Transport for the South East draft Transport Strategy Public Consultation – for Organisations

Introduction

We are pleased to present the draft Transport Strategy for South East England, prepared by Transport for the South East (TfSE), the region's Sub-national Transport Body.

This strategy outlines a vision for the South East to be recognised globally for achieving sustainable prosperity and the highest quality of life.

You can view the full draft Transport Strategy and a summary document online or by requesting a paper copy. To view these documents online go to [LINK]

Please consider these documents before submitting your response.

In addition to the strategy, an Integrated Sustainability Appraisal has been conducted to assess the strategy’s impact on sustainability goals, including biodiversity, health, and access equity. We are also asking for comments on this.

You can view all document online at [LINK]

Feedback received in this consultation will be incorporated as part of the development of the final Transport Strategy which will be published in 2025. 

You can complete this survey online at:

https://tfse.engage-360.co.uk/

You can also return a paper copy to us at the address below by 7 March 2025:

Transport for the South East
County Hall

St. Anne’s Crescent
Lewes

BN7 1UE

This survey should take around 20 minutes to complete.

Our privacy notice is provided at the end of this survey so you can see how we use your data.

Thank you for talking the time to complete this survey.

About your Organisation

Q What is the name of your organisation?

East Sussex County Council

Q What type of organisation do you represent?

Local authority	☒
Business	☐
Charity of third sector	☐
Transport operator	☐
National partner	☐
Town or Parish Council	☐
Airport or Port	☐
Other	☐

If you answered ‘other’ above please tell us the type of organisation you represent

Insert response

Q I confirm that I am authorised to respond to this consultation on behalf of my organisation

Yes	☒
No	☐

Q What is your name?

Jon Wheeler

Q What is your job title?

Team Manager – Infrastructure Planning & Place

Q Please tell us your email address

jon.wheeler@eastsussex.gov.uk

Challenges

Since TfSE published its first Transport Strategy in 2020, the context has evolved significantly. National and local policy changes, intensified decarbonisation efforts, post Brexit trade dynamics, and shifts in travel behaviour due to the pandemic all present new challenges.

Our research has identified several key challenges that need to be tackled if the region is to succeed.

You can find full details of the challenges our region faces on page 6 of the draft Transport Strategy summary document, and from page 25 of the full draft Transport Strategy document.

Q Do you agree that the challenges we have outlined above are the right ones that the Transport Strategy should be seeking to address?

Strongly agree	☐
Agree	☒
Neither agree or disagree	☐
Disagree	☐
Strongly disagree	☐
Don’t know	☐

Q Do you think there are any other challenges we should consider?

· Affordability of travel – given that it is a key aspect of your inclusion and integration mission and that local communities regularly tell us about the affordability of travel, it is strongly suggested that this needs to be reflected within the challenges

Q Are there any other comments you would like to make on the challenges?

· Decarbonisation, Brexit trade dynamics and shifts in travel behaviour can be considered as evolution of challenges from the first strategy both of which had uncertainties as to scale and direction of impact in 2020, and as such could not be considered new.

· We would prefer to see UK regional or sub-national transport body comparisons on the housing affordability challenge, rather than with California.

Vision and Goals

Our vision is to create a region that not only leads the way in sustainable, net zero carbon growth but also offers its residents, businesses, and visitors the highest quality of life.

This vision is supported by three goals, addressing the pillars of sustainable development: fostering a competitive economy, improving social outcomes, and safeguarding the region's natural and historic environment.

Together, these goals ensure that growth in the South East is inclusive, resilient, and sustainable.

You can find full details of our vision and goals on page 7 of the draft Transport Strategy summary document, and page 35 of the full draft Transport Strategy document.

Q How strongly do you support the visions and goals in the draft Transport Strategy?

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q Do you have any further comments on the vision or the goals?

· We welcome the vision and goals, all of which have strong alignment with the recently adopted East Sussex Local Transport Plan 4 (LTP4). LTP4’s vision is “an inclusive transport system that connects people and places, is decarbonised, safer, resilient, and supports our natural environment, communities, and businesses to be healthy, thrive and prosper.”

· We agree with the alignment of the three pillars of sustainable development – economy, environment, social - which will support greater alignment between future transport planning and strategic planning (housing and employment growth).

· Economic goal – we are supportive of this goal as it is in alignment with the East Sussex Economic Prosperity Strategy 2024 – 2050. However, it is suggested that you may wish to consider including reference to economic prosperity within the goal.

· Social goal – whilst we are supportive of this goal as it is in alignment with the East Sussex LTP4, it is suggested that some minor amendments are included to highlight not just the opportunities to improve, but to ‘improve and support healthy lifestyles and communities, safety etc…’

· Environment goal

o We are supportive of this goal and suggest the inclusion of ‘conserve’ as well as protect the environment to further strengthen this goal.

o This also includes the concept of Environmental Net Gain and that ‘new transport developments should leave the environment better off than before by enhancing biodiversity, using sustainable design, and integrating green solutions into infrastructure projects’. This concept needs further consideration and explanation. How can it be measured? Does it relate to construction or operational impacts? As the term ‘environment’ is quite broad, how would you calculate the net gain or loss if (for example) a development improved biodiversity but increased carbon emissions?

· Page 67 notes that the ‘avoid’ aspect of ‘avoid-shift-improve’ approach is about delaying ‘avoid’ journeys/modes until it is/they are decarbonised. The use of the word avoid is misleading in this context as it requires further explanation. The East Sussex LTP4 is about providing choice, and we acknowledge that some choices will not necessarily meet the decarbonisation aspirations, at least in the short-term. As this is about providing modal choice here, as set out throughout your strategy, you may wish to use the word ‘delay’ which suggests delaying the journey until its decarbonised or take a mode of transport with a smaller carbon footprint.

· We welcome references to growing our region’s economy and competing with the global market place. These aspirations are supported by East Sussex, Brighton & Hove and West Sussex Local Visitor Economy Partnership (LVEP) which sets out a vision in the LVEP Strategy for Growth to grow the value of the visitor economy from £5 billion to £7.5 billion with benefits felt widely across Sussex and recognising the county as a exemplar in sustainable and regenerative tourism.  Sussex commits to a forward-thinking approach to regenerative tourism, fostering sustainable practices to preserve local cultures and biodiversity. It offers visitors authentic, transformative experiences while supporting local economies. Through proactive measures, Sussex addresses climate change and biodiversity challenges, striving for recognition as a leading sustainable destination.

Strategic Connectivity Mission

Connectivity refers to the speed, frequency, and ease by which people and goods move between places. TfSE’s focus is on strategic and regional connectivity, as local connectivity is led by our local authority partners.

You can find full details of our strategic connectivity mission on page 10 of the draft Transport Strategy summary document, and page 44 of the full draft Transport Strategy document.

Q How strongly do you support the strategic connectivity mission in the draft Transport Strategy?

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q How important are the key outcomes of the strategic connectivity mission to your organisation?

	Very important	Important	Neither important or not important	Not very important	Not important at all	Don’t know
Journey time and reliability on strategic corridors is comparable to those serving London	☐	☒	☐	☐	☐	☐
Key towns, cities and international gateways are as accessible by public transport as they are by car	☐	☒	☐	☐	☐	☐
Rail freight is as competitive as road freight	☐	☐	☒	☐	☐	☐

Q How strongly do you support the priorities which will enable us to improve strategic connectivity?

Short-term and long-term priorities are shown at the top of this page.

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q Please tell us the one priority from the list at the top of the page you see as most important to achieving this mission?

Advancing key connectivity projects to improve regional transport links. Overall connectivity of the county by road and rail, to other parts of the South East geography, key gateways (eg Gatwick), London and beyond is relatively poor compared to our neighbouring authorities and our strategic transport infrastructure, particularly road, is very inconsistent.  This leads to challenges with increased journey times to/from the county and the reliability of these journeys as well as impinging growth opportunities in the county.

Resilience Mission

The resilience of the South East’s transport network is vital to the region’s economic, social, and environmental well-being. 

You can find full details of our resilience mission on page 12 of the draft Transport Strategy summary document, and page 52 of the full draft Transport Strategy document.

Q How strongly do you support the resilience mission in the draft Transport Strategy?

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q How important are the key outcomes of the resilience mission to your organisation?

	Very important	Important	Neither important or not important	Not very important	Not important at all	Don’t know
The transport network delivers comfortable, reliable journeys between key towns, cities and international gateways	☐	☒	☐	☐	☐	☐
The transport network has the agility to manage and absorb disruptions quickly	☒	☐	☐	☐	☐	☐

Q How strongly do you support the priorities which will enable us to improve resilience?

Short-term and long-term priorities are shown at the top of this page.

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q Please tell us the one priority from the list at the top of the page you see as most important to achieving this mission?

Strategically planning for future risks to enhance network adaptability.  Our Local Transport Plan 4 (LTP4) emphasises that we need a transport system that is more capable of recovering from unexpected disruptions including events caused by climate change.  In turn, this will improve journey time reliability for people and businesses; enable transport journeys to be resilient, flexible, and adaptable and recover quickly from emergencies and events, and improve the resilience of highway and other transport infrastructure and assets from extreme weather events (intense rainfall and surface water flooding, high temperatures) but also taking account of future longer term impacts arising from coastal erosion and sea level rises on coastal areas.

Inclusion and Integration Mission

Creating an inclusive and integrated transport network should be a fundamental part of planning and decision-making. However, TfSE’s engagement with socially excluded groups has revealed that many communities across the region still face barriers to access, putting them at risk of exclusion.

You can find full details of our inclusion & integration mission on page 14 of the draft Transport Strategy summary document, and page 60 of the full draft Transport Strategy document.

Q How strongly do you support the inclusion and integration mission in the draft Transport Strategy?

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q How important are the key outcomes of the inclusion and integration mission to your organisation?

	Very important	Important	Neither important or not important	Not very important	Not important at all	Don’t know
Everyone can affordably travel where they need to go and when	☐	☒	☐	☐	☐	☐
Customer satisfaction with the transport network is high across all sections of society	☐	☒	☐	☐	☐	☐

Q How strongly do you support the priorities which will enable us to improve inclusion and integration?

Infrastructure and service priorities are shown at the top of this page.

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q Please tell us the one priority from the list at the top of the page you see as most important to achieving this mission?

Providing socially necessary transport to connect isolated communities with essential services – this is important for ensuring that those communities especially in the rural hinterland of the county away from the coastal strip, but also people across the county without access to or chose not to use a private vehicle, are able to access a range of services by alternatives.  The recent improvements to public transport funded via the Bus Service Improvement Plan, including the introduction of Flexibus and increased bus service frequency/extension of services, has helped to address these social isolation challenges that individual people and wider communities experience.

Decarbonisation Mission

The UK Government, TfSE, and all local authorities in the South East are committed to achieving net zero transport emissions by 2050. 

You can find full details of our decarbonisation mission on page 16 of the draft Transport Strategy summary document, and page 68 of the full draft Transport Strategy document.

Q How strongly do you support the decarbonisation mission in the draft Transport Strategy?

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q How important are the key outcomes of the decarbonisation mission to your organisation?

	Very important	Important	Neither important or not important	Not very important	Not important at all	Don’t know
All surface transport trips are net zero emission by 2050	☐	☒	☐	☐	☐	☐
We have not exceeded our carbon budgets by 2025[DC1]	☐	☒	☐	☐	☐	☐
The South East is seen as a world leader in decarbonising transport	☐	☐	☒	☐	☐	☐

Q How strongly do you support the priorities which will enable us to improve decarbonisation?

Short-term and long-term priorities are shown at the top of this page.

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q Please tell us the one priority from the list at the top of the page you see as most important to achieving this

Promoting integrated land use and transport planning to minimise unnecessary car use and improving public transport and active travel infrastructure to provide attractive sustainable travel options are joint highest priorities.

Our LTP4 highlights that there is a need to better connect existing and future housing to jobs, effectively bringing more of the population ‘closer’ to employment opportunities. This will spread the benefits of future economic growth more evenly, and benefit businesses who will have a wider range of potential employees to select from.  In addition, future population increases could load more journeys onto the network, potentially worsening congestion.  However, if a co-ordinated land use/transport planning approach is pursued which focusses development within established urban areas then this approach can help to reduce these increases in transport demand, alongside other measures and infrastructure which improve sustainable travel choices and encourage walking, wheeling, cycling and public transport in existing and new communities.

.

Sustainable Growth Mission

The sustainable growth mission aims to deliver prosperity without harming the welfare of future generations. It supports the UK Government’s first mission, to “kick start economic growth”.

You can find full details of our strategic growth mission on page 18 of the draft Transport Strategy summary document, and page 76 of the full draft Transport Strategy document.

Q How strongly do you support the sustainable growth mission in the draft Transport Strategy?

Strongly support	☐
Support	☒
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q How important are the key outcomes of the sustainable growth mission to your organisation?

	Very important	Important	Neither important or not important	Not very important	Not important at all	Don’t know
Population growth and economic development is underpinned by sustainable transport and infrastructure	☐	☒	☐	☐	☐	☐
The South East has well connected communities with easy access services and employment	☐	☒	☐	☐	☐	☐

Q How strongly do you support the priorities which will enable us to improve sustainable growth?

Transport Intervention priorities are shown at the top of this page.

Strongly support	☐
Support	☐
Neither support or do not support	☐
Oppose	☐
Strongly oppose	☐
Don’t know	☐

Q Please tell us the one priority from the list at the top of the page you see as most important to achieving this

Concentrating development in areas with strong transport infrastructure and co-ordinating housing and transport planning across authorities are the two joint highest priorities.  As highlighted earlier, a co-ordinated land use/transport planning approach which focusses development within established urban areas or on key strategic transport links, which are likely to have the strongest transport infrastructure in the county, can help to reduce these increases in transport demand, alongside other measures and infrastructure which improve sustainable travel choices and encourage walking, wheeling, cycling and public transport in existing and new communities.  If transport infrastructure improvements are required to facilitate development locally, this should be done on an ‘infrastructure first’ basis rather than following housing and employment space coming forward.

The Government’s further planning reforms and opportunities arising from devolution may facilitate a further evolution of how we plan transport and land use planning at a more strategic level than at present through the Local Plans at local planning authority level.

Q Do you have any further comments on any of the five missions?

Overarching comments

Support and alignment with East Sussex Local Transport Plan (LTP4)

· East Sussex County Council supports the use of a mission approach and the key missions selected, as these accord with the East Sussex LTP4 Objectives and outcomes.

· We welcome that each mission follows a structured route map that clarifies the path forward. This a robust approach that will strengthen the links with delivery alongside this being in alignment with the new government’s approach to policy delivery. 

Suggestions

· We have reservations over the use of the term mass transit and using a bus symbol for mass transit. The use of the bus icon suggests that bus mass rapid transit is proposed whereas at the strategy consultation launch webinar, it was stated  that mass transit is mode agnostic and would be defined as studies and scheme development progresses. Therefore, we would suggest that the icons used in your mapping are reviewed and choose an alternative non-transport mode icon for mass transit to avoid any confusion and setting of expectations.

· TfSE may wish to consider highlighting the opportunities of their specific role in supporting local authorities and strategic transport partners in delivering the missions.

Strategic connectivity mission

Support and alignment with LTP4

· We welcome the strategic connectivity mission.  East Sussex experiences many of these challenges and the mission strongly aligns to our theme of the LTP4 theme of ‘Keeping East Sussex connected’ (LTP4 section 8).

· East Sussex County Council specifically supports the short-term priorities of ‘reinstating international rail services from Ebbsfleet and/or Ashford to relieve capacity at St Pancras’ and ‘Planning for long term improvements by safeguarding critical areas and aligning planning policies’.

· We welcome the outcome of improving rail journey times. Compared to other parts of the country, some of our communities experience longer journey times in accessing other areas of East Sussex, the south east, London and nationally over comparable or longer distances to other parts of the country (for example, it is a two hour rail journey time from Bexhill to London by whichever route – a distance 52 miles as the crow flies – whilst Birmingham to London with a comparable rail journey time is 101 miles).

Suggestions

· This mission could be strengthened by referring to some of emerging themes from the Integrated National Transport Strategy, i.e. recognising that different passengers have different needs and supporting areas to make all forms of transport work together better’. We suggest that the outcomes of improving rail journey times are classified as short- or medium-term priorities for our county rather than long-term.

· Accessible international gateways should have different modal focuses. Airports should be most accessible by public transport (including by bus and coach services) and port gateways should be more focused towards highway traffic but have good public transport connections for those travelling, where permitted, without a motor vehicle (e.g. it is recognised the Newhaven port traffic is likely to be road based with some passenger traffic to/from coming via rail at Newhaven Town and Newhaven Harbour stations)

· The use of rail freight is welcomed, though there is a significant challenge of available time critical paths and suitably gauged cleared routes in the UK, and especially in parts of the south east including East Sussex. This availability results in road being the preferred route for time-critical movement of goods, due to the flexibility in the event of an incident on the highway network, something which is harder to achieve on the rail network. It would be good to see commitment to identifying which rail gauges need increase to accommodate rail freight.

· Whilst we understand that this mission is focussed on strategic connectivity, it is suggested that reference to the opportunities for longer distance cycle networks are referenced (to ensure alignment with the TfSE Regional Active Travel Strategic Action Plan) as part of integrated strategic connectivity and to be mode inclusive.

· This mission refers to the need for ‘expanding rail capacity to support growth at Gatwick and Southampton airports It is recommended that in relation to Gatwick Airport that this mission is amended to include the reference of improving the modal share of travel by sustainable travel to and from Gatwick. This amendment to the mission wording should include rail capacity and is irrespective of the Secretary of State’s pending decision on the Gatwick Northern Runway proposal.

Resilience mission

Support and alignment with LTP4

· We welcome the strategic connectivity mission, we experience many of these challenges locally within the county of East Sussex and it strongly aligns to the LTP4 theme of ‘Keeping East Sussex connected’ and LTP4’s objective 6 (‘strengthen the resilience of our transport networks’).

· We welcome the reference to developing secondary corridors (e.g. Uckfield-Lewes), which is identified in the East Sussex LTP4’s Investment Plan as well as both Lewes and Wealden District Council’s Local Plans and Infrastructure Development Plans.

· We welcome the acknowledgement of the impacts of coastal erosion on the county’s transport networks, especially when key corridors (A259 and rail routes) pass close and/or near to the sea and are more at risk on impacts from rising sea levels.

Suggestions

· Though we do note the map on page 50 of the Draft Transport Strategy has the label (“secondary corridors including Lewes-Uckfield-Tonbridge”). This label does not align with LTP4 (which has ‘Lewes-Uckfield Line reopening’ and ‘Spa Valley Line modern operations reopening’. Therefore, we suggest that the resilience priorities map label is amended to reflect and align LTP4 to avoid confusion between partners and the public.

· Long-term priority 2 (page 49) – the last sentence is incomplete (“Developing secondary and alternative corridors as diversionary routes to ensure users always have options, such as Uckfield – Lewes, Canterbury Chord, and improvements to secondary highway routes along the London – Brighton corridor such as the.”).

· Key initiative 4, ‘Making the case for, and securing, more and consistent funding for maintenance and enhancements, such as infrastructure adaptation, coastal erosion, and delivering nature-based solutions’ - this needs to add an aim to better understand and mitigate risks in road and rail networks, for example highway drainage, within the context of climate change. There are many unknowns at the lower levels of transport networks (e.g. smaller roads) which could produce unwelcome challenges should the impacts arising from climate change accelerate.

Inclusion and integration mission

Support and alignment with LTP4

· We welcome the inclusion and integration mission, as a key principle of LTP4 is ‘inclusivity’ and is a key word prominently positioned at the start of LTP4’s vision.

Suggestions

Transport network accessibility and affordability

· We note that your strategy definition of inclusivity seems to be focused on/towards affordability, rather than the ability of people to access and travel around the transport network(s). We know both are important, but that having access to a preferred transport network should be the priority.

· We request the distinction and separation of the two challenges of a) accessing and moving around using transport networks and b) affordability. Though the two are closely related.

· Affordability is largely a challenge outside of the control of local transport authorities, and we rely on lobbying and partnership working with operators and other partners. We acknowledge that this is an area where TfSE are likely to have some increased lobbying power, given the larger geography coverage across local transport authorities and region-wide aspirations for affordability. Therefore we suggest that this is reflected in the strategy.

· The East Sussex LTP4 aspires to deliver a number of mobility hubs to provide interchange opportunities across the county, including at railway stations and in key towns without rail links, supporting inclusivity through supporting people move around our transport networks, similar to other authorities. Therefore we suggest that this is referenced within this mission.

· Given the importance of affordability within this mission, some indication on the change of travel costs (e.g. the cost of rail fares, bus fares or fuel) or changes in travel behaviour (e.g. has there been a reduction in the number of season tickets, are more people travelling after the peak period(s) when fares are cheaper?) would be beneficial to provide context.

· We welcome the inclusion of integrated fares and ticket systems across modes and note that there are other good examples of this in the region already (e.g. Plusbus (for train and bus)). We also recommend referencing ticketing for rail travel to/from the Isle of Wight using ferry/hovercraft services, with through tickets available from any railway station in Great Britain, which is of great benefit to day and night visitors to the island.

· It would also be good to see a commitment for a single price for the same walk-on product (e.g. bus day tickets) regardless of purchase location or method, which can occur with some transport operators within the TfSE region, and thereby be inclusive to all users regardless of technology availability. This is of increasing importance as the £2 fare cap becomes £3 (as of start of 2025), and day tickets may become more appropriate for some users as they could be cheaper or provided more travel opportunities for the same price.

· With regard to the key priorities map we welcome and largely agree with the priorities that affect our county. In East Sussex LTP4 there is no reference to mass (bus or rail) transit, and we suggest that the TfSE strategy reflects this and doesn’t include reference in relation to East Sussex.

Technology

· Under infrastructure priorities we would recommend that suggestion and acknowledgement of technology is made here, whether that be in mobile network coverage (e.g. Wadhurst station has no mobile network coverage), or the use of technology to provide real-time information in urban centres close to key transport stops and stations, providing travellers with information about their upcoming journey.

· We also note that whilst technology is a useful source of travel information, not all transport users have access to social media or apps, and maybe reliant on Wi-Fi signals when their data allowance is low or used. Therefore, non-technology inclusion methods need to be considered to achieve inclusivity.

Transport related social exclusion

· We also welcome the inclusion of socially necessary public transport services, though these are subject to available funding and are areas that local authorities must regularly review when faced with budgetary challenges.

· We note that areas of East Sussex are at higher risk of transport related social exclusion as noted within the strategy and on the key priorities map on page 58 of the strategy.

Equalities

· We also welcome references to lighting within infrastructure priority 1. Lighting is important to groups of people who identify as having some protected characteristics (i.e. sex (particularly women), sexual orientation (e.g. LGBTQIA+), gender reassignment (trans and non-binary people) and religion/belief), and better lighting and CCTV, provides them with confidence to use transport networks, particularly active travel routes.

· Nowhere within the strategy document is the term “socially excluded groups” defined. We assume these are user groups identified beyond those we have legal duties towards as per the Equalities Act 2010. If the term includes groups we have legal duties towards (i.e. those with protected characteristics under the Equalities Act) please consider making this clearer with the terminology you use, as people who identify as having protected characteristics may not consider themselves to be ‘socially excluded’.

· There is no particular reference to legal duties in relation to the inclusion and integration mission. We feel they should be referenced.

· We support the commitment to further developing the evidence base in relation to social exclusion, including impacts on specific groups.

Decarbonisation mission

Mission Statement

Under ‘we will know when we have succeeded’, the mission statement says, ‘We have not exceeded our carbon budgets for surface transport by 2050.’ Details of what (and how much) the carbon budgets are should be included here, as readers may be unfamiliar with the terminology.

Support and alignment with LTP4

· We support the inclusion of the decarbonisation mission. East Sussex County Council has declared a climate emergency. ‘Decarbonising transport and travel’ is the third objective in East Sussex’s LTP4.

· We support the priorities around power supply and resilience. It’s great to see the strategy encompass this.

Suggestions

Active travel

· In the East Sussex LTP4, outcome 3.1 concerns increasing the proportion of the number of people travelling by active, public and shared transport. Given the mission’s aspirations in relation to active travel infrastructure and wider strategy aspirations for public transport use, it is suggested that including the proportion of trips using active, public or shared transport modes as a sign you have succeeded in achieving this mission.

Aviation

· We note the references to Gatwick Airport and passenger growth aspirations. It is suggested that this is amended to include the reference of improving the modal share of travel by sustainable travel to and from Gatwick. This amendment to the mission wording should include rail capacity and is irrespective of the Secretary of State’s pending decision on the Gatwick Northern Runway proposal.

Freight

· We welcome references to the role that freight transport has in achieving decarbonisation. It is suggested that references are made to first/last mile freight in delivering and collecting from properties and businesses and the role that freight consolidation centres and electrified (or other power sourced) fleets or cargo delivery bikes can play for first/last mile deliveries. This area could be linked into short term priority 7.

Public transport

· Short-term priority 4 (improving bus services) should be linked to Bus Service Improvement Plans and the aspirations and achievements that local authorities and bus operators have had over the past few years. In East Sussex the BSIP is supporting improved frequences or whole bus routes and Flexibus across the county, providing connectivity to employment, education, training and leisure activities.

· We welcome the references to the electrification of the Ore-Ashford and Uckfield – Oxted (Surrey) railway lines, which are currently operated by diesel trains, are isolated diesel train operations in the far south east of an otherwise largely electrified railway network.

Carbon

· We welcome the reference to reducing the embodied carbon of new infrastructure and would suggest that the area of materials is looked at in the short-term alongside organisations that maintain and install infrastructure to introduce sustainable materials at the earliest opportunity into infrastructure projects.

EV Charging

· The short-term priorities for decarbonisation should include a priority on affordable electric vehicle (EV) charging solutions for people without home charging. Whilst this section covers availability of on-street charging is covered as an issue, affordability isn’t mentioned. Currently, high prices for on-street chargers can make EVs more costly to ‘fuel’ than conventional vehicles. This should also be included in the delivery section.

· The context of the decarbonisation mission states, ‘Furthermore, the UK currently trails many European countries in the provision of electric vehicle charges – including Scandinavian countries, the Low Countries, and France.’ This needs to define how we’re trailing, as numbers of chargers is only part of the picture. The metrics produced by Cenex might be useful here (https://www.vauxhall.co.uk/content/dam/vauxhall/Home/electric-streets/cenex-vauxhall-report-charging-UK.pdf). Also, note there’s a typo in ‘chargers’.

Sustainable growth mission

Support and alignment with LTP4

· We welcome this mission and it links to Objective 5 of LTP4 (‘Support sustainable economic growth).

· Reference to the enhancement of places is welcomed and aligns with the East Sussex LTP4 approach of ‘people and places’.

Suggestions

Devolution

· We strongly suggest that mission must reflect the changes set out in the Government’s White Paper on devolution in England on 16 December 2024 and consider the options being pursued by local authorities within TfSE’s geography that will be emerging over the coming months. This includes the proposed changes to strategic spatial planning in terms of improving the scoping, geography and timescales. This is alongside the support for integrated planning as part of strategic plans, which will need to be connected with plans for nature, transport and energy.

Active travel

· We would like to see greater reference to active travel in the sustainable growth outcomes, particularly where a development is close to local centres and other key destinations where active travel should become the mode of choice for trips.

· We would like to see increased reference to demand management, walkable neighbourhoods here, supporting references within the climate mission.

Investment priorities

· We feel that the investment priorities should be re-ordered so that connectivity is the most important, followed by cost/affordability and then the quality and frequency of services, to reflect potential priorities of the workforce when applying for and deciding on employment opportunities. The key priorities map suggests that there are no key priorities for our county, other than mass transit along the coast between our border with Brighton through to Hastings (via Eastbourne).

Spatial Planning

· In relation to local plans and housing, and employment, development, it would be useful to see references to delivery of critical transport infrastructure earlier in the housing and employment developing process, so that transport infrastructure and services are ready to operate once the site is developed, particularly where interventions can be delivered through developer contributions.

Global Policy Interventions

You can find full details of our global policy intervention on page 84 of the full draft Transport Strategy document.

Q How strongly do you agree that the global policy interventions are needed?

Strongly agree	☐
Agree	☒
Neither agree or disagree	☐
Disagree	☐
Strongly disagree	☐
Don’t know	☐

Q Are there any other global policy interventions you think should feature in the Transport Strategy?

· Freight policies - East Sussex LTP4 will be supported by a new Freight Strategy which is currently being developed.

· It would also be beneficial to have icons of the modes affected by each policy area in your summary image. This would help ensure that all modes are included, easily identifiable and not overlooked.

Delivery

The following tables outline the key actions TfSE must take out until 2030 to achieve our missions, and tackle known, cross-cutting delivery challenges. 

You can find full details of TfSE's roles as part of our delivery plan from page 91 of the full draft Transport Strategy document.

Q How strongly do you agree with the actions that TfSE has set in the Delivery Plan?

Strongly agree	☐
Agree	☒
Neither agree or disagree	☐
Disagree	☐
Strongly disagree	☐
Don’t know	☐

Q If you disagree or strongly disagree please tell us more about this?

N/A

Indicators

There are a number of indicators we propose to use to measure the progress of the strategy.

You can view the full table of indicators on page 95 of the full draft Transport Strategy document.

Q Are the indicators that we have identified the right ones to measure?

Yes	☒
No	☐
Don’t know	☐

Q If you have answered ‘no’ above, please tell us more

N/A

Integrated Sustainability Appraisal

Q To what extent do you agree or disagree that the Integrated Sustainability Appraisal represents a through assessment of the draft Transport Strategy?

Strongly agree	☐
Agree	☐
Neither agree or disagree	☐
Disagree	☐
Strongly disagree	☐
Don’t know	☐

Q Do you have any specific comments regarding the Integrated Sustainability Appraisal?

Equalities terminology

There are a number of instances within the report, and across your documents, where the terminology used in relation to equalities needs to amended to preferred terminology:

· “…those with a disability…” should read ‘disabled people’

· “…the elderly…” should read ‘older people’

Health Impact Assessment

· We would welcome the development a standalone Health Impact Assessment of the strategy.

Overall Views

Q To what extent do you agree that the draft Transport Strategy sets out an ambitious yet achievable strategy to improve transport across the South East?

Strongly agree	☐
Agree	☒
Neither agree or disagree	☐
Disagree	☐
Strongly disagree	☐
Don’t know	☐

Q Are there any additional comments you would like to make on the draft Transport Strategy?

Support and alignment with LTP4

· We welcome the strategy and note that there is alignment with the recently adopted East Sussex LTP4.

· We welcome the synergies between your cross-cutting principles and the principles of the East Sussex LTP4. LTP4 is about creating ‘places for people’ and is aligned with the concept of triple access planning of considering not only physical transport but also digital and social factors of accessibility, thereby making the transport network more inclusive and connected.

· LTP4 also sets out modal hierarchies that prioritises active and sustainable travel modes, and the hierarchies can differ depending on the movement and place of that street.

Delivery

· The delivery section notes the importance of partners, such as East Sussex County Council as a local highway authority, in achieving the vision and goals. We note that other than in the delivery section there is minimal reference to the importance of partners in delivering on your vision and goals, particularly where partners will need to lead and deliver on the positive change you aspire to.

· Therefore, we would encourage that you review the wording in the strategy and make greater reference to the role of partnership working and review the use of words such as ‘we’ (which is used regularly in the missions).

· It should be recognised that successful delivery is reliant on the availability of funding. Availability of funding is a significant challenge and concern for local transport authorities, particularly when we have ambitious Plans including those for transport through our LTP.

Strategic connectivity

· We suggest that reference to longer distance cycle networks are referenced (to ensure alignment with the TfSE Regional Active Travel Strategy Action Plan) as part of integrated strategic connectivity and to be mode inclusive.

· We would also like to see reference to local transport and highway authorities in setting priorities for the road and rail network alongside National Highways and Network Rail (and Great British Rail in the near future).

Inclusion and integration

· We would welcome reference to TfSE supporting local transport authorities creating accessible transport networks.

Decarbonisation

· East Sussex County Council welcomes the carbon assessment playbook and look forward to working with TfSE in establishing a process by which it can support policy and scheme assessment.

Sustainable growth

· We welcome reference to Lucy Saunder’s Healthy Streets and as an authority we are introducing training on this approach across our teams in 2025.

· It would be good to see reference to supporting local planning and highway authorities in addressing development impacts that have not been mitigated for when a development opens (whether this be due to funding availability or changes on the development occupation timescales).

Environment

· We would welcome a stronger emphasis on the natural environment, as it is, as noted, a key pillar of sustainable development. Whilst reference is made to biodiversity net gain, there is limited reference to the protection and conservation of our environment. East Sussex LTP4 has an objective (4) about conserving and enhancing our local environment. Consideration could be given to more prominent inclusion within a mission or given a mission of its own.

Indicators

· We welcome the inclusion of indicators. We note that there are no targets and are supportive of this approach as the East Sussex LTP4 does not have targets either, due to the uncertainty of funding for interventions.

· It would be beneficial to add suggests data sources for monitoring of these indicators to provide a degree of confidence that these indicators can be monitored over time and won’t have to be unreported due to a lack of data.

Strategic connectivity

· It would be helpful to understand the definition of reliability in the context of the strategic connectivity indicator as this can mean different things to different people/organisations.

Integration and Inclusion

· It is suggested that smart ticketing should be by bus operator, not service.  In addition, the number of passengers using SMART ticketing is not inclusive as it ignores cash payments.[DC2]

· It would be helpful to outline how NOx and SOx levels relate to inclusivity or integration

Sustainable growth

· Consideration could be given to the inclusion of an indicator of accessibility (e.g. X% of the population within a journey time of Y minutes of employment etc.

Decarbonisation

· For Electric Vehicle chargers, there should be indicators beyond simple number of chargers. The indicators produced by Cenex may be of interest ((https://www.vauxhall.co.uk/content/dam/vauxhall/Home/electric-streets/cenex-vauxhall-report-charging-UK.pdf))

Health

· We would welcome stronger emphasis on health benefits, particularly around active travel. As improved health can have benefits elsewhere in the health and care system.

Equalities terminology (Strategy)

· There are a number of instances within the report where the terminology used in relation to equalities needs to changed to preferred terminology:

o “…those with disabilities…” (e.g. page 12) should read ‘disabled people’

o “…the elderly…” (e.g. Pages 12, 55, 57) should read ‘older people’

Assessments

Equalities terminology (EDI and Socially Excluded Groups document)

· The term BAME is not preferred, please use ‘ethnic minorities’ and be as specific as possible as to which sub-group you refer.

· There is a section on ‘sex, sexuality and gender identity’. Firstly this is the wrong language not aligned to the Equality Act, it should be ‘sex’, ‘sexual orientation’ and ‘gender reassignment’. Secondly, the section does not contain any information on sexual orientation or gender reassignment. It would be more helpful to have a separate section on sexual orientation and gender reassignment, even if data is limited to the census and some wider observations about perceptions of safety: there is research out there. East Sussex LTP4 consider this within the Equalities Impact Assessment (Equalities Impact Assessment for LTP4 | East Sussex County Council).

· There is an outstanding question in the document on how all this data and engagement will be used during the strategy implementation. There is a wealth of information here that would need to inform individual equality impact assessments on specific projects and programmes. As a local transport/highways authority we would be willing to work with you on any Equality Assessments for schemes for programmes that are within or affect our geography.

· The proposal in the document to share both the approach and the document is supported.

Privacy Notice – Transport for the South East Transport Strategy Refresh

Overview

This Privacy Notice covers the responses to the public consultation of our draft Transport Strategy we are delivering as part of our Transport Strategy Refresh.

Transport for the South East and our host authority East Sussex County Council takes data protection seriously. Please be assured that your information will be used appropriately in line with data protection legislation, will be stored securely and will not be processed unless the requirements for fair and lawful processing can be met.

What information is being used?

In order to ensure we accurately reflect the demographic and geographic range of our region, and to keep interested parties updated with this project we will collect the following information:

Personal Data:

Name

Email address

How will your information be used?

Your name and email address will be used so we can monitor and identify duplicate responses, and where agreed so we can contact you at future stages of this project, either to seek your further views or share the outcomes of your involvement as the strategy develops.

All data will be assimilated and pseudonymised for reporting purposes.

We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing.  Your information is never sold for direct marketing purposes.

Our staff are trained to handle your information correctly and protect your confidentiality and privacy.

Your information is not processed outside of the European Economic Area.

What is your legal basis for processing this information?

Our legal basis for processing your data is consent.

How long will your information be kept for?

Your information will be kept for the duration of this project. You will have the option to remain on our stakeholder database beyond this and if you consent to this we will retain your name and email address until you withdraw consent.

How will your information be stored?

Your information will be stored on our secure systems and accessed only by authorised Transport for the South East officers.

Sharing your information

Your data will shared with our contracted consultants for analysis purposes.

Your rights

Under data protection legislation, you have the right:

· to be informed why, where and how we use your information

· to ask for access to your information

· to ask for your information to be corrected if it is inaccurate or incomplete

· to ask for your information to be deleted or removed where there is no need for us to continue processing it

· to ask us to restrict the use of your information

· to ask us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information

· to object to how your information is used

· to challenge any decisions made without human intervention (automated decision making)

Please visit www.eastsussex.gov.uk/your-council/about/keydocuments/foi/data-protection for further details. 

How to find out more or complain

Should you have any further queries on the uses of your information, please speak directly to our service: tfse@eastsussex.gov.uk

To complain about the use of your information, please contact our Customer Services Team at www.eastsussex.gov.uk/contactus/complaints or our Data protection Protection Officer atwww.eastsussex.gov.uk/your-council/about/key-documents/foi/data-protection/data-protection-officer.

You can also contact the ICO for further information or to make a complaint:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Phone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number or you can report a concern on the ICO website at https://ico.org.uk/make-a-complaint/

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[DC1]Says 2050 in online survey

[DC2]Not sure how much we can comment on these as they seem to have come from other documents?