Commenting on Wealden Local Plan

Introduction

Whether you live in Wealden or on the borders of Eastbourne, Lewes or Rother additional housing growth, in the Wealden area, will affect you. So you should comment on the Draft Local Plan.

“Wealden District Council is preparing a new Local Plan. [it] will be the key planning document for Wealden District. Once adopted, the Local Plan will form part of the Development Plan for the District, replacing all existing local plan policies and will be used to assess and make decisions on planning applications.” There will be 16,000 new houses of which around 8,000 have already been planned for .

It is a challenge to go through all the background documentation. The consultation itself is over 200 pages. So this blog has had to be selective. To begin with here are the top 8 areas in terms of new housing

Most of this will be in South Wealden and especially on the borders of Eastbourne. From this table you can see that much of the local area is already ‘confirmed’. In Willingdon for example all the space is already committed apart from some ‘windfall’. So you may feel it is too late. This is not the case. Within the plan are some policies that have some merit and these should be supported.

Here are some links you will need . The Wealden Local Plan itself including a short video . Then the Consultation Portal – Where you create an account and add comments

Background

The lack of a local plan has made Wealden vulnerable to developers who were likely to win, if they appealed, when their planning submission was rejected. With a plan the council has more control of where housing can go. Without a plan the growth of housing could be higher. If there is a proposed housing development ,that you do not agree with, then you can highlight this in your submission, ideally linking it to the relevant policy.

One of the key concerns is the transport infrastructure. Before reading the rest of the blog you may wish to read this blog, on how over optimistic future predictions , are used by councils and developers to the detriment of residents.

Discussions with relevant district officers, councillors and directors suggest there may be residents who do not support a greener and more active travel agenda . Therefore it is important to support these policies and schemes.

Below are a number of the key chapters in the consultation that are worth commenting on. :-

Chapter 3 is Vision and Objectives

Suggest you strongly support “Sustainable and active travel’ but make points as to how this is not being addressed.

There has been no evidence of any increase in public transport, wheeling, cycling and walking. Many County, District and Borough plans refer to a planned shift away from cars . This has never been delivered. In fact East Sussex CC has not achieved any change in the mix of transport and total vehicle trips have simply increased

Suggest the need for high level plans across multiple sites. There are many examples where each site has its own access road and no attempt made to have public or active travel routes through these developments . For example at Horsebridge there is an area with over 5 different adjacent estates with no co-ordination of the access across them. A house that you want to visit, maybe only a few hundred meters away, but the car may need to exit one estate and then enter another one. On top of this the connections to the Cuckoo Trail, tell cyclists to dismount and push over 200m on sandy narrow tracks to get to the estates. Discriminatory especially to those who use mobility scooters, elderly or with heavy e-bikes

There needs to be a clear strategy to deal with the effect of all this housing growth on the current residents, where the existing streets might have more ‘permeability’ and could then be used as ‘rat runs’.

Plus stress more emphasis needed on actively supporting greater biodiversity, perhaps in adjacent areas, to counteract the consequences of this extra urban housing. Perhaps though Section 106 agreements.

There does not seem to be enough on encouraging reaching net zero through the design of housing in terms of their location and the wider community. This would strongly support higher insulation, solar panels, EV charging and heat pumps

Chapter 4 – Spatial Strategy

Suggest you strongly support “4.18 The benefits of a 20-minute neighbourhood concept are extensive, providing health, social, environmental and economic benefits to people and communities. Additionally, the concept would seek to tackle many of the issues that we need to address through our plan such as reducing carbon emissions, helping people to become more active, reducing mental health issues and loneliness, improving our town and village centres, making our settlements great places to live as well as improving access to affordable healthy food.”

Support the statement in “4.26 East Sussex County Council’s Local Transport Plan 4 Consultation(12) supports the 20-minute neighbourhood or the ‘complete, compact and connected neighbourhood’ approach by providing a shift towards supporting healthy lifestyles by walking, wheeling or cycling and more active travel, as well as through the design of public places and healthy places through integrated neighbourhoods.”

So from the above, mention your support for higher density dwellings in the centres which should have access to a mix of leisure, shopping and business all nearby and accessible by bus or active travel. You could also add support for 20 mph and school streets

Support – “Policy SS9: Health, Wellbeing and Quality of Life”that creates improved connectivity and supports healthier and more active lifestyles

Chapter 5 – ‘Climate Change’

Generally strongly support

CC1 Net Zero Development Standards – New Build. Support Policy but would prefer a clearer steer around residential standards of insulation, solar, batteries and heat pumps. There are no examples locally which could be seen as evidence of the ideal higher standards

CC4 Carbon sequestration, Support Policy but make the point, large areas of land are being urbanised and it is unlikely that sequestration could be achieved in or around the new housing estates

Policy CC5: Renewable and Low Carbon Energy. Agree with the principle of “Support will be given to community led energy schemes where evidence of community support can be demonstrated”

Policy CC6 Water Efficiency . Support the principles though make the point it is partly the cumulative effect of all these new houses which will determine how both water and waste (Southern and South East Water) cope. Some of the pumping stations, pipes and sewage works are already under strain

Policy CC7 Managing Flood Risk. Support the principle though areas such as between Polegate and Willingdon have always been susceptible to flooding. Concreting over will add to the problem across all the low lying estates. Make reference to the work the Environment Agency are undertaking around flooding and rising sea level.

Policy CC8 Sustainable Drainage. Support the principle such as in CC7 but perhaps question whether previous experience shows if this been dealt with in the past

Chapter 9 Infrastructure

Policy INF1 Infrastructure provision, delivery, and funding. “The provision of infrastructure facilities such as those relating to healthcare and education should be provided” Stress there needs to be guarantees of them being built and that you have concerns based on recent sites that the delivery of schools and health centres may not happen. This is due to the higher build costs and the funds that health and education may have. Plus a need to adhere to DfT’s “Guidance on Land Use/Transport Interaction Models”

Policy INF2 Sustainable transport and active travel– Support this policy. However the local housing developments simply fail on the criteria listed. No attempt appears to have new been made to create viable routes through multiple estates . Routes identified in the LCWIP, that are supposed to be on these sites ,have not been taken into consideration. Good examples would be alongside the railway from Hampden Park to Polegate (such as routes 312 and 225). Recent experience shows that proposed bus and cycle lanes are very vulnerable to being dropped through pressure from those who do not support them. They must be installed.

Policy INF5 Safeguarding of Infrastructure– Support the concept but as already mentioned there are many potential active travel routes in LCWIP that have been ignored through planning.

Policy INF8 Open space, sports and recreation provision– Suggest make the point – There are large areas of open land that have been lost and this cannot be rectified by a few small parks

Chapter 10 Design

Policy DE1 Achieving well-designed and high-quality places. Support the aim however challenge most of the new developments. These are car centric, low traffic neighbourhoods that do not allow through traffic. Most of the current developments have similar housing and add very few community buildings. The road layouts are meandering and do not support more direct routes for active travel . They also do not support bus routes and this will mean when funding runs out residents without a car will struggle. Perhaps building housing for elderly people should be closer to amenities and bus routes on main roads. In ‘Manual for Streets’ it explains the consequences of building ‘car-centric’ estates that make active travel within the estate and to other destinations problematic

Closing comments.

Please read any other chapters and additional documents, if you want to look into this plan in more detail. You have until Friday 10th May 2024 to submit your comments

Meeting to discuss Local Transport Plan 4

UPDATE: Outcomes from the LTP4 meeting are here.

When: Monday February 12th, 1pm to 4.30pm

Where: in Eastbourne Town Hall

The latest Local Transport Plan for East Sussex (LTP4: 2024-2050) is currently out for consultation, with a closing date of 25 February 2024. The local plan is important as it drives policies and spending priorities.

Come and join us in this open meeting to discuss LTP4 and help shape a response from our network, or plan your own response.

The meeting will take the form of parallel workshops and short presentations. We have invited transport experts, providers and activists, as well as councillors and community stakeholders from East Sussex to participate. The recent Sustainable Transport & Active Travel summit demonstrated how much expertise we have in our community. We also saw the willingness to share that expertise and collaborate in order to make progress. Let’s not waste this opportunity!

To let us know you are coming, complete the registration form here. Note that you don’t need to be an expert to join in – your views are important.

Draft agenda

Welcome and introductions: Councillor Jim Murray
What is a local transport plan and what can it achieve?: Chris Todd, Transport Action Network
Review of LTP4, What do we like, what’s missing? Open discussion with Paul Humphreys and Derrick Coffee
Breakout into parallel workshops looking at LTP4 objectives and exploring the following:
How can we achieve these objectives? What would success look like in our local area? How can we measure progress? What are our targets?
Refreshment break
Feedback from workshops
Open discussion of proposals and practical exercise to rank proposals and update on the One Planet platform
Summary and concluding remarks

Useful info

You should find the following information helpful to look at before you come:

Summary of LTP4 objectives and outcomes – 2 min read
Consultation survey questions – 2 min read
Guidance notes on LTP4 from Paul Humphreys – 5 min read
Response to LTP4 from Lewes Climate hub
See Norman Baker’s summit presentation with thoughts on LTP4 – video and transcript available
LTP4 executive summary from ESCC –
LTP4 draft implementation plan from ESCC
See also other transport presentations on the Transport summit web page

Local Transport Plan 4– Guidance Notes

Introduction

Note- Following comments and feedback new sections have been added, at the end, in indigo – 28/01/24

If you are looking to comment on the East Sussex Local Transport Plan (LTP4), you may find this blog helpful. Hopefully it provides some general guidance. Please remember a short blog cannot address all the issues.

Overall the consultation asks you to score a number of nebulous and intangible statements. For most it is hard to disagree with them. You are asked to provide an overall score on categories that are open to interpretation. These might be for example – strongly agree, agree …..disagree.

However the questions may cover areas where your response might be more nuanced.

As background you may find this blog on the shortcomings of the consultation process of some relevance.

Governance and Reporting

Most project methodologies such as Prince2 have monitoring, interim targets, reports and exception reporting. Most of these are found in the Council’s Carbon Plan .

Section 9. Governance “ Provide oversight of the delivery of the action plan .. Annual reporting to Cabinet and full County on progress “

For transport an equivalent could be modal share. (The split between cars, walking, cycling ,bus and rail). This could be either around private transport (70%) or perhaps for active travel (walking, wheeling, cycling and buses) (20%). Other metrics such as the share of EVs or carbon footprints are perhaps down to national policy.

There were predicted modal share changes, in LTP3, but there appears to be no review undertaken. It is also normal for plans and projects to have a ‘lesson learnt’ process at the end. So for LTP4 , following the approach elsewhere , there should be:-

• 5 year interim targets. With perhaps one or two clear definable metrics.
• Review every 2 years
• Description of the new projects for the following 2 years.

This is described in Theme A Section 4.3 “potentially suitable KPIs [ Key Performance Indicators] …. We will establish appropriate governance to oversee the development, delivery and benefits realisation arising from schemes and policies included in this strategy.”

Action – Request that the governance, reporting and targets are more clearly stated

Modal Shares

In the plan there are a number of scenarios provided. All of them are compared to a 2050 ‘Business as Usual’ scenario . This one below is one of the more ‘optimistic’ of them. All have, to some extent, fewer cars trips and more active travel

You may want to consider, as stated in LTP4, that cycle journeys are recently down. Bus journeys are still not at pre-pandemic levels and the plans for bus lanes have been severely scaled back. There has never been any evidence, of a long term reduction, in the modal share and total trips for cars. This is excluding systemic changes resulting from Covid.

The blog on the dangers of unverifiable modelling may be of interest

Action. Ask for more information how the ‘numbers’ behind the scenarios can be validated

Change of Approach by the Council

Campaigners have seen no evidence, of a change in mindset, as suggested by the LTP4 vision. This month the local bus lane plans have been severely reduced, 20 mph schemes are not considered for wide areas, cycle schemes remain very low, but a priority around cars and large road schemes remains in place

Here is an example from Transport Scotland for a clear direction to reduce national car kilometres by 20%.

“The route map does not aim to eliminate all car use. We recognise that would not be realistic or fair, especially for journeys undertaken by disabled people or in rural areas where sustainable travel options may not always be available or practical. Rather, the route map encourages all of us to reduce our over reliance on cars wherever possible and identifies four key behaviours that we want everyone in Scotland to consider each time we plan a journey:

• make use of sustainable online options to reduce your need to travel;
• choose local destinations to reduce the distance you travel;
• switch to walking, wheeling, cycling or public transport where possible;
• combine a trip or share a journey to reduce the number of individual car trips you make, if the car remains the only feasible option.”

Action – Ask how the council officers and councillors intend to change their approach to transport to support the scenarios they outline in the Plan.

Pollution and Decarbonisation

There are those who think that the issue of carbon can be addressed by a shift to Electric Vehicles (EVs). Instead of the LTP’s ‘People and Places’ the alternative of ‘Avoid Shift Improve’ is much more focussed on active travel, de-carbonisation and alternatives to the private car, even if electric.

For parking perhaps propose charges based on either CO2 or else around the size of the vehicle. You may also wish to comment on the extra journeys generated through the proposed large road schemes, such as the ‘duelled’ A27.

One aspiration, featured in this and the previous LTP, was linking ‘Land Use Planning’ and Transport. There is very little evidence for recent housing developments that this is being take seriously.

Action – If you want to encourage less polluting vehicles then ask how they will be encouraged ( E-bikes, e-scooters, and smaller greener cars)

Action – Ask for ESCC to be more positive in planning applications in supporting active travel and buses in the large car-centric housing developments especially in South Wealden.

Cycling and Walking

The Plan has many references to more walking, wheeling and cycling. However consider from data provided by ESCC, only £165k has been spent, on cycle infrastructure in the last 4 years.

Contrast this with 6.61 “Reviewing and delivering the Local Cycling and Walking Infrastructure Plan – which includes a robust pipeline of deliverable active travel schemes for networks and places – ensuring a balance of schemes to support walking, wheeling and cycling.”

Whatever is written in the LCWIP and in the Council’s budget book, the actual spend on cycling is negligible. The plan ’admits’ that those cycling once a month, in the county, have dropped, in 5 years, from 15% to 10% and is now well below the England average

In terms of walking there has been progress . However schemes that might help active travel such as 20 mph, Low Traffic Neighbourhoods , modal filters and School Streets require a change in approach from officers and councillors.

Action 1) Ask for evidence of investment, not from the Budget Book, but of actual schemes they will build.

Action 2) In the Health Impact Assessment how the general health of the population will be prioritised . This is around reducing obesity, lack of exercise and multiple chronic conditions

Scenarios

The problem of predicting future levels of traffic, is that even with no interventions, the so called ‘Business as Usual’ (BAU) in 2050, is different to now. Here is an example from Transport for South East ( TfSE). This is

from their BAU of 2050. Then the various others scenarios are on top of this. In other words how much the trip balance will change, from BAU, with various interventions. (Note the icon with a cycle is for walking as well)

So the BAU is likely to be similar for East Sussex. Here are various scenarios from LTP4. Unless one of them is chosen then there is no effective track on progress. This may suit the Council as no real accountability exists. Plus the option of having 5 year reviews is then less valid.

Targets

Once an agreed scenario, as above, is agreed there has to be a clear plan to get there. This is called ‘backcasting’ and is the opposite of forecasting. (How do we get there v what might happen). In the image below it shows how it should be broken down into smaller time periods. Perhaps every 5 years.

So in LTP4 there are many schemes and policies but there is no guidance, for readers, as to what would deliver the most change. During the initial workshops there were requests, to provide details as to how the algorithms generated the various scenarios . Otherwise it is a ‘black box’ with outputs that the public have to take on trust. Change would partly be achieved by the schemes and projects listed in LTP4. (Of course some change will also be through National Government). Otherwise you may mention, in your consultation reply, certain schemes that sound good to you, but actually deliver less, in terms of overall change, than another good alternative.

The targets could include :-

modal shares
pollution NOx PMx
road traffic incidents
children specific – such as trips to school
transport poverty of each council , (that shows Eastbourne to be nearly the worst in the South of England.)

Ideally ones that are already recorded and for which there are comparisons across the UK.

Cars

If the most important consideration is reducing carbon then moving from the ‘Internal Combustion’ to Electric Vehicles will do this. Especially within the county where the manufacture and disposal is elsewhere as is most of the electricity production.

However cars are getting bigger and heavier each year. ( 0.5 cm wider p.a) . They no longer fit in car parking places. Brakes and tyres create PM2.5 pollution. When in the road they make passing harder and this increases congestion and road damage. Smaller, lighter cars need to be encouraged. Currently an EV charged at home is cheap per mile and this may encourage even more road miles. If you think road charging might reduce congestion look at this report . As mentioned earlier ‘Avoid Shift Improve’ would encourage alternatives such as more micro-mobility.

Paul Humphreys EEAN -Transport Group

Suncoast Solar Farm Planning Application (ref.230800): setting the context

This guest blog is from Miles Berkley, who was one of the co-founders of the Eastbourne ECO Action Network CIC, and is a Director of TechResort CIC which works from its base in Devonshire Ward helping to tackle digital exclusion, here and across East Sussex. He’s also a member of the multi-agency Lewes District Cost of Living Partners Action Group, and is a subscribing member of Friends of the Earth.

Setting The Context:

Friends of the Earth notes the need to increase at a minimum the amount of locally generated renewable energy in Eastbourne from about 4.8 GWh currently to 28GWh i.e. 5.8 times present levels (UK Climate Change Committee). In fact, Friends of the Earth recommends we go further to reach 56.1 GWh. For more details, look here: https://groups.friendsoftheearth.uk/near-you/local-authority/eastbourne#energy

The Eastbourne Borough Council Carbon Neutral Annual Report (Dec 2023) reveals that the town’s emissions in 2021 rose 6% from 2020 levels to 277.4 ktCO2e, the main source of which is domestic buildings, closely followed by transport. Eastbourne Borough Council has pledged to achieve a carbon neutral town by 2030, which the Tyndall Centre at the University of Manchester states that it requires an overall reduction of emissions by 12.3% per year – which is not being achieved.

We are experiencing the destabilising effects of accelerating global warming with more extreme weather events: storms, flooding, heatwaves, wildfires – all devastating the habitats of every species. We need to rapidly scale up action to decarbonise our energy sources, moving away from fossil fuels, as well as improving the UK’s national energy security.

Biodiversity Net Gain – improvements needed.

The present proposal presents a Biodiversity Net Gain (BNG) of between 24-29% based on the creation of new habitats and water courses, plus the addition of 11.51 new hedgerow units.

In comparison, another similar sized local development of 17MW (compared to 20MW for Suncoast) achieved a 243% net gain in habitat areas, and 104% in hedgerows. This, the Ouse Valley Solar Farm, is supported by Greenpeace.

The Cleve Hill Solar Farm (373MW) development on the North Kent Coast achieves a 65% BNG and is supported by Swale Friends of the Earth Group. The latter development achieved this by reducing the overall area covered by solar panels to 45.5% of the developable area, leaving the remaining arable land to be managed for biodiversity benefits.

The Berwick Solar Farm in Wealden has, for example, installed a Swift Tower, orchards, and thermosolar beehives.

The developers need engage the professional opinion, and support of, local ecologists to conduct further studies, to obtain detailed expertise regarding the site, and to help oversee the delivery of a far-reaching and rigorous biodiversity net gain management programme. Preferably, they could work with Sussex Wildlife Trust which advised the Berwick Solar Farm, and possibly Buglife, who also provide specialist advice to realising the biodiversity of solar developments.

This proposal should seek to improve the BNG target, either through reducing the density of solar panels on the existing developable area and/or including other areas within the proximity for biodiversity investment, as done at Cleve Hill.

Local Community Benefits – needs a clear, significant, and defined local gain.

The proposal indicates that a Community Benefit Fund may be created but falls short of specifying the financial contribution envisaged, or the process for managing this, and does not set out transparently the financial gains to the developer, or landowner (Chatsworth Estate/Duke of Devonshire).

Suncoast state that the 20MW capacity can supply c6.400 homes. They use a metric of 2,900 kWh per home (slightly higher than the Ofgem average of 2,700 kWh consumption of electricity). The Energy Stats portal, which monitors the wholesale market price of energy, indicates the average price is currently around 10p per kWh – which if achieved would result in a minimum annual income to Suncoast of £1,856,000 annually, though market prices fluctuate e.g. prices have been twice or three times this level during the past 12 months, this could result in a turnover of c£4-6 million per annum.

From this the developer would need to repay the capital costs, say £424,000 per annum (£16 million capital investment at 6% interest depreciated over the 40 years expected lifespan) less other costs such as network connection fees, business rates, maintenance and rent to the landowner. If the development achieved an average net margin of say c20% of turnover, this could result in a net profit somewhere between £360,000 -1,080,000 each year (depending on market prices)

This speculation goes to the heart of the difference of this type of commercial development compared to a community energy scheme where the financial profile is more transparent, and the community benefit better defined. It would be beneficial for Suncoast to share its financial forecasts.

Level Up our deprived parts of town in a targeted and direct way

This proposal needs to recognise the financial wealth historically extracted from Eastbourne by the Chatsworth Estate (valued at some £905 million) together with opportunity to “level up” those parts of the town which are most deprived, from the latest LSOA data i.e. these are Hampden Park, Langney, the northeast of town centre, Roselands, and Devonshire Ward.

Given the historical perspective, and depth of the local need I suggest that a minimum fund of £5,000-10,000 per MW annually is provided by Suncoast i.e. £100,000 -200,000 each year. With the fund to be administered by a board of local constituted third sector grassroots organisations directing the funds to tackle deprivation in all its manifestations (energy and food poverty, homelessness, digital exclusion, and other aspects of deprivation) in these areas. This would augment and better target the now much reduced Eastbourne Borough Council Devolved Ward Budget Scheme.

Review of 2023: a personal perspective from our Executive Director

Another year has gone by, so time for a review of what the Eastbourne Eco Action Network (EEAN) has been up to in 2023, following on from the reviews of our activities in 2021 and 2022.

The highlight of our year was undoubtedly our widely acclaimed Sustainable Transport & Active Travel Summit in November, which opened with a keynote speech from Chris Ralls, a member of the EcoTransport Group. This summit brought together all the main players in the local transport sector to investigate ways of deepening collaboration on plans and actions to tackle Eastbourne’s notoriously chronic traffic congestion and pollution, as well as its over-dependence upon cars for travelling across town. Transport accounts for over 25% of the town’s carbon emissions, a proportion which has so far stubbornly refused to decline. The quality of presentations and workshops was very high, and together with the extensive networking evident during the summit, there is perhaps a good chance that the barriers to progress on local transport will finally be overcome, leading to more, better, safer walking and cycling infrastructure as well as more reliable bus services operating on dedicated bus lanes supported by more bus priority measures. The first opportunity to see such progress will come if the new Local Transport Plan 4 prepared by East Sussex County Council gets final approval and adequate funding for its implementation. You can comment on it now that it is open to public consultation until February 2024.

The One Planet Eastbourne online community ecosystem platform for mapping and tracking progress towards a more sustainable town was developed by the EEAN this year using the innovative OnePlanet app, designed to facilitate deeper collaboration between local organisations on climate actions and environmental initiatives. Extra grant funding has now been secured to significantly extend work on this platform and to help other local local groups to use the OnePlanet app.

The EEAN organised an Eastbourne Carbon Neutral 2030 Gathering at the Town Hall in May, bringing together many of the local groups involved in helping to make the town Carbon Neutral by 2030. It was an excellent opportunity for those groups to give updates on their progress and to network with other local groups. Hopefully another such gathering can be organised in 2024.

The EEAN partnered up with Energise Sussex Coast to train up local volunteers to become Energy Champions, equipping them to run local energy projects such as giving basic energy advice to local residents and supporting local energy efficiency or clean energy initiatives of various kinds. The first event organised by the Eastbourne Energy Champions was a Business Community Energy Day in July at East Sussex College’s Green Training Hub in Hampden Park The first cohort of Energy Champions have now completed their training, and more cohorts will be trained up in 2024.

Eastbourne Borough Council decided this year to fund a scheme for offsetting the carbon emissions of Airbourne 2023, by far the town’s biggest festival of the year. The council approached us for advice on which scheme to fund, and we advised that the best scheme would be one developed locally by the Eastbourne United Nations Association. This scheme, which has been running successfully for many years, channels donations from local organisations into supplying free tree saplings to local communities in Uganda, proving these communities with much needed biodiversity improvements as well as nutritious fruit and natural medicines. The amount of carbon sequestered by the scheme is much greater than any similarly-sized tree planting scheme in the UK because of the special nature of the trees planted and the very favourable climate of that part of equatorial Uganda where the tree are planted.

In October, Eastbourne Borough Council submitted plans to the South Downs National Park Authority for its proposed Black Robin Farm redevelopment, part of its government-funded Levelling Up project. If approved, this would trigger a significant investment in the Eastbourne Downland Estate, the biggest since the downland was saved by popular opposition from being sold off by the council in 2017. Comments on the plan can be made via the SDNPA planning portal. Much rides on how well the plans would protect and enhance the downland biodiversity as well as addressing how transport by visitors to the site by bus, walking and cycling can best be supported and encouraged. I and my fellow directors have submitted comments to the SDNPA about the plans.

In December, plans for a big solar farm in Eastbourne, the first ever, was submitted to Eastbourne Borough Council by a commercial developer. If approved, it will be sited in Eastbourne Park and will supposedly generate 20MW of electricity, equivalent to producing enough clean energy to power 6,400 homes per year. If approved, the solar farm would represent the single biggest increase in solar power within the town, adding to the solar power generated by the solar canopy installed this year by Eastbourne DGH over one of its car parks. Solar power is a key part of the clean energy transition and a key element in the national strategy of weaning the UK off its traditional reliance on fossil fuels for power generation. However, much rides on the quality of the solar farm’s proposals on protecting local biodiversity, and how much the local community would benefit from the project. I and my fellow directors gave advice to the developers on how that might best be achieved.

2023 was the hottest year in human history and 2024 looks set to be even hotter when the current El Nino reaches its climax. No wonder 2023 was full of natural disasters worldwide such as severe floods, droughts and storms. Given that we may be entering the early stages of climate breakdown, there is a need for much more rapid progress not only towards a zero carbon Eastbourne, but also towards building a strong climate adaptation plan to prepare for the inevitable and damaging impacts of climate change upon Eastbourne, a low-lying coastal community that is very much in the front line of climate change, facing the rising seas and stronger storm surges of a rapidly warming world. Indeed, a key part of adapting to climate change is managing and improving our local sea defences. Which is why, in November, the Environment Agency released its list of options for maintaining and improving the local sea defences from 2027 to 2037 and started a public consultation on them. The EEAN is represented on the agency’s Coastal Community Forum for Eastbourne and attended all of its meetings so far, giving feedback about what our network perceives as the key issues that need addressing.

Key to developing the effective climate adaptation plan we need is the development of a strong and resilient local food system that supports local food growing initiatives and provides equitable access to healthy, locally grown or locally sourced food. Fortunately, the good folks at the Eastbourne Food Partnership, one of our partners, are doing lots of work on this and have this year won the Bronze Award from Sustainable Food Places for that work. They deserve congratulations on achieving this significant milestone and look forward to deepening our collaboration with them in 2024, especially through working with them on researching ways in which local food growing can adapt to our changing climate.

But there is so much more to do, especially as Eastbourne Borough Council’s latest update to its Climate Emergency Strategy states: “The Tyndall Centre and the University of Manchester have carried out analysis that recommends a minimum of a 12.3% per year reduction to deliver a Paris aligned carbon budget. The borough as a whole is a long way off meeting this year-on-year reduction”. The effectiveness of the council’s climate action plan was comprehensively assessed this year by Climate Emergency UK, which published a detailed scorecard of progress achieved in Eastbourne so far. Yet, as the strategy update also says, “We must not be put off by the challenge but must rally together and work together to improve the environment of our town for our residents, children, businesses and visitors now and in the future in order to mitigate global climate change”.

I wish to thank all the members and supporters of EEAN for all their hard work. The EEAN is entirely run by volunteers on a very small budget but consistently punches way above its weight, making significant contributions towards the ECN2030 campaign. May you all have a very restful and peaceful Christmas holiday period followed by a very Happy New Year.

Andrew Durling, Executive Director, Eastbourne Eco Action Network CIC

Can We Trust Transport Modelling?

Are you intending to comment on East Sussex County Council’s Local Transport Plan 4 ( LTP4). For those who want to review the proposals the future projections for transport look good. Predicted to have fewer car trips whilst buses, pedestrians and cycling numbers are all up. That is good news! …. but as a reminder LTP3 had similar aspirations

Perhaps now is the time to ask why planners are generating such positive scenarios, that you may feel are not achievable. The predictions are derived from complex algorithms. Often the process is described as a ‘black box’. The definition of which is ‘a complex system whose internal workings are hidden or not readily understood’ . That makes anything it produces as hard to verify

Let us examine the accuracy of such models. From a lay person’s perspective the optimistic scenarios, over the last 10 years, never seem to have been delivered.

This table below , with 19% fewer cars trips, is from the LTP4. Some scenarios deliver an even larger drop in car trips. [As background, on a number of the workshops it had been asked, if some explanation could be be provided as to how the ‘black box’ generated these outputs]

In sharp contrast, in LTP4 it does admit that, across the county, the number of residents cycling has reduced by around 33% in 5 years. Plus there was a large decrease in bus provision over 20 years and even with an increase in funding, bus passengers are only 90% of pre-Covid numbers.

The largely ‘positive’ models are endemic throughout the planning process. Over the last 10 years many focus on a 10% ‘modal shift’, away from cars, towards buses and cycling. However these predictions then feed into other local plans and permeate through the whole planning process.

As an example ESCC’s ‘Hailsham, Polegate to Eastbourne corridor ‘, from 10 years ago, predicted a 10% reduction in modal share for cars. This scenario is then used by developers, on that key route, to show the extra traffic, from their developments, will be offset by the modal shift this original report had predicted. The example used here is taken from the Transport Assessment for Hindsland in Willingdon. (see Tables 6.2 and 6.3)

Method of Travel – Currently (left) and with planned improvements (right)

Notice that the developers take current traffic data and then adjust to the new modal share. So that cars, including passengers, are down from 80% to 70% and this would suggest traffic levels will be lower. To compensate, for the lower private transport, there is an increase in bus trips from 4% to 9%. That is a 125% increase, alongside an increase for cycling up 150%. But there has never been a demonstrable increase in either.

This general approach, to overstating modal shift, is also seen in Eastbourne, by developers, on schemes such as the Magistrates Court and TJ Hughes. The positive transport assessments, produced around higher levels of active travel, seem to satisfy both developers and councils. They do not alter the reality.

Now look at Black Robin Farm (SDNP/23/04238/FUL). Aecom ,in their transport review for Eastbourne Borough Council, provided a comprehensive analysis of transport options. Their algorithm produced –

The reality check is that for Eastbourne 5% of trips are by bus and on the Downs nearer 10%. However there is no explanation as to how 50% Public Transport could ever be achieved. Plus in this scenario cycling at 4% would be an increase from an original estimate of 1,000 to 4,000 trips p.a. Cynics might think the data was to convince South Downs National Park that there would not be a high demand for car parking. Based on the 100,000 visitors predicted p.a.

Many of these models have shown to exaggerate the modal shift away from private cars. To provide reassurance, models need to be validated, to see how accurate they were. The Government’s Transport Analysis Guidance (TAG) “provides an overview of good practice in planning the evaluation of transport interventions to ensure robust evidence can be collected about the difference that they are making in practice. It is intended to support evaluation planning and stronger business cases for a range of transport interventions in terms of mode, type of intervention” Model guidance from Govt

In summary we are asked to take on trust the ‘black box’ approach, that transport planners are using, when our lived experience would suggest something different. Perhaps now is the time to reassess the accuracy of the predictions. If you have doubts then make this clear in your comments for LTP4 and question them about their methodology

Paul Humphreys EEAN Transport Group

Council Consultation Shortcomings

Introduction

Consultations are considered valuable for getting community and stakeholder perspectives. There is even an expectation, from the Government, that where applicable consultations may take place. However particularly in transport, some councils can use them to block change. In contrast as an alternative other councils, especially during Covid, tried out schemes. Then the public could experience the proposed changes and decide if they like them.

It is becoming increasingly clear that relying on consultations has limitations. The more council consultations, you are involved in, the more the failings become apparent. These include :-

Question Bias. Written to deliver the ‘desired outcome’. By writing questions in a particular way the options are limited. Such as the one for local cycling, where there was the choice of nothing or designs that were substandard. Not what the ‘users’ wanted. There is often no easy way to specify a different or better solution. If you choose ‘nothing’ the funds are then lost.

Limited Representation: Consultations attract those who have strong opinions and miss out the majority. On top of this, certain marginalised communities with limited resources, may not have equal access. Leading to an incomplete understanding of the community’s needs. As an example the bus consultation along Seaside is through one of the most deprived wards in the town and has low car ownership. Should the local residents be given greater weight than those who are more vocal but live elsewhere ?

Tokenism: A recent consultation on the town centre had 64% disagreeing or strongly disagreeing with the proposal. The County Council still proceeded. This leads to frustration and distrust among participants for future consultations.

Lack of Expertise: Public consultations often involve those who may not understand the complexities of planning issues or the regulations . Unfortunately not everything can be simplified.

Manipulation : Consultations can be susceptible to manipulation or bias. Those with greater resources or more power may dominate the outcome, drowning out the opinions of others. Special interest groups can exert undue influence and this is often true on both sides of a debate

Constraints: Consultations can be both time-consuming and resource-intensive, requiring significant effort to organise and manage. This can lead to delays in the planning process and using up valuable funds that could be used to deliver real change . It can also be used as a tool to allow councils not to proceed, which may have been their original preference. This can often be the case with anything that adversely affect car drivers. There is pressure for councils to develop ‘green’ plans that they do not really want. This happened during Covid when the county was funded by the Government to implement temporary solutions. If councils can show that there are negative comments they can drop the scheme and keep the funds.

Resistance to Change: Public consultations may reinforce the ‘status quo’, as many people are resistant to any change. Often only a narrow cross-section of the local demographic tends to engage in council consultations. Often with a preponderance of older people taking part, whilst the views of young people and students, who are mostly reliant on public transport, are not usually represented well enough. However often controversial schemes are then accepted and most would not want it back the way it was.

Social media – Assuming many residents do not fully understand or even look at the documentation, there is the strong evidence of people being influenced by ‘simple summaries’ on social media. This is an increasing problem. As an example a recent local social media campaign had the suggestion that, in the current bus consultation, all of Seaside would become a bus lane and there would be no parking. This is not even close to reality. However these simple messages can then be the main source of misinformation for people completing the online consultation.

Compromise : There is little scope, for those with different views, to come to some common agreement. Often the consultants will speak to the different sides in isolation. When perhaps, through a wider meeting, a compromise could be achieved.

Summary

Consultations can be used in a number of ways :-

genuinely find residents opinions
ensure the desired outcome from the council’s perspective
allow councils to drop schemes they did not actually want
rubber stamp a decision that had already been taken

Paul Humphreys EEAN Transport Group

Could there be an end to Eastbourne’s congestion?

Eastbourne is one of the most car-dependent towns in the southeast. The reason? The alternatives to driving a car in Eastbourne just don’t meet the needs of most people. Too many cars on the road, and too many cars parked alongside the road, legally and illegally, lead to unsafe road conditions for cyclists and pedestrians. There are less than a handful of safe cycle paths. Traffic congestion leads to unpleasant and dangerous levels of pollution, which deter people from walking or cycling along our streets.

There are too few buses for them to be a convenient alternative to driving. Commuters and school children cannot rely on buses as they are too often delayed by traffic jams during busy times. Laying on more services is not cost-effective unless more people use buses. People won’t use buses unless there are more services and buses run to time … and so the cycle continues.

The lack of alternatives to cars leads to more people driving cars whether they want to, or need to. Congestion leads to more congestion … and so the cycle continues.

Eastbourne needs radical changes to end the cycle of congestion. Giving people safe, reliable alternatives to driving a car will reduce congestion so that those who need to drive a car, can and those that want to walk, cycle, or take a bus, can make those choices.

Eastbourne now has an opportunity to make changes. East Sussex County Council has put forward a bus improvement plan, with funding to match. Eastbourne has waited a long time for this level of investment in our transport infrastructure and if we don’t take it up, we lose the funds.

The East Sussex Bus Service Improvement Plan (BSIP) includes a set of Bus Priority Measures which is open for consultation until 25 September 2023. You have until then to show your support for the proposed changes. So please act now.

About the proposed changes

OK they are not perfect, but these things rarely are at first and the consultation allows us to offer suggestions for improvements. The aims of the BSIP are all heading in the right direction:

Improve the reliability and punctuality of bus services and explore methods to make bus services more accessible.
Encourage an increase in the proportion of people travelling by bus.
Enhance the bus network, reducing journey times and improving reliability and punctuality of bus services.
Increase bus usage across the county by building a bus network that meets everyone’s needs.
Complement and support wider transport investment across the country.

The aim of the bus priority measures is to make bus journeys quicker, more efficient and reliable. Through introducing dedicated spaces for walking and cycling, ESCC also want to improve the safety, convenience and attractiveness of these journeys, and help encourage more people to travel on foot, by bike, and use the bus.What’s not to like?

View the Bus Priority Measures Consultation document here (there are pictures!)
Most important : Participate in the Consultation here.

If you want to attend one of the public consultation in-person events on 16^th September from 09:30-13:30 at The Foundry (inside The Beacon shopping centre), Eastbourne, BN21 3NW. Add this event to your calendar (.ics)

Could there be an end to Eastbourne’s congestion? It’s in your power. Give your broad support to these proposed changes and give our councillors the confidence to make the decisions we need them to make.

Jill Shacklock

What to do about Airbourne 2023 carbon emissions?

Airbourne 2023 is now over. But its carbon emissions remain in the atmosphere, adding to global warming. The emissions from Airbourne 2022 were estimated by Eastbourne Borough Council to be 241.5 tonnes C02e from the airshow event itself, and 6,033 tonnes C02e from the transport impact of event visitors. The council decided to offset those emissions through a carbon capture scheme. Eastbourne already does have carbon capture initiatives, primarily those run by Treebourne, a social enterprise that had its beginnings within the Eastbourne Eco Action Network, and which has already planted many thousands of trees across the borough, primarily on council-owned land.

But the scale of the carbon emissions from a festival as big as Airbourne 2023 – which attracted 750,000 visitors, most of them arriving in Eastbourne by car – was such that they could not be offset within the borough alone. So following conversations between Eastbourne Borough Council, the Eastbourne Eco Action Network CIC, and the United Nations Association Eastbourne, it was agreed that the council would fund the UNA Eastbourne’s carbon offsetting scheme, allocating £7,000 to plant 14,000 tropical hardwood trees in Uganda, capturing 62,240 tonnes of carbon over 10 years. This scheme has been running successfully for many years already, resulting in 175,418 trees planted in Uganda so far.

But the scheme does far more than carbon capture. It was designed in close collaboration with local communities in Uganda to ensure that the scheme has the full consent of those communities and meets their needs. Backed by scientific research and monitored closely by UNA Eastbourne and its Ugandan partners, the trees planted are indigenous to Uganda, grown by Ugandan tree nurseries from seedlings, distributed freely to those communities that want them, and nurtured to full growth by those very same communities who integrate them within their own agroforestry practices on their farms or on land maintained by community institutions such as local schools and churches. The trees not only capture carbon faster and in far greater quantities than trees planted outside of the Equatorial region where Uganda is, but they provide many other benefits, such as enriching the soil and providing a harvest of nutritious fruit and natural medicines for the communities that nurture them.

Importantly, the trees planted under this scheme do not take farmland out of production, nor push out poor farmers onto more marginal land. Local farmers decide if they need the trees, which they value because the types of trees offered under the scheme complement the crops they grow on their farms. The trees protect the crops interplanted between them and enrich the soil, thereby increasing the productivity and income of the farms. Trees and crops work well together within the agroforestry system common on small farms in Uganda, something we should perhaps have a lot more of within the UK.

All of us, whether we live in the UK, Uganda, share the same planetary home, so all of us benefit from carbon capture schemes when they are run well, with careful selection of trees, right location, etc. The scheme that UNA Eastbourne runs in Uganda recognises that reality and also delivers a degree of climate justice too, as Uganda, like most countries in Africa, has contributed far less to global warming than rich countries like the UK have historically done, whilst the carbon footprint of most Ugandans is far less than that of most people in Eastbourne.

We can be proud of the fact that a carbon capture scheme devised in Eastbourne is having a significant effect in drawing down carbon from the atmosphere and setting a good example of an effective, fair, research-backed carbon offsetting scheme. But this does not relieve us of the responsibility to reduce the carbon emissions of Eastbourne, and our own individual carbon footprints, as fast as possible. The emissions of festivals like Airbourne, and indeed of all sectors of the Eastbourne economy, have to be much further reduced year on year until the town becomes genuinely carbon neutral, hopefully by 2030. Will we collectively rise to the challenge?

This blog post written by Andrew Durling, a Board director of the Eastbourne Eco Action Network CIC

New Parking Solutions For Eastbourne

The existing approach to parking is no longer enough

The current uninspiring consultation, on parking in Eastbourne Town centre, shows how nothing radical is being considered. Primarily it does not help to meet the Borough Council’s 2030 carbon target.

https://consultation.eastsussex.gov.uk/economy-transport-environment/eastbourne-informal-2022/

Eastbourne

There are a large number of underused car parks in the town. Drivers needs to be encouraged to use them, to free up road space. The obvious way is by differential charging and making it cheaper to park there than in the street.

There will always need to be some parking especially places for the disabled and less mobile. But cars are becoming ever bigger and wider and this is limiting the road space. Deciding that parking availability is a top priority, makes buses passing cars an issue. It has also stopped any cycle lanes being built in the town centre.

London

Other areas of the country are facing the issue of parking head on. So it is worth looking at other councils to see what could be done. Limits by pollution, size of vehicle and CO2 are all possible. As are the removal of some free and pay parking spaces

Take Newham or Lambeth as examples. The latter is the latest council in London to introduce emissions-based parking fees.

Similar charges are expected elsewhere in England. Though they could be less complex with perhaps 4 or 5 bands. Owners of the most polluting cars can expect to pay more than twice as much as cleaner cars. There are now 26 different charges to park for an hour in Lambeth ( see above). It depends on a car’s tax band as to what you pay. Plus a surcharge is added for diesels. These emissions-based charges were shown to change motorists’ behaviour. A spokesman said: “People make fewer journeys or they choose a cleaner vehicle.”

https://www.lambeth.gov.uk/parking/emission-based-parking-charges/street-parking

So this may encourage families with 2 cars to drive into town in the smaller and greener one. Plus there will need to be more dedicated spaces allocated to EV charging as well as giving priority to ‘Car Clubs’

In summary, if we are really going to make a ‘modal shift’ in favour of active travel, we have to re-balance the use of road space, in favour of lower carbon options.

Paul Humphreys – EEAN Transport Group