement is given.

·      3.3.12 says the access point satisfies the policy statement but failure to discuss other access points nullifies this

·      4.2.20 is not a supported statement, people walking along the Ridge are at risk which can only increase with increased traffic.

The Travel Plan comments on how the changes in the Highway Code now make it much safer to cycle, even if this statement is accepted there are no plans (or space) to create cycle lanes so it cannot be sensible to encourage more cyclists on to the main East/West Highway with it’s non-stop flow of traffic. Assuming drivers adhere to the new guidelines than an increase in cyclists on this road will only serve to make delays on this road worse.

In general the conclusions of the document should be refuted as so many of the options are not realistic considering  the geography and the very busy nature of the routes required to be taken by pedestrians or cyclists  and that the report contains factual errors.

The nature of the report suggests a desktop exercise with little or no knowledge of the actual site and surrounding area.

The NPPF states that all significant development should be focused on locations that are or can be made accessible – it is clear from the geography of the site that this is not sustainable and there are no plans to make it sustainable.  This development should be rejected on these grounds. The NPPF goes on to say that unacceptable impact on the residual cumulative impacts on the road network should be considered.