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COURT LODGE OAST, UDIMORE, RYE, EAST SUSSEX TN316BB
TEL: 01424-883 319 E-MAIL:NBING@METRONET.CO.UK 

5 July 2007

Head of Planning
East Sussex County Council
Transport and Environment  Freepost LW43
LEWES
East Sussex BN7 1B


Dear Sir

BEXHILL – HASTINGS LINK ROAD

Friends of the Brede Valley objects to the application for the Bexhill-Hastings Link Road.

1. The Friends of the Brede Valley 

Friends of the Brede Valley aims to protect the landscape and environment of the Brede Valley and surrounding areas, including the AONB around Hastings and Romney Marsh. We have members both from the locality and wider afield, reflecting the national importance of the landscape which includes the historic Cinque Port towns of Rye and Winchelsea. 

FOBV began as Save the Brede Valley in 1993. We have worked to obtain changes in transport policy and planning in East Sussex ever since. We support the outcome of the Access to Hastings and South Coast Multi-Modal Studies which is that there will not be a major road along the South Coast, that more sustainable forms of transport will be developed, and that local transport solutions will be sought.

2. Objections in principle to Bexhill-Hastings Link Road

We are strongly opposed to any increase in road capacity or new road scheme that will increase traffic on the A259 and A28 between Hastings and Ashford. The Hastings Eastern Bypass (A21 at Baldslow to A259 at Guestling Thorn) would have had a serious impact east of Hastings by increasing traffic and thus pressure for road-building between Hastings and Ashford. Upgrading of the A259 east of Hastings (such as building of bypasses) is not possible without serious damage to the remarkable landscape of the Brede Valley, the settings of Rye and Winchelsea, and the stretch of Romney Marsh between Rye and Brenzett. 

Any road that would connect the A259 west of Bexhill Town Centre with Queensway and The Ridge in Hastings would be likely to increase traffic on the A28 and the A259 east of Hastings. Building any new road across Combe Haven which would bring traffic along Queensway to The Ridge, would create pressure for the Eastern Bypass because of the problems it would create on the Ridge from Baldslow past the Conquest Hospital to Ore, and on the A28 through Westfield, Broad Oak Brede, and beyond, to Tenterden.

That one section of new road in the Bexhill-Hastings area can lead to another is demonstrated by the County Council’s own admission (The Times, 3 March 2004), that the link road could eventually be extended to cover the full route of the original bypass. “If the Government decided it had made a mistake in 2001 and it wished to promote a trunk road bypass round Hastings and Bexhill, then no doubt they would make use of the link road,” according to the then Director of Planning and Transport. 

The Bexhill-Hastings Link Road would also have a harmful effect on Hastings. By making a connection with the Crowhurst Road, it would add traffic to that road and its continuation, Wishing Tree Lane and Springfield Road in Upper St Leonards. The BHLR would not reduce traffic in Hastings; by moving traffic from the A259 onto other roads in the town, it would increase rather than reduce impact of traffic and the impact would be felt over a wider area.

The BHLR would add to traffic problems by increasing road capacity between the two towns and thus generate (induce) a significant amount of new traffic. At present the total volume of traffic, particularly at peak hours, is restricted by the limited road capacity on the A259 between Harley Shute Road and Glynde Gap. Building a second road would release this constraint and the result would be more car trips between Hastings and Bexhill (and beyond) than at present. This is shown by the increase in CO2 that the BHLR would generate.

3. Conflict between the proposal and Government climate change policies

The BHLR fails to comply with crucial Government policies on climate change. Instead of reducing CO2 emissions its effect will be to increase them.

In a list of local authority roads currently proposed in all of England, the BHLR is the second-worst in terms of impact on Carbon Dioxide emissions. The most recent estimate is that the BHLR would add nearly 6000 tonnes tof CO2 to the atmosphere each year, compared to not building it. In all of England, only the East Kent Relief Road Phase 11 is worse in terms of increased emissions (8520 tonnes per year). 
(Source: Parliamentary Answer By Gillian Merron, Department for Transport Minister, Hansard 17 May 2007, col 841W, and East Sussex CC published information on BHLR.)


4. The published route north of Combe Haven

The published route seeks to avoid both the Combe Haven SSSI and the High Weald AONB, but would have an impact on both. The route selected is the same in relation to Combe Haven as that promoted by the County Council in 1990 at the time of public consultation on the then proposed A259 Trunk Road Bexhill and Hastings Western Bypass, and at that time called the ‘Modified Orange’ Route. 

The ‘Modified Orange’ Route was rejected by the Secretary of State for Transport in December 1990. He decided that it would be more damaging to the landscape, farming and nature conservation than routes further south. Relevant passages from his statement are attached.

The alternative routes south of the Combe Haven, which would require a direct crossing of the SSSI, have been rejected as unacceptable in terms of impact on landscape and nature conservation. The Secretary of State for Transport rejected the ‘Modified Orange’ route north of Combe Haven; it would, he concluded “severely affect the landscape on the north side of the valley and have a severe impact on farming and isolated properties”. 

The route now published is very similar to that route rejected in 1990. The landscape where it would be built is even more attractive and valuable than it was in 1990. The application should be withdrawn and other solutions to the needs of the Bexhill-Hastings area adopted. 

Yours faithfully

Nicholas Bingham

Chairman, Friends of the Brede Valley


APPENDIX

EXTRACTS FROM SECRETARY OF STATE’S DECISION ON ALTERNATIVE ROUTES FOR BEXHILL & HASTINGS WESTERN BYPASS, DECEMBER 1990

'28. In Section 2 [between the A269 and Mayfield junction with Queensway] it is considered that the Red or Orange Routes would have, overall, the least impact on people or property. With the need for two level junctions, the impact of the Blue Route at Lunsford Cross would be more severe with one property requiring demolition. Between the A269 and Combe Haven, Red or Orange would have least impact on the landscape, nature conservation and farming interests. Within Combe Haven the Red Route is considered to be less damaging than Blue or Orange in its impact on the landscape the effect on nature conservation and farming. ESCC proposed their modification to the Orange Route to take it out of the Combe Haven SSSI but this cannot be fully achieved when the route is realigned to provide a two level junction at Mayfield Farm. In addition the modified Orange Route would severely affect the landscape on the north side of the valley and have a severe impact on farming and isolated properties.


‘29. During consultation people living in or near Combe Haven reported that it was prone to localised fog. This was confirmed by investigations following public consultation, but the effect of fog on routes could be minimised by adopting higher elevations for the routes. This could be easier to achieve with the Red Route.


‘30 ......... In Section 2 he noted that the prime objective of modifying the Orange Route cannot be fully achieved and that there are several conflicting interests to be taken into consideration. On balance he considers the Red Route would provide the most satisfactory solution.
.........'.