QUESTION 83: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

I have no problem with the development boundary .

Do not agree - We believe that the three sites as specified in the response to question 81 above should be the proposed development boundary and that figure 109 should be amended accordingly to reflect these sites
Preferred site PS24 - Reasons for objection
1. Access to the A268 via Pippins is extremely problematic in terms of driver sight line when exiting the proposed site due to the proximity of the hill to the west between Tanhouse Lane and The Cock Inn as this stretch of the A268 is in a 40mph limit (which is often being exceeded by motorists) and approaching vehicles cannot be seen until they are passing The Cock Inn. To the east side there is a blind bend from The Old Post Office to approximately Crookwell and although this is a 30mph limit motorist quite often exceed it - as can be confirmed by the local Speedwatch group
2. Entry to the site is by the Highways Authority own admission only achievable in principle and requires presumably the demolition of a perfectly habitable property 'Pippins' to achieve access to the site and even then a priority system will be required at the rear end
3. It is unclear from the proposal as to whether or not there is provision for pedestrian access on this entry / exit road as providing these will reduce the width even further and not providing them will be to put people's lives at risk
4. The creation of this access will undoubtedly have a severe impact on the occupiers of the properties that will be either side of this road who will have to endure the comings and goings day and night of vehicles and the like to the 45 dwellings
5. As this proposal relies very much on the owners of Pippins being prepared to sell their property to any potential developer, which presumably they have said they will, what provision has been made should they change their mind or cannot agree a sale price with the developer - would this result in a compulsory purchase order?
6. The two options to connect the footpath to the south and west are not specified other that they require third party land so it is not possible to judge what the implications of this may be
7. Though to a lesser extent properties abounding the proposed site will also be greatly impacted by this proposed development
8. The 2007 Open Spaces, Sport and Recreation Study is now dated - at the time play need in the village categorised Peasmarsh as only having a medium term need. There has been ongoing work to improve current play facilities with an ambitious programme, designed with substantial consultation with local people, to substantially upgrade the present provision, which is within the recommended distance for even young children. The Parish Council believes that it would be detrimental to the character and cohesion of the village to develop a separate play area with no guarantee of ongoing maintenance
9. The inclusion of the orchard with the TPO, although commendable, does raise concerns as to who and how it will be manage to ensure that as the trees deteriorate and die that they will not become a hazard to anyone using this area
10. The pond on the proposed pedestrian through-route also raises safety concerns and issues particularly in regard to children who may use the route or play in the vicinity of this pond
11. The site is very badly drained. There is major concern from the lower lying houses to the eastern side of the site that they already face flooding from run off from the sites ponds and streams and this would be further exacerbated by any development here. The idea of "creating a multi-functional SuDS" alongside the pedestrian link in the form of a "wetland habitat green corridor" suggests that such flooding has been considered with scant regard to the impact on neighbouring properties and that such damage is considered to be acceptable within this proposal (See attached photographs - sent by email with a second copy of Peasmarsh Parish Council's response)
12. That the site is well hidden is a surprising suggestion as once built upon it would be as visible as any of the alternate sites dismissed as unsuitable because of AONB
13. A number of the assertions stated in the 'key opportunities' for this site are little more than conjecture and stated from an urban attitude towards 'open space' rather than a rural one. For example the school already has already in place access to a wide range of environmental opportunities, including a forest school, and a community orchard is not seen as a priority for the parish but rather as a major risk and potential unwarranted additional financial burden to the local community


Peasmarsh Parish Council preferred sites and reasons for choosing them
PS5
Appendix 3 Assessed Sites - Options - The following statement is made as the justification for rejection of this site
"A sloping pasture bounded by a stream and historic field boundary. Although adjacent to the supermarket and bus service, it is further from other village services and is accessed via a narrow, hedgerow-lined country lane. It is exposed above across low lying and attractive High Weald Area of Outstanding Natural Beauty (AONB) countryside to the west, which is typified by medieval field patterns. The topography is such that the site feels remote from the main built-up area of the village. Development would have a negative impact on rural AONB character".
The supermarket and petrol station are the main village services and other than the primary school, the recreation ground, Flackley Ash Hotel and The Horse and Cart public house there are no other services within Peasmarsh so to state it will be further away from services makes little sense as the distance between this site and PS24 is minimal in terms of the other services and PS24 is actually further from the supermarket and Flackley Ash Hotel.
The access could be easily obtained from the existing roundabout adjacent to Jempson's giving much safer access to the A268 from the already established access road to Jempson's Supermarket and is also much closer to amenities i.e. Supermarket, Post Office, Pharmacy etc.
As this important amenity will be within walking distance people will have no need to use their cars when shopping which will have a positive impact not only on the environment but also people's health
There may be an impact on ANOB but given that the Tanhouse Yard business units are located at the North West edge of the site and that there are also several dwellings around the periphery any impact to ANOB would appear to be minimal.
The statement "the site feels remote" is a subjective opinion rather than a statement of fact and could just as easily be applied to the location of PS24
PS6
Although the impact of this site on ANOB maybe marginally greater than PS5 this is more than offset by the supermarket and petrol station to the north of it as both are clearly visible from the A268 from Flackley Ash Hotel (to the west) up to The Cock Inn (to the east) and thus totally obscure the site. The site also links onto PS5 with the same benefits of access etc.
PS7S
The impact of this site on ANOB is somewhat less than PS5 and PS6 and also links onto PS6 with the same benefits of access as PS5 and could be developed at a later stage as opposed to one large development and with less impact on existing properties.
It is interesting that PS7N Land at Oaklands, Main Street is rejected for highway safety issues, run off to the pond and access to frontage via third party lands which are all issues also associated with PS24 and one wonders why PS24 is preferred when this site is not.

General observations on constraints within Peasmarsh infrastructure
With the re-development of The Maltings complex adding ten extra dwellings and the proposal to add another 45 dwellings this will increase the population of the village by around 120 (2.3 people per household 2011 census) an approximate 10% increase. It is hard to see how the village will be able to absorb this increase without the issues detailed below being addressed - which sadly this document fails to acknowledge or address
a. Drainage - Concerns that a number of issues regarding the drainage and in particular the foul water have been reported over a number of years and the Parish Council have regularly been told this is due to the Iden treatment works running near to its maximum capacity
b. Doctors surgery - Residents at present have to go to either The Rye Medical Centre or The Northiam Surgery both of which will be under increased pressure by developments within the surrounding villages and may have to start limiting their patients to those within their catchment area
c. Dentist - A lack of local access to NHS provision
d. Bus service - Reduced to a two hourly service in April 2016, day time only and more limited on Saturdays, with the prospect that this will be reduce even further due to budgetary constraints at ESCC
e. The village primary school, already extended to meet local need, is nearing capacity and will almost certainly struggle to accommodate additional children with little space to extend further
f. Utilities - Gas pressure and broadband are already experiencing difficulties and are regularly failing the community whilst upgrading is not a priority to the companies involved
g. Employment opportunities are very limited and what few there are tend to be mostly in the service and tourist sector, which are generally minimum wage or at best low paid, making even so called affordable housing no more than a dream

In conclusion
We acknowledge and agree that there is a need for more affordable housing and would stress that this is not a case of 'NIMBY' ism but simply that the proposed site, PS24, is ill conceived and fraught with potential problems and we would urge you to reconsider the proposed site in the light of the comments you will receive and give careful consideration to the alternative sites we have suggested
However, there is a general feeling that this is 'A done deal' and that irrespective of what valid objections, concerns and issues that are raised about the suitability of this preferred site that these will be totally ignored and that this is merely a rubber stamp exercise to give RDC the excuse to say that a consultation had taken place. This view is reinforced by the knowledge that a TPO was placed on the orchard at PS24 prior to the launch of the consultation and that Peasmarsh Parish Council is in possession of an email from Richard Wilson at RDC, dated 2014, in which he states "that the only feasible sites for development in Peasmarsh are near to Jempson's Supermarket"
Below is a summary of a note from a resident regarding a previous rejected development of the PS24 site and is worthy of your consideration given the consequences that ensued for the developer involved
"A development of this type on this land was rejected in 1972 causing the development company Galleon Estates to go bankrupt and into liquidation and things have deteriorated over the thirty one years I have lived here in so much as there is now only one shop that doesn't open on Sundays, public transport only exists with financial support from the Parish Council and employment in the village in the form of a garage and repair workshop together with the wood yard have already gone for the benefit of housing development.
On a more personal note my houses was built by Galleon Estates and I have in the Conveyance for the property dated 25th August 1972 in the first schedule the full and free right of way along what I believe is Green Lane to enable access to the rear of my land and would be interested to know how this will be maintained should this proposed development go ahead. I believe that all four houses that were built by Galleon Estates have this same right"

Do Not Agree
I believe that the three sites as specified in the answer to the Question 81 should be the proposed development boundary in figure 109 and it should be amended to reflect this.
Reasons for objections to site PS24.
1. As stated previously access to this site is extremely dangerous from the main road and directly to myself and my family who are immediately tot he east of the property.
2. Drainage
a) Surface Water. The proposal recognises the possible need for SuDS. The whole area is very poorly drained. The direct impact on adjacent properties would be a disaster.
b) Sewage. The drainage system that runs underneath the main street has blocked on many an occasion, therefore the extra load could not be sustained by the present system.

3. Impact on Amenity
This proposal impacts adversely on a significant number of dwellings as follows:
a) The proposal is outside the planning boundaries pertaining when people purchased houses adjoining. The reasonable expectation of "no disturbance" is thus denied and loss of value in our houses.
b) Public Transport, of which the only forms is the bus service every two house and even more greatly reduced at weekends.
c) Doctors surgery - at the moment the only two choices are Northiam or Rye, each a drive or a bus journey away.
d) Dentist, the same options as the Doctors but not all will take NHS.
e) Employment, this is very limited in the area, combined with the assumption you have transport to get to a place of work and not relying on a poor transport system that doesn't correspond with train times.
f) Education. The village school is virtually up to full capacity.
g) Utilities. Gas pressure and broadband are already experiencing difficulties and failing the community, whilst upgrades are not a priority to the companies involved.

DO NOT AGREE
I believe that the three sites as specified in the answer the Question 81 should be the proposed development boundary in figure 109 and it should be amended to reflect this. Reasons for objections to site PS24.

1. As stated previously access to this site is extremely dangerous from the main road and directly to myself and my family who are immediately to the east of the property.
2. Drainage
a) Surface water. The proposal recognises the possible need for SuDS. The whole are is very poorly drained. The direct impact on adjacent properties would be a disaster.
b) Sewage. The drainage system that runs underneath Main Street has blocked on many an occasion, therefore the extra load could be sustained by the present system.
3. Impact on Amenity
This proposal impacts adversely on a significant number of dwellings as follows:
a) the proposal is outside the planning boundaries pertaining when people purchased houses adjoining. the reasonable expectation of "no disturbance" is thus denied and loss of value in our houses.
b) Public transport, of which the only form is the bus service every two hours and even more greatly reduced at weekends.
c) Doctors surgery - at the moment the only two choices are Northiam or Rye, each a drive or a bus journey away.
d) Dentist, the same options as the Doctors but not all will take NHS.
e) Employment, this is very limited in the area, combined with the assumption you have transport to get to a place of work and not relying on a poor transport system that doesn't correspond with train times.
f) Education - the village school is virtually full to capacity.
g) Utilities - gas pressure and broadband are already experiencing difficulties and failing the community, whilst upgrades are not a priority to the companies involved.

DO NOT AGREE
I believe that the three sites as specified in the answer the Question 81 should be the proposed development boundary in figure 109 and it should be amended to reflect this. Reasons for objections to site PS24.

1. As stated previously access to this site is extremely dangerous from the main road and directly to myself and my family who are immediately to the east of the property.
2. Drainage
a) Surface water. The proposal recognises the possible need for SuDS. The whole are is very poorly drained. The direct impact on adjacent properties would be a disaster.
b) Sewage. The drainage system that runs underneath Main Street has blocked on many an occasion, therefore the extra load could be sustained by the present system.
3. Impact on Amenity
This proposal impacts adversely on a significant number of dwellings as follows:
a) the proposal is outside the planning boundaries pertaining when people purchased houses adjoining. the reasonable expectation of "no disturbance" is thus denied and loss of value in our houses.
b) Public transport, of which the only form is the bus service every two hours and even more greatly reduced at weekends.
c) Doctors surgery - at the moment the only two choices are Northiam or Rye, each a drive or a bus journey away.
d) Dentist, the same options as the Doctors but not all will take NHS.
e) Employment, this is very limited in the area, combined with the assumption you have transport to get to a place of work and not relying on a poor transport system that doesn't correspond with train times.
f) Education - the village school is virtually full to capacity.
g) Utilities - gas pressure and broadband are already experiencing difficulties and failing the community, whilst upgrades are not a priority to the companies involved.

DO NOT AGREE
I believe that the three sites as specified in the answer the Question 81 should be the proposed development boundary in figure 109 and it should be amended to reflect this. Reasons for objections to site PS24.

1. As stated previously access to this site is extremely dangerous from the main road and directly to myself and my family who are immediately to the east of the property.
2. Drainage
a) Surface water. The proposal recognises the possible need for SuDS. The whole are is very poorly drained. The direct impact on adjacent properties would be a disaster.
b) Sewage. The drainage system that runs underneath Main Street has blocked on many an occasion, therefore the extra load could be sustained by the present system.
3. Impact on Amenity
This proposal impacts adversely on a significant number of dwellings as follows:
a) the proposal is outside the planning boundaries pertaining when people purchased houses adjoining. the reasonable expectation of "no disturbance" is thus denied and loss of value in our houses.
b) Public transport, of which the only form is the bus service every two hours and even more greatly reduced at weekends.
c) Doctors surgery - at the moment the only two choices are Northiam or Rye, each a drive or a bus journey away.
d) Dentist, the same options as the Doctors but not all will take NHS.
e) Employment, this is very limited in the area, combined with the assumption you have transport to get to a place of work and not relying on a poor transport system that doesn't correspond with train times.
f) Education - the village school is virtually full to capacity.
g) Utilities - gas pressure and broadband are already experiencing difficulties and failing the community, whilst upgrades are not a priority to the companies involved.

We regret that we are not able to agree, in their totality, to major changes to the development boundary.
The reasons may be implied from our comments on PEA1 and question 82.

We regret that we are not able to agree, in their totality, to major changes to the development boundary.
The reasons may be implied from our comments on PEA1 and question 82.

We regret that we are not able to agree, in their totality to major change to the development boundary. The reasons may be implied from our comments on PEA1 and question 82.

We regret that we are not able to agree, in their totality to major change to the development boundary. The reasons may be implied from our comments on PEA1 and question 82.

We regret that we are not able to agree, in their totality to major change to the development boundary. The reasons may be implied from our comments on PEA1 and question 82.

We regret that we are not able to agree, in their totality, to major changes to the development boundary.

The reasons may be implied from our comments on PEA 1 and question 82.

Ref DaSA Part C
Dear Sir

I am writing to you regarding the above proposed plan as it applies to Peasmarsh.

After consulting with various local people and after attending yesterday's Parish Council meeting it is apparent there is widespread objection to the proposal and indeed real alarm at the apparent paucity of research made by Council before issuing the proposals.

Whilst attached you will find an amalgam of various issues discussed and our reasons behind them I would draw your particular attention to two particular problems.

Several of my neighbours in so called Griffin Lane have endurde many problems with flooding at times of heavy/moderate rainfall when our gardens are turned into lakes as current drainage from the proposed site, cannot cope properly. Indeed in the 24 years I have lived at this address I have spent considerable sums trying to rectify this, to no avail. Your proposals for building on this land can only exacerbate this problem hugely, unless a major upgrade of surface water drainage and sewage is conducted well in advance of any building. Failure to do so would be a wilful example of you ignoring this fundamental problem.

The second major issue is the traffic access for the proposed site directly onto the A268 as suggested. Frankly, I am amazed that the proposed entry/exit point is regarded a safe and viable without major changes i.e. traffic calming, roundabouts etc.

As ever, the devil is in the detail but it is clear major expenditure is needed to overcome the problems referred to above. In an effort to be positive regarding development regarding question 81 for alternative sites you will see these are suggested which would have less onerous cost requirements for the council and would remove the danger of direct access onto the A268 main road.

The attached document will give you a more comprehensive view of our discontent with the proposal and I strongly disagree with the plan as it stands

Yours faithfully

Roger Evans.

We regret that we are not able to agree, in their totality, to major changes to the development boundary. The reasons may be implied from our comments on PEA1 and question 82.

We regret that we are not able to agree, in their totality, to major changes to the
development boundary. The reasons may be implied from our comments on PEA1 and question 82.

Question 25
I cannot speak for the wisdom or otherwise of development boundaries in other towns and villages. I am clear that the development boundary for Peasmarsh, already heavily developed, should not be moved. See reasons in answers to Questions 82 and 83.


Question 81
Alternative Sites Item 4 (below) would suggest that significant further development within Peasmarsh would be unwise unless and until local employment prospects are increased to cope with the expanded population that this implies. While the present school uptake is slightly below 100% improving performance of the local school, now forecast, taken together with current and proposed development would probably overwhelm this facility again pointing to the conclusion that development elsewhere where the objective criteria set out above can be met.

Further development would appear to conflict with NPPF (National Planning Guidelines) sec 11.13 which requires planers to make fullest possible use of public transport" (of which there is practically none) and to recognise "the intrinsic character and beauty of the countryside". In addition to these points that militate against further development there are some parts of the village where the gas supply is barely above the minimum allowable pressure, the electrical supply has recently required enhancement to maintain an adequate voltage, the telephone system has been causing ongoing problems and the broad-band speeds in some areas are disappointing.
If the comments above in regard to road access, impact on village amenities, local employment and educational opportunities, sewage and drainage and other limitations of local utilities are ignored by planners or over-ridden then without an in depth study of alternative possibilities within Peasmarsh any suggestion must be tentative.
However, two possible sites had unanimous acceptance but the point must be iterated that all sites within the village are subject to some if not all of the objections listed above. In descending order of preference:

Alternative Site 1
(a) A site behind Jempsons and marked on Planning Map PS6 and PS5 avoid some of the adverse consequences attaching to PEA1.
(1) In particular vehicular access into a slightly widened Tanhouse Lane and just above the existing roundabout meets the requirement of easy and safe access to the A268.
(2) Although this land is outside the present planning envelope (as is PEA1 proposal) it impacts adversely on very few houses
(3) It is thought that there would be no surface water drainage problem associated with this site

Alternative Site 2
Shown on the Planning Map as PS3
Further development of Tanyard Field i.e. behind the recent development of five houses.
(1) Good road access could be made into the bottom of Church Lane
(2) This site has already been partly developed along the road and falls within the planning envelope


Question 82
In regard to your question PEA1 my neighbours and I have discussed the proposed allocation. Our approach has been conditioned by a clear recognition of the need for some development and in particular that for affordable housing.
In order to approach this matter objectively we have come to the conclusion that any proposed site should meet a number of criteria or at least so far as is possible, and that these criteria should apply (a) to that site now proposed or (b) to any alternative site or sites whether or not within the village. Regrettably the proposed site fails to meet most of the criteria and although it might look a neat extension on a planner's map it is an almost perverse choice when looked at with local knowledge. Accordingly we do not agree with proposal PEA1 (Question 82) and the reasons are stated below.

The criteria for development:
1. Road Access: Access onto the busy A268, particularly from a development as large as 45 houses, should have a clear sight line in both directions. The destruction of Pippins to make way for an entry point does not meet this critereon because
(a) traffic approaching from the North West i.e. over Cock Hill: Does not have a sufficient line of sight because of the brow of the hill and the road curvature. In practice this line of sight is reduced below the theoretical measurement because drivers have to be aware of traffic accessing the road from Old House and Forstal's Farm Lane from the Cock Inn (often with caravans) and also from the individual housing. At certain times this traffic can be temporarily blinded when coming out of the shade over the brow of the hill into bright sunlight straight down the road
(b) traffic approaching from the South East is largely unsighted by the curvature of the road especially as is likely to be the case at peak times, when traffic needs to keep well away from the crown of the road because of oncoming wide loads. Again sighting the access point in practice is less than the theoretical line of sight because of the need to observe traffic accessing the road from both sides particularly Malthouse Lane on the driver's right and Griffin Lane or the left. Once again this proposal creates a traffic hazard even without the additional hazard of sight impairment resulting from parked vehicles.
In short the proposal is likely to create a traffic hazard even for vehicles adhering to the speed limits. While it could be possible to re-engineer this part of the roadway e.g. by traffic calming measures & a roundabout this would be an expensive proposition and would inevitably impede the traffic flow on the A268.

2. Drainage There are two considerations pertaining to the proposed site in regards to drainage namely (a) Surface water drainage and (b) foul water drainage (sewage).

(a) Surface Water. The proposal recognises the possible need for SuDS (which has been interpreted to mean Subterranean Drainage Scheme). In fact this whole area is very poorly drained, so much so that with a further 1.5 ha effectively covered with buildings and hard surfaced road the run-off could not be contained without a massive and therefore expensive drainage programme. If further consideration to this site is even to be entertained this installation should be a condition precedent which must be built, tried and tested before any planning permission be granted. Failure to implement proper drainage before housing development is likely to result in the sort of flooding experienced in the Mallards Estate (Farley's Way) despite promises made by planners and developers.
As things now stand any heavy rain leads to flooding to the South East to an unacceptable degree.

(b) Sewage. We understand that Rother Council made an undertaking that no significant further development should be undertaken unless and until there was an increased diameter sewage pipe connected to the Iden Sewage Works. Even making allowance for greater efficiency in water usage (fitting of meters, and more efficient machinery) the sheer size of the proposed development is most likely to overwhelm the present infrastructure. The development is approximately 8% of the total housing stock of Peasmarsh and a much higher percentage of that connected to the sewage system because many of the outlying houses are not on main drainage and have individual sceptic tanks. This increased sewage capacity must be installed before further development, other than small one off developments are to be considered.

3.Impact on Amenity
Developments should impact (adversely) as little as possible on the existing amenities. This proposal impacts adversely on a significant number of dwellings as follows:
(a) The proposal is outside the planning boundaries pertaining when people purchased houses adjoining. The reasonable expectation of 'no disturbance' is thus denied.
(b) The houses along Griffin Lane enjoy by virtue of the intrinsic nature of the topography, great tranquillity (so great that BBC have broadcast programmes that needed total quiet from the garden of Old Redford). The topography would likely work in reverse if the development took place as projected and the houses would be greatly affected by noise. This contention is supported by those rare, and thus acceptable, occasions when the Cock Inn have fireworks or a loud band. Such on going disturbance would be contrary to Government Planning Guidelines. (c) This disturbance would be exacerbated by the proposal in siting a common walkway at the end of the gardens of those houses along Griffin Lane, which would be both noisy and on the experience of those houses abutting the Main Street a dumping ground for undesirable rubbish. (d) the amenity expected within a village and that pertaining to a town or suburbia are quite different. Peasmarsh housing stock has already been expanded by some 70% since the war (against a population increase shown in the nearest relevant census of only 30%). The status of Peasmarsh as a quiet rural village is already threatened by the existing volume of expansion and the consequence of further expansion is to be avoided if possible.
4. Public Transport and Employment Clearly public transport and employment are separate subjects but they are taken together because each impacts heavily upon the other. The public transport in Peasmarsh is at that critically low point where to maintain even the semblance of an acceptable level of service it has had to be subsidised by the Parish Council. It is not yet known whether this will be successful. RDC introductory note that says "Peasmarsh (enjoys) a good range of services" is incorrect. Employment opportunities within the village or so nearby that public transport is not required are few. A development of 45 houses with some 40% 'affordable' houses (18) suggests that the householders may have the need of a good public transport system to gain and keep employment (or alternatively there would be significant traffic volume exiting a major development at the rush hours to get to work or children to school- see section 1 above). The conclusion from this is that such development that goes ahead should be within reach of a satisfactory transport system or employment opportunities which Peasmarsh does not offer.


Question 83
I regret that we me not able to agree, in their totality, to major changes to the development
boundary. The reasons may be implied from our comments on PEA1 and question 82.

Question 25
I cannot speak for the wisdom or otherwise of development boundaries in other towns and villages. I am clear that the development boundary for Peasmarsh, already heavily developed, should not be moved. See reasons in answers to Questions 82 and 83.


Question 81
Alternative Sites Item 4 (below) would suggest that significant further development within Peasmarsh would be unwise unless and until local employment prospects are increased to cope with the expanded population that this implies. While the present school uptake is slightly below 100% improving performance of the local school, now forecast, taken together with current and proposed development would probably overwhelm this facility again pointing to the conclusion that development elsewhere where the objective criteria set out above can be met.

Further development would appear to conflict with NPPF (National Planning Guidelines) sec 11.13 which requires planers to make fullest possible use of public transport" (of which there is practically none) and to recognise "the intrinsic character and beauty of the countryside". In addition to these points that militate against further development there are some parts of the village where the gas supply is barely above the minimum allowable pressure, the electrical supply has recently required enhancement to maintain an adequate voltage, the telephone system has been causing ongoing problems and the broad-band speeds in some areas are disappointing.
If the comments above in regard to road access, impact on village amenities, local employment and educational opportunities, sewage and drainage and other limitations of local utilities are ignored by planners or over-ridden then without an in depth study of alternative possibilities within Peasmarsh any suggestion must be tentative.
However, two possible sites had unanimous acceptance but the point must be iterated that all sites within the village are subject to some if not all of the objections listed above. In descending order of preference:

Alternative Site 1
(a) A site behind Jempsons and marked on Planning Map PS6 and PS5 avoid some of the adverse consequences attaching to PEA1.
(1) In particular vehicular access into a slightly widened Tanhouse Lane and just above the existing roundabout meets the requirement of easy and safe access to the A268.
(2) Although this land is outside the present planning envelope (as is PEA1 proposal) it impacts adversely on very few houses
(3) It is thought that there would be no surface water drainage problem associated with this site

Alternative Site 2
Shown on the Planning Map as PS3
Further development of Tanyard Field i.e. behind the recent development of five houses.
(1) Good road access could be made into the bottom of Church Lane
(2) This site has already been partly developed along the road and falls within the planning envelope


Question 82
In regard to your question PEA1 my neighbours and I have discussed the proposed allocation. Our approach has been conditioned by a clear recognition of the need for some development and in particular that for affordable housing.
In order to approach this matter objectively we have come to the conclusion that any proposed site should meet a number of criteria or at least so far as is possible, and that these criteria should apply (a) to that site now proposed or (b) to any alternative site or sites whether or not within the village. Regrettably the proposed site fails to meet most of the criteria and although it might look a neat extension on a planner's map it is an almost perverse choice when looked at with local knowledge. Accordingly we do not agree with proposal PEA1 (Question 82) and the reasons are stated below.

The criteria for development:
1. Road Access: Access onto the busy A268, particularly from a development as large as 45 houses, should have a clear sight line in both directions. The destruction of Pippins to make way for an entry point does not meet this critereon because
(a) traffic approaching from the North West i.e. over Cock Hill: Does not have a sufficient line of sight because of the brow of the hill and the road curvature. In practice this line of sight is reduced below the theoretical measurement because drivers have to be aware of traffic accessing the road from Old House and Forstal's Farm Lane from the Cock Inn (often with caravans) and also from the individual housing. At certain times this traffic can be temporarily blinded when coming out of the shade over the brow of the hill into bright sunlight straight down the road
(b) traffic approaching from the South East is largely unsighted by the curvature of the road especially as is likely to be the case at peak times, when traffic needs to keep well away from the crown of the road because of oncoming wide loads. Again sighting the access point in practice is less than the theoretical line of sight because of the need to observe traffic accessing the road from both sides particularly Malthouse Lane on the driver's right and Griffin Lane or the left. Once again this proposal creates a traffic hazard even without the additional hazard of sight impairment resulting from parked vehicles.
In short the proposal is likely to create a traffic hazard even for vehicles adhering to the speed limits. While it could be possible to re-engineer this part of the roadway e.g. by traffic calming measures & a roundabout this would be an expensive proposition and would inevitably impede the traffic flow on the A268.

2. Drainage There are two considerations pertaining to the proposed site in regards to drainage namely (a) Surface water drainage and (b) foul water drainage (sewage).

(a) Surface Water. The proposal recognises the possible need for SuDS (which has been interpreted to mean Subterranean Drainage Scheme). In fact this whole area is very poorly drained, so much so that with a further 1.5 ha effectively covered with buildings and hard surfaced road the run-off could not be contained without a massive and therefore expensive drainage programme. If further consideration to this site is even to be entertained this installation should be a condition precedent which must be built, tried and tested before any planning permission be granted. Failure to implement proper drainage before housing development is likely to result in the sort of flooding experienced in the Mallards Estate (Farley's Way) despite promises made by planners and developers.
As things now stand any heavy rain leads to flooding to the South East to an unacceptable degree.

(b) Sewage. We understand that Rother Council made an undertaking that no significant further development should be undertaken unless and until there was an increased diameter sewage pipe connected to the Iden Sewage Works. Even making allowance for greater efficiency in water usage (fitting of meters, and more efficient machinery) the sheer size of the proposed development is most likely to overwhelm the present infrastructure. The development is approximately 8% of the total housing stock of Peasmarsh and a much higher percentage of that connected to the sewage system because many of the outlying houses are not on main drainage and have individual sceptic tanks. This increased sewage capacity must be installed before further development, other than small one off developments are to be considered.

3.Impact on Amenity
Developments should impact (adversely) as little as possible on the existing amenities. This proposal impacts adversely on a significant number of dwellings as follows:
(a) The proposal is outside the planning boundaries pertaining when people purchased houses adjoining. The reasonable expectation of 'no disturbance' is thus denied.
(b) The houses along Griffin Lane enjoy by virtue of the intrinsic nature of the topography, great tranquillity (so great that BBC have broadcast programmes that needed total quiet from the garden of Old Redford). The topography would likely work in reverse if the development took place as projected and the houses would be greatly affected by noise. This contention is supported by those rare, and thus acceptable, occasions when the Cock Inn have fireworks or a loud band. Such on going disturbance would be contrary to Government Planning Guidelines. (c) This disturbance would be exacerbated by the proposal in siting a common walkway at the end of the gardens of those houses along Griffin Lane, which would be both noisy and on the experience of those houses abutting the Main Street a dumping ground for undesirable rubbish. (d) the amenity expected within a village and that pertaining to a town or suburbia are quite different. Peasmarsh housing stock has already been expanded by some 70% since the war (against a population increase shown in the nearest relevant census of only 30%). The status of Peasmarsh as a quiet rural village is already threatened by the existing volume of expansion and the consequence of further expansion is to be avoided if possible.
4. Public Transport and Employment Clearly public transport and employment are separate subjects but they are taken together because each impacts heavily upon the other. The public transport in Peasmarsh is at that critically low point where to maintain even the semblance of an acceptable level of service it has had to be subsidised by the Parish Council. It is not yet known whether this will be successful. RDC introductory note that says "Peasmarsh (enjoys) a good range of services" is incorrect. Employment opportunities within the village or so nearby that public transport is not required are few. A development of 45 houses with some 40% 'affordable' houses (18) suggests that the householders may have the need of a good public transport system to gain and keep employment (or alternatively there would be significant traffic volume exiting a major development at the rush hours to get to work or children to school- see section 1 above). The conclusion from this is that such development that goes ahead should be within reach of a satisfactory transport system or employment opportunities which Peasmarsh does not offer.


Question 83
I regret that we me not able to agree, in their totality, to major changes to the development
boundary. The reasons may be implied from our comments on PEA1 and question 82.


I would also like to add that historically a development of this type on this land was rejected in 1972 causing the development company Galleon Estates to go bankrupt and into liquidation. Although I do not have any record of why the planning permission was rejected at that time, I do not believe that there as been any improvement in the facilities of the village since then that would change that original decision. I fact over the thirty one years that I have lived here things have deteriorated.
We are now down to one shop in the village that doesn't open on Sundays. Public transport only exists with financial support from the Parish Council. In village employment in the form of a garage and repair workshop, and the wood yard have already gone for the benefit of housing development.

Houses that are built and others on the market in the village, take a long time to be sold and occupied and are often soon back up for sale which makes me wonder who these new houses are being made available for, certainly not the existing purchasers or those in the village.

I am also struggling to understand how this proposed development aims to, and I quote "improve pedestrian linkage connecting to the school and Main Street", if there is not going to be another pathway to School Lane. If there was, and it was via the southern aspect of the preferred site it wouldn't be an improvement any way because it would be uphill and parents with children will still use Main Street and the path opposite the Maltings or drive causing more chaos at the school.
School lane is manic with vehicles at school time as it is.

Access to the proposed site via "Pippins" will mean that 10 or more metres of highway will have a `priority solution`. Being that all the ground services will also have to pass under this section of road the risk of this narrow access being blocked by road works or other obstructions is relatively high. This would mean that the new development would be totally isolated and emergency vehicles, let alone residents would not be able to access the estate.

On a more personal note my houses was built by Galleon Estates and I have in the Conveyance for the property dated 25th August 1972 in the first schedule the full and free right of way along what I believe is the track that goes up between The Clock House( which used to be the old Post Office and shop) and Laurel Hall(which used to be the old Sunday School) to enable possible access to the rear of my land. I would be interested to know how this will be maintained should this proposed development go ahead. I believe that all four houses that were built by Galleon Estates have this same right.

I have worked for over fifty years to have a property that I can enjoy in my retirement. Looking out onto from my land and being partly surrounded by a housing estate is not a vision I had in my retirement plans.

We regret that we are not able to agree, in their totality, to major changes to the development boundary. the reasons may be implied from our comments on PEA1 and question 82.

I wish to make comments about the land south of Main Street covered in your policy PEA1 site PS24. My main concerns is the unsuitable vehicle access from and on to Main Street. This is rather narrow and is on a piece of road that has a slight bend that will restrict visibility. I note the development is for 45 dwellings and this has a potential of 60 to 70 cars plus all the service vehicles trying to exit onto the main road. We live adjacent to the site and have suffered three cars written off by vehicles running into them during our residency in Peasmarsh.

You state that Peasmarsh has a good range of services. We are lucky to have a very good supermarket but a bus service only once in two hours and a primary school that is virtually at full capacity now, no doctor's surgery and no street lighting. The development will have a lasting impact on the surrounding area, this will I feel be detrimental and other sites need to be considered instead such as one or two smaller ones.

Question 24

I agree with the policy approach to a comprehensive development but reserve judgement on the proposed policy wording. It should be noted that the correct and sensible approach does not of itself insure a sensible outcome. For the reasons stated in answers to your questions 82 and 83 some very unwise and ill thought out proposals have resulted. Perhaps the Planners have become carried away by enthusiasm in making recommendations in regards to Peasmarsh and, for example, the inclusion of a derelict orchard (decaying trees) within or attaching to a children's' play area creating a wholly unnecessary hazard.

Question 25
I cannot speak for the wisdom or otherwise of development boundaries in other towns and villages. I am clear that the development boundary for Peasmarsh, already heavily developed, should not be moved. See reasons in answers to Questions 82 and 83.





































































Question 81
Alternative Sites Item 4 (below) would suggest that significant further development within Peasmarsh would be unwise unless and until local employment prospects are increased to cope with the expanded population that this implies. While the present school uptake is slightly below 100% improving performance of the local school, now forecast, taken together with current and proposed development would probably overwhelm this facility again pointing to the conclusion that development elsewhere where the objective criteria set out above can be met.

Further development would appear to conflict with NPPF (National Planning Guidelines) sec 11.13 which requires planers to make fullest possible use of public transport" (of which there is practically none) and to recognise "the intrinsic character and beauty of the countryside". In addition to these points that militate against further development there are some parts of the village where the gas supply is barely above the minimum allowable pressure, the electrical supply has recently required enhancement to maintain an adequate voltage, the telephone system has been causing ongoing problems and the broad-band speeds in some areas are disappointing.
If the comments above in regard to road access, impact on village amenities, local employment and educational opportunities, sewage and drainage and other limitations of local utilities are ignored by planners or over-ridden then without an in depth study of alternative possibilities within Peasmarsh any suggestion must be tentative.
However, two possible sites had unanimous acceptance but the point must be iterated that all sites within the village are subject to some if not all of the objections listed above. In descending order of preference:

Alternative Site 1
(a) A site behind Jempsons and marked on Planning Map PS6 and PS5 avoid some of the adverse consequences attaching to PEA1.
(1) In particular vehicular access into a slightly widened Tanhouse Lane and just above the existing roundabout meets the requirement of easy and safe access to the A268.
(2) Although this land is outside the present planning envelope (as is PEA1 proposal) it impacts adversely on very few houses
(3) It is thought that there would be no surface water drainage problem associated with this site

Alternative Site 2
Shown on the Planning Map as PS3
Further development of Tanyard Field i.e. behind the recent development of five houses.
(1) Good road access could be made into the bottom of Church Lane
(2) This site has already been partly developed along the road and falls within the planning envelope















Question 82
In regard to your question PEA1 my neighbours and I have discussed the proposed allocation. Our approach has been conditioned by a clear recognition of the need for some development and in particular that for affordable housing.
In order to approach this matter objectively we have come to the conclusion that any proposed site should meet a number of criteria or at least so far as is possible, and that these criteria should apply (a) to that site now proposed or (b) to any alternative site or sites whether or not within the village. Regrettably the proposed site fails to meet most of the criteria and although it might look a neat extension on a planner's map it is an almost perverse choice when looked at with local knowledge. Accordingly we do not agree with proposal PEA1 (Question 82) and the reasons are stated below.

The criteria for development:
1. Road Access: Access onto the busy A268, particularly from a development as large as 45 houses, should have a clear sight line in both directions. The destruction of Pippins to make way for an entry point does not meet this critereon because
(a) traffic approaching from the North West i.e. over Cock Hill: Does not have a sufficient line of sight because of the brow of the hill and the road curvature. In practice this line of sight is reduced below the theoretical measurement because drivers have to be aware of traffic accessing the road from Old House and Forstal's Farm Lane from the Cock Inn (often with caravans) and also from the individual housing. At certain times this traffic can be temporarily blinded when coming out of the shade over the brow of the hill into bright sunlight straight down the road
(b) traffic approaching from the South East is largely unsighted by the curvature of the road especially as is likely to be the case at peak times, when traffic needs to keep well away from the crown of the road because of oncoming wide loads. Again sighting the access point in practice is less than the theoretical line of sight because of the need to observe traffic accessing the road from both sides particularly Malthouse Lane on the driver's right and Griffin Lane or the left. Once again this proposal creates a traffic hazard even without the additional hazard of sight impairment resulting from parked vehicles.
In short the proposal is likely to create a traffic hazard even for vehicles adhering to the speed limits. While it could be possible to re-engineer this part of the roadway e.g. by traffic calming measures & a roundabout this would be an expensive proposition and would inevitably impede the traffic flow on the A268.

2. Drainage There are two considerations pertaining to the proposed site in regards to drainage namely (a) Surface water drainage and (b) foul water drainage (sewage).

(a) Surface Water. The proposal recognises the possible need for SuDS (which has been interpreted to mean Subterranean Drainage Scheme). In fact this whole area is very poorly drained, so much so that with a further 1.5 ha effectively covered with buildings and hard surfaced road the run-off could not be contained without a massive and therefore expensive drainage programme. If further consideration to this site is even to be entertained this installation should be a condition precedent which must be built, tried and tested before any planning permission be granted. Failure to implement proper drainage before housing development is likely to result in the sort of flooding experienced in the Mallards Estate (Farley's Way) despite promises made by planners and developers.
As things now stand any heavy rain leads to flooding to the South East to an unacceptable degree.

(b) Sewage. We understand that Rother Council made an undertaking that no significant further development should be undertaken unless and until there was an increased diameter sewage pipe connected to the Iden Sewage Works. Even making allowance for greater efficiency in water usage (fitting of meters, and more efficient machinery) the sheer size of the proposed development is most likely to overwhelm the present infrastructure. The development is approximately 8% of the total housing stock of Peasrnarsh and a much higher percentage of that connected to the sewage system because many of the outlying houses are not on main drainage and have individual sceptic tanks. This increased sewage capacity must be installed before further development, other than small one off developments are to be considered.

3.Impact on Amenity
Developments should impact (adversely) as little as possible on the existing amenities. This proposal impacts adversely on a significant number of dwellings as follows:
(a) The proposal is outside the planning boundaries pertaining when people purchased houses adjoining. The reasonable expectation of 'no disturbance' is thus denied.
(b) The houses along Griffin Lane enjoy by virtue of the intrinsic nature of the topography, great tranquillity (so great that BBC have broadcast programmes that needed total quiet from the garden of Old Redford). The topography would likely work in reverse if the development took place as projected and the houses would be greatly affected by noise. This contention is supported by those rare, and thus acceptable, occasions when the Cock Inn have fireworks or a loud band. Such on going disturbance would be contrary to Government Planning Guidelines. (c) This disturbance would be exacerbated by the proposal in siting a common walkway at the end of the gardens of those houses along Griffin Lane, which would be both noisy and on the experience of those houses abutting the Main Street a dumping ground for undesirable rubbish. (d) the amenity expected within a village and that pertaining to a town or suburbia are quite different. Peasmarsh housing stock has already been expanded by some 70% since the war (against a population increase shown in the nearest relevant census of only 30%). The status of Peasmarsh as a quiet rural village is already threatened by the existing volume of expansion and the consequence of further expansion is to be avoided if possible.
4. Public Transport and Employment Clearly public transport and employment are separate subjects but they are taken together because each impacts heavily upon the other. The public transport in Peasmarsh is at that critically low point where to maintain even the semblance of an acceptable level of service it has had to be subsidised by the Parish Council. It is not yet known whether this will be successful. RDC introductory note that says "Peasmarsh (enjoys) a good range of services" is incorrect. Employment opportunities within the village or so nearby that public transport is not required are few. A development of 45 houses with some 40% 'affordable' houses (18) suggests that the householders may have the need of a good public transport system to gain and keep employment (or alternatively there would be significant traffic volume exiting a major development at the rush hours to get to work or children to school- see section 1 above). The conclusion from this is that such development that goes ahead should be within reach of a satisfactory transport system or employment opportunities which Peasmarsh does not offer.










Question 83
We regret that we me not able to agree, in their totality, to major changes to the development boundary. The reasons may be implied from our comments on PEA1 and question 82.

The following comments, related to biodiversity matters, are made on behalf of the Sussex Wildlife Trust.

If a question from the consultation is not included below, please assume that the Trust has no comments to make at this time.

PART B: DEVELOPMENT POLICIES

QUESTION 2: Do you agree that the optional water efficiency standard should be adopted and the proposed policy wording?

We are concerned that this policy appears to limit itself to water efficiency and believe that it should be broader in its approach to water resource management. The policy appears to consider only domestic water efficiency and we question if the policy should also consider commercial use.

QUESTION 3: Where, if anywhere, do you think could be an appropriate location for wind turbine(s) to be sited in the District?

Any proposal for wind turbines and associated infrastructure, such as connections to the grid, needs to ensure that impacts on biodiversity and their placement within the landscape in terms of their potential impacts on ecological networks are assessed before suggestions are made regarding suitable locations.
Therefore changes in policy wording to reflect this should be made.

QUESTION 4: What opportunities do you think there are to encourage biomass/wood fuel from local sources and how should these be reflected in planning policy?

This could be demonstrated through a policy which encourages biomass potential in commercial and possibly residential developments through appropriate design. However, the policy would need to recognise the importance of protecting woodlands so that their biodiversity value is considered and enhanced through the process. Further, the Rother Local Plan currently does not include an ancient woodland policy; if a wood fuel policy is adopted a separate ancient woodland policy is needed.

QUESTION 7: Do you agree with the policy approach to equestrian developments and the proposed policy wording?

We are encouraged to see the supporting text for this policy recognise the sensitivities of equestrian developments in the countryside and the need to ensure that these features are safeguarded. In relation to this we highlight that in paragraph 7.16 the last sentence states 'However, there is scope for equestrian development in the countryside that is limited in scale'. The term 'scale' perhaps needs defining to add clarity.

We are concerned about equestrian developments being proposed on designated sites such as Local Wildlife Sites. Therefore we welcome an approach to more clearly defined acceptable limits of equestrian development in relation to designated sites. The policy could benefit from underlining the need for up to date ecological management plans accompanying proposals, as per National Planning Policy Framework ( NPPF) section 165.

QUESTION 12: Do you agree with the proposed policy approach to external residential areas and the proposed policy wording? If not, what changes would you wish to see?

Creative approaches and orientation should be considered when designing external spaces. Their setting within the green infrastructure aspirations of the District should be looked at during the planning application stage. This would ensure a holistic and considered approach to green infrastructure.

While bullet point (i) gives clarity to the external spaces of dwellings of 3 or more bedrooms, there is a lack of commitment to the amount of space need for flat and complex developments. The last sentence of this bullet point states that, 'an appropriate level of usable community and amenity space should be provided'. We are concerned that this statement does not give the decision maker a clear enough direction for its interpretation.

Bullet point (ii) should reference the need to be permeable and where gardens are being lost efforts should be made to ensure there is no loss to biodiversity reference NPPF section 109. The council may find the RHS advice leaflet useful www.rhs.org.uk/advice/profile?PID=738

We suggest bullet point (iii) uses wording to incorporate green roofs on waste and recycling stores to help add to a developments' contribution to biodiversity as per NPPF section 118 'Opportunities to incorporate biodiversity in and around developments should be encouraged'.

QUESTION 13: Do you agree with the proposed policy approach to extensions to residential gardens and the proposed policy wording? If not, what changes would you wish to see?

This is an interesting policy and we welcome its inclusion. The Sussex Wildlife Trust have concern that an extension to a garden, if allowed, could in time lead to other development within that garden boundary. Therefore, the type of habitat a garden extension would involve needs to be considered.

We remind Rother District Council that the NPPF section 53 highlights the need to resist inappropriate development of gardens. Therefore perhaps wording to this effect is needed within the policy.

QUESTION 15: Do you agree with the policy approaches to boundary treatments and drives and accesses and to the wording of the proposed policies? If not, what changes would you wish to see?

The Sussex Wildlife Trust suggests that policy DHG7 (Boundary Treatments) includes wording to reflect the sentiments of section 118 of the NPPF.

This could be achieved by including a bullet point requiring impermeable boundary features to include gaps or passages beneath them to enable movement of wildlife such as hedgehogs and amphibians.

In addition policy DHG8 (Accesses and Drives) should reflect the need to ensure the proposals for new driveways do not lead to a loss in natural capital delivering ecosystem services. Therefore these should be permeable and look to include biodiversity features. See RHS guidance www.rhs.org.uk/advice/profile?PID=738

QUESTION 18: Do you agree with the policy approaches to maintaining landscape character and the High Weald AONB and to the respective proposed policy wordings?

The Sussex Wildlife Trust supports the policy approach to maintaining landscape character and the High Weald AONB. We recommend that policy DEN2 be strengthened by the addition of wording requiring development to deliver biodiversity gains which meet the AONB objectives.

We are concerned that the wording in the last sentence of the policy 'major development will be resisted' would not allow a decision maker to be clear when determining an application. What is the level of resistance intended?

QUESTION 19: Do you agree with the proposed definition of the Strategic Gaps, and the policy applying to them? If not, what changes would you wish to see?

Figure 7 demonstrates that an area of the existing Bexhill and Hastings/St Leonards green gaps is proposed to be removed from the strategic gap. However the supporting text (10.19 - 10.21) does not indicate the reasons for the exclusion. We feel the supporting text for this section would benefit from a brief explanation for the reason in inclusion or exclusion of areas.

We ask the council to consider the value of the strategic gaps in harnessing the district's natural capital. This natural capital will be delivering vital ecosystem services to the district and potentially to the authorities adjoining Rother District. Therefore we would suggest that this is reflected in the policy wording by:
'Within these gaps development will be carefully controlled and development will only be permitted in exceptional circumstances. Any development must be unobtrusive, not detract from the openness of the area and ensure that ecosystem services are not compromised.'

We believe this additional wording will reflect the importance of strategic gaps for ecosystems service delivery and will also enable the policy to sit in line with NPPF para 109.

QUESTION 20: Do you agree with the policy approach to supporting biodiversity and green space and to the proposed policy wording?

We are encouraged by the manner in which the supporting text for this policy has been approached. The Sussex Wildlife Trust supports the inclusion of an 'Enhancement Policy' approach, however the wording should be strengthened to better conform to the wording and ethos of Chapter 9 of the NPPF.

Part i - the qualification of 'in principle' should be removed. The proposal is either supported in full or it is not, 'in principle' adds nothing to the policy.

Part ii - the word 'significant' should be removed. All developments should aim to avoid harm to biodiversity.

Part iii - should look to reflect the sentiments of the NPPF section 109. The first sentence should be amended to read:
'In addition to ( ii) above , all developments will be expected to deliver net gain to biodiversity by retaining and enhancing biodiversity in a manner appropriate to the local context ....'

Part iv has a requirement for 'larger developments of more than 2 hectare or 50 dwellings...' to produce a green infrastructure (GI) masterplan'. Looking at the allocations, very few meet this requirement. We recognise that there are some larger allocations around Bexhill where we would certainly support the need to produce GI masterplans but we are concerned about the substantial number of allocations which do not meet these criteria. We suggest that the threshold is lowered to 25 dwellings. We also recommend that the policy requires all development to contribute to the aspirations of Rother's Green Infrastructure Strategy.

We suggest that Rother District Council include an Ancient Woodland policy within the Local Plan. This would reflect the ethos of the NPPF which clearly states in section 117:
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

QUESTION 21: Do you agree with the policy approach to sustainable drainage and the proposed policy wording?

Reviewing the supporting text and policy wording there is no recognition of Pevensey and Pett being low lying areas (below sea level) and the associated risk of sea and ground water flooding. We suggest that this is included.

QUESTION 23: Do you agree with the policy approach to managing environmental pollution through the planning process and with the proposed policy wording?

The policy would be strengthened by ensuring that there is mention of biodiversity within the policy bullet point relating to lighting.

Lastly, although the supporting text highlights that the district is not subject to any Air Quality Management Areas, with increasing development we suggest that the council recognise the natural capital that helps filter and deal with pollutants.

Increased levels of development in the district means resources may come under increasing pressure. It may benefit the council to consider talking to the Sussex Biodiversity Record Centre about their Ecoserve programme. This programme shows where the district's natural capital is delivering ecosystem services such as air purification in relation to population demand.

QUESTION 24: Do you agree with the policy approach to comprehensive development and the proposed policy wording?

We support recognising the importance of a holistic approach to development which considers the three roles of sustainable development. In order to achieve this within the policy wording we suggest that the policy looks to include wording regarding net gain to biodiversity as per section 109 of the NPPF. We feel that this is important as phased development may overlook the cumulative impact on the district's natural capital and the ecosystem services being delivered.

PART C: SITE ALLOCATIONS

General Comments
The Trust recognises that the presence of designated sites and priority habitats and species has been a contributing factor in the assessment of the suitability of site allocations. We very much support the council's approach to exclude designated sites and sites of high biodiversity value for development. However we note that the site assessments were primarily based on desk-top studies. With the exception of North Bexhill and Spindlewood Drive it does not appear that any on the ground assessments have been carried out.

Given the council's commitment in the Core Strategy objectives 'To protect important ecological resources in the district' and in policy EN5 to 'support opportunities for management, restoration and creation of habitats...' we recommend that preliminary ecological appraisals are carried out for the preferred sites before they are officially allocated. This will ensure that any issues relating to ecology are identified before the plan reaches the examination stage.

We are pleased to see that the 'Key constraints/opportunities' sections for many of the preferred site allocations consider ecological impacts. However, these considerations are again inconsistently reflected in policy wording. For example, policy IDE1 requires that an ecological assessment is undertaken and that any impact on protected species mitigated. Further to this, policy MAR1 states that development proposals should be subject to an ecological survey.

By singling out only two of the site allocations, this may give the impression that proposals for other allocations may not require ecological surveys. The NPPF has a clear requirement for planning decisions to be based on up to date information and for development to achieve net gains for biodiversity. It would not be acceptable for proposals to proceed without the inclusion of up to date ecological information, especially given that thus far the sites have only been assessed at a desk-top level. This position needs to be reflected in the Biodiversity Policy (please see comments for QUESTION 20) and in all the site allocation policies. Therefore the following wording should be added to all site allocations:
'Prior to determination:
A site wide landscape and ecological management plan that is informed by up to date ecological information, including information on the site's utilisation and delivery of ecosystems services, will be produced. Mechanisms needed for implementation will be identified and secured. This will be to the
satisfaction of the local planning authority to ensure long term maintenance of retained and newly created habitats.'

We recognise that information regarding a site's utilisation of ecosystem services maybe too onerous for small allocations. However, we take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Ecoserve. This programme uses biodiversity and habitat data to look at the ecosystems services currently provided by an area's natural capital. It also assesses where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider as an aid to helping smaller developments see how they could make a contribution or enhancements to the continued delivery of those services through their site.

Additionally, many of the site allocations are adjacent to ancient woodland. Again whilst this is usually noted in the 'Key constraints/opportunities' section, it is not consistently reflected in the policy wording for the allocation. For example Policy BRO1 part (v) specifies that 'a buffer zone of at least 15 metres is provided to the Ancient Woodland', while the presence of an ancient woodland is not mentioned in, for example, policy BEX1 or BEX2. Conversely policy BEX 9 does specify the need for a buffer to protect the adjacent ancient woodland, but the width of the buffer is not specified.

Core Strategy policy EN1 and NPPF paragraph 118 require the protection of ancient woodland in the district. Additionally, Natural England's Ancient Woodland standing advice is clear that a minimum buffer must be at least 15 metres. We therefore recommend that an Ancient Woodland policy is included in the DaSA and that any site allocation policy with the potential to impact on ancient woodland includes a requirement of a buffer zone of at least 15 metres.

We also note that most of the allocations require the 'retention and enhancement of boundary planting'. We understand that this requirement is primarily to mitigate visual impacts on the AONB, however this is also an opportunity to ensure that each allocation contributes to the creation of an ecological network for the district. We therefore recommend that when boundary planting is specified, additional wording is used, such as:
'Provision is made for the retention and enhancement of boundary planting, for the benefit of biodiversity and for screening purposes'.

The majority of the site allocation policies use the term 'some' when describing the number of dwellings or size of employment space required within a development. This is not a standard planning term and hence we are concerned that its use leaves the policies open to broad interpretation. Given the landscape and ecological sensitivities of many of the site allocations, we recommend that a maximum figure is proposed in each policy. This will provide clarity and ensure that the policy can be robustly applied.

Alternatively, if an approximate value is preferred, we recommend the use of the word 'approximately' rather than 'some' as this is more frequently used in a planning policy context. However, if the council is minded to use this approach, we would ask that an additional requirement is added to the policies to ensure that overdevelopment does not occur. We recommend the following:
'The final number of dwellings/employment size selected must be based on up to date environmental information that demonstrates the current ecosystem delivery of the site and its capacity to absorb the proposed level of development. '

QUESTION 26: Do you agree with the requirements of Policy BEX1? If not, how would you wish to see it amended?

General comment
The Sussex Wildlife Trust supports a plan-led planning process and acknowledges that site BEX1 is included in the adopted North East Bexhill SPD. However, we question whether the district's natural capital can absorb this level of development around Bexhill. All the allocated sites around the north east of Bexhill should be treated holistically and assessed for their impact on ecosystem services (NPPF paragraphs 109, 114 and 117). There must be a strategic approach to the development of these sites to ensure that ecological networks are retained across the sites.

Policy BEX1
We support the protection of the adjacent ancient woodland and the retention of the tree line through the centre of the site, as shown in the detailed map. However, this protection does not appear to be repeated in the policy wording. Additionally, the 'Key constraints/opportunities' section recognises that the land along the Combe stream to the north-west of the site should be retained as an amenity/wildlife corridor. Again, this is not reflected in policy wording. If requirements are not included in the policy, we are concerned that they may be disregarded at the application stage. This could also lead to confusion for developers and inconsistency in the decision making process. Therefore, policy BEX1 should be strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 The retention of the central belt of trees and enhancements to create a robust corridor between the ancient woodland and the wider countryside.
 The retention of the land along the Combe stream as an amenity/wildlife corridor
The Trust supports the retention of the central tree belt; however, the proposed access appears to sever this corridor. We recommend that the access is reconfigured to ensure the corridor is preserved in its entirety. If this is not deemed feasible wording should be added to ensure that the tree belt still functions as and ecological corridor.

It is vital that any green infrastructure within the site connects well to the surrounding area. We recommend additional wording in section (iv) to insure this:
'landscape and woodland belts are developed, implemented and connected to the wider landscape as an integral part of proposals'.

QUESTION 27: Do you agree with the preferred sites for housing development at Bexhill? If not, which site(s) should be preferred?

The Trust questions whether the district's natural capital is able to absorb this level of development around Bexhill. Before finalising site allocations, especially larger greenfield sites around the development boundary, we recommend that the council assesses the capacity of these sites to provide ecosystem services. We take this opportunity to highlight to the council that the Sussex Biodiversity Record Centre are now able to run a programme called Eco serve which uses biodiversity and habitat data to look at the ecosystems services the natural capital is currently providing and where the demand for those services are in relation to population. We suggest that this might be a useful evidence base for the council to consider.
QUESTION 28: Do you agree with the requirements of Policy BEX2? If not, how would you wish to see it amended?

General comment
As per our comments for QUESTION 26, site BEX2 should be assessed strategically with allocation BEX1 and BEX3. Overall, these allocations cover a significant area of greenfield, which will be providing vital ecosystem services to the district. The cumulative impact of these allocations on the district's natural capital needs to be assessed and accounted for to ensure that the expansion of Bexhill is truly sustainable as per the NPPF. Additionally, any green infrastructure strategy should cover all these sites to ensure permeability throughout the developments and multifunctional benefits across the north east of Bexhill are achieved.

Policy BEX2
As per our comments for QUESTION 26, we are concerned that some of the intentions in the 'Key constraints/opportunities' section and the detailed map are not reflected in the policy wording. We recommend that policy BEX2 is strengthened to include:
 A buffer of at least 15 metres to the ancient woodland
 Part (ii) should include a requirement for the pond to be retained as an ecological feature with landscaping to connect it to the wider countryside

QUESTION 29: Do you agree with the requirements of Policy BEX3? If not, how would you wish to see it amended?

Notwithstanding our general comments in QUESTIONS 26 and 28, if development is to occur here then option 1 would be preferable. This would retain a larger proportion of greenfield and allow more creative approaches to green infrastructure and ecological enhancements. We recommend that information on the site's utilisation and delivery of ecosystem services should be produced and used to inform the site's layout.

The Trust is concerned that the now approved North Bexhill Access Road severs the ghyll woodland at Kiteye Wood.

Any development in this area should seek to mitigate this impact through appropriate habitat creation and/or management. Additionally, the policy should make reference to the retention of the land along the Combe stream as an amenity/wildlife corridor, as per policy BEX1. These requirements could be included in part (vii) of the policy, which we support.

As with previous comments the wording to protect ancient woodland should be strengthened to include a requirement for a 15 metre buffer.

We also recommend that the policy protects the 'Woodland Complex at Buckholt Farm' Local Wildlife Site, to the north east of the site allocation. Whilst it sits outside the development boundary, this ancient woodland could still be harmed by the indirect impacts of the development. These need to be assessed and avoided at the master planning stage.

QUESTION 33: Do you agree with the requirements of Policy BEX7? If not, how would you wish to see it amended?

The Trust supports the retention of the southern section of the site as an ecology area. However, the wording of section (iv) should be strengthened to include a requirement to enhance the area as per core strategy policy EN5. We recommend:
'The southern section of the site remains undeveloped as an ecology area. Ecological enhancements should be implemented to improve the area for biodiversity. Provision should be made for the long term management of this area.'
QUESTION 35: Do you agree with the requirements of Policy BEX9? If not, how would you wish to see it amended?

The Trust supports the retention of the tree belts in the centre of the site, the designation as a natural green space and the wording of part (vi). However, it is not clear to us how this corridor will be retained intact given that vehicle access is only proposed from the east of the site. This indicates that internal roads will sever the corridor in order to access the residential area in the North West. This should be a consideration in designing the layout of the site. At the very least we recommend wording to ensure that the integrity of the green corridor is maintained.

We support the inclusion of section (vii), however this should be strengthened with a requirement for the ancient woodland buffer at least 15 metres wide.

Additionally, it should be specified that the pond is retained as an ecological feature, rather than as part of any SuDS scheme for the site.

QUESTION 36: Do you agree with the requirements of Policy BEX10? If not, how would you wish to see it amended?

The Trust supports requirement (ii), however this should be expanded to specify that integration includes an integrated scheme of green infrastructure to ensure that the entire site remains permeable and receives multifunctional benefits.
The words 'where possible' should be removed from part (v). The pond should be retained and enhanced; this cannot be seen as unduly onerous given the site of the scheme.

QUESTION 37: Which of the development options for Northeye do you prefer? Should other options be considered?

Any policy for this site must include protections against the potential negative impacts of the creation of sports pitches such as flood lighting and impermeable surfaces. We recommend wording is included to ensure that there are no harmful impacts of this type of development.

QUESTION 38: Do you agree with the requirements of Policy BEX11? If not, how would you wish to see it amended?

This policy should include wording to manage the type of playing pitches which might be suitable on this site. Consideration should be made to the use of artificial pitches and associated lighting. In particular, potential impacts on bats which are likely to be present in the area should be considered.

QUESTION 43: Do you agree with the requirements of Policy BEX15? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that 'a large proportion of the site suffers from surface water flooding'. Therefore, we recommend that an additional criterion is added to the policy to ensure that a SuDS scheme is implemented to rectify this issue. We also recommend that green infrastructure is included to both help with the flooding issue and to connect the site to the wider GI network in the town.

QUESTION 47: Do you agree with the preferred site for housing development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust supports the allocation of brownfield sites of low ecological value over the allocation of greenfield sites. A large amount of development is already proposed for the fringes of Hastings through the Hastings Development Management Plan. We would not support any further urban sprawl into the surrounding countryside without full accounting of the area's natural capital and assessment of the area's utilisation and delivery of ecosystem services.

QUESTION 49: Do you agree with the preferred sites for employment development along the Hastings Fringes? If not, which site(s) should be preferred?

The Trust does not support further urban sprawl at the Hastings fringe; however of the four sites recommended, the preferred sites seem to be the least damaging. As stated previously we recommend that preliminary ecological appraisals are carried out before sites are formally allocated to ensure that there is no significant harm to biodiversity.

Additionally, a wider green infrastructure plan should be required, covering both of these sites in conjunction with the adjacent Hasting allocations to ensure a holistic approach.

QUESTION 50: Do you agree with the requirements of Policy HAS2? If not, how would you wish to see it amended?

We recommend that point (iv) is strengthened as follows to ensure net gains to biodiversity as per the NPPF:
'provision is made, in conjunction with the adjoining employment allocations, for the retention, enhancement and long-term future management of woodland to the north of the site for the benefit of biodiversity'.

QUESTION 51: Do you agree with the requirements of Policy HAS3? If not, how would you wish to see it amended?

We support criterion (iv), however any green infrastructure should be integrated into the surrounding employment allocations, to ensure multifunctional benefits are seen across the whole area.

QUESTION 53: Do you agree with the requirements of Policy HAS5, including the boundary as defined in the Policies Map? If not, how would you wish to see it amended?

We recommend an addition to criterion (ii) to ensure net gains to biodiversity as per the NPPF.
'...the Site of Nature Conservation Importance within it, and creates net gains to biodiversity within the Park...'

QUESTION 54: Do you agree with the recommendation regarding the Hastings Fringes development boundaries? If not, please explain how you wish the development boundaries to be applied to this area?

The Trust strongly supports the designation of a strong development boundary which prevents further urban sprawl into the wider countryside. (Please see QUESTION 47).

QUESTION 56: Do you agree with the requirements of Policy BEC1? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 57: Do you agree with the requirements of Policy BEC2? If not, how would you wish to see it amended?

We recommend that the policy is strengthened to better reflect the contents of the 'Key constraints/opportunities' section. In particular, reference should be made to the requirement to keep the remaining area as amenity land and to the retention of the pond as an ecological feature rather than as part of any SuDS scheme deemed necessary.

QUESTION 59: Do you agree with the preferred sites for development at Broad Oak? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value such as BO14. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 60: Do you agree with the requirements of Policy BRO1? If not, how would you wish to see it amended?

The Trust strongly supports the wording of requirement (v) and the specification of a buffer of at least 15 metres. We recommend that this wording is replicated in other policies for sites adjacent to ancient woodland.

We support requirement (iv), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 61: Do you agree with the requirements of Policy BRO2? If not, how would you wish to see it amended?

We support requirement (iii), but would recommend the addition of 'for the benefit of biodiversity' to ensure that any tree and hedgerow planting contributes to the wider ecological network of the district.

QUESTION 65: Do you agree with the requirements of Policy CAM2? If not, how would you wish to see it amended?

This policy needs to be strengthened to ensure that the adjacent Local Wildlife Site, Local Geological Site, SSSI and Special Protection Area are protected from harm. Whilst the protection and management of the dunes is a key landscape and ecological objective of the SPD, there does not appear to be a specific requirement to protect and enhance these designated sites. This should be addressed in the policy.

QUESTION 66: Do you agree with the proposed development boundary? If not, how would you wish to see it amended?

The Trust strongly supports the deletion of the SSSI from the development boundary. Dungeness, Romney Marsh & Rye Bay SSSI is of national importance to biodiversity and should not be degraded through encroaching development.

QUESTION 68: Do you agree with the requirements of Policy CAT1? If not, how would you wish to see it amended?

The 'Key constraints/opportunities' section states that buffer planting should be informed by ecological surveys, however this requirement is not reflected in the policy wording. Given that the site appears to contain well developed scrub, any application for this site must include a thorough ecological survey to assess if the site can absorb the level of development suggested whilst producing net gains for biodiversity.

QUESTION 69: Do you agree with the requirements of Policy CAT2? If not, how would you wish to see it amended?

Requirement (iii) should be subject to ecological surveys to assess the impact of severing the hedgerow. We also recommend that 'for the benefit of biodiversity' is added to the end of requirement (iv)(b) to ensure that any tree and hedgerow planting contributes to the wider ecological network in Catsfield.

QUESTION 72: Do you agree with the requirements of Policy HUR1? If not, how would you wish to see it amended?

As the stream/ditch that sub-divides the two lower fields is recommended to be retained for both heritage and ecological reasons, this should be reflected in the policy. We recommend that requirement (vii) is amended to:
'...is retained and incorporated within the layout as an ecological feature. Development should ensure that the biodiversity value of the feature is enhanced and that it is integrated into the wider blue/green infrastructure plan for the site...'

QUESTION 73: Do you agree with the requirements of Policy HUR2? If not, how would you wish to see it amended?

This site is adjacent to Hurst Green Meadows and Woodland Local Wildlife Site. This should be acknowledged in the policy and a requirement to protect and enhance the LWS should be included.

QUESTION 76: Do you agree with the requirements of Policy IDE1? If not, how would you wish to see it amended?

We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species. Opportunities to incorporate biodiversity gains throughout the development should be taken.

QUESTION 79: Do you agree with the requirements of Policy NOR1? If not, how would you wish to see it amended?

Enhancements to the existing tree belts should be sought for the benefit of biodiversity.

QUESTION 82: Do you agree with the requirements of Policy PEA1? If not, how would you wish to see it amended?

The Trust strongly supports the protection of the traditional orchard and the aims to bring it into long-term sustainable management. This is a priority habitat and as such its protection and enhancement is fundamental to the council's aims in the Core Strategy. We strongly support requirement (v) and recommend that there is a requirement for a long-term ecological monitoring and management plan for the site.

Requirement (vi) should include 'enhancement' as well as retention to ensure net gains to biodiversity. We also recommend that the requirement for a SuDS scheme is included in the policy.

QUESTION 83: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

The Trust strongly supports the exclusion of the traditional orchard from the development boundary. This will help to protect the site in the long term.

QUESTION 84: Do you agree with the preferred site for development at Rye Harbour? If not, which site should be preferred?

The Trust strongly supports the exclusion of sites designated as SSSI. These would clearly not be suitable for development and their allocation would be contrary to the Core Strategy and NPPF.

QUESTION 85: Do you agree with the requirements of Policy RHA1? If not, how would you wish to see it amended?

The site is also adjacent to the SPA and this should be acknowledged in the policy. We recommend that requirement (iv) is extended as follows:
'...development of RH10 does not adversely impact upon the Rye Harbour SSSI and avoids impacts on the SPA'.

QUESTION 86: Do you agree with the proposed development boundary? If not, how would you like to see it amended?

It appears a typo is included in paragraph 15.98. The reference to Donsmead, Station Road should be removed.

We support the proposed development boundary as it should prevent further development encroaching onto sites designated for their biodiversity value.

QUESTION 87: Do you agree with Policy RHA2 regarding the Harbour Road Industrial Estate and the proposed boundary changes? If not, how would you wish to see it amended?

Given the ecological sensitivity of the land surrounding this allocation, we recommend that requirement (iii) is strengthened as follows:
'...a comprehensive landscaping strategy and an ecological monitoring and mitigation plan to improve the overall appearance and the biodiversity value of development.'

QUESTION 88: Do you agree with the preferred sites for development at Westfield? If not, which site(s) should be preferred?

The Sussex Wildlife Trust strongly supports the exclusion of sites containing ancient woodland and/or designated for their biodiversity value. To allocate such sites would be contrary the policies within the Rother Core Strategy.

QUESTION 89: Do you agree with the requirements of Policy WES1? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. Further to this, as identified in the 'Key constraints/opportunities' section, the previous ecological appraisals suggested biodiversity gains. The Trust strongly supports the inclusion of wording to support biodiversity gains but seeks that these are not limited to bird and bat boxes. Instead biodiversity gains should be implemented depending on the findings of the up to date ecological surveys submitted at the time of the application. We remind the council that if they are minded to suggest bird and bat boxes as part of the gains for this site in future, wording should be included to highlight the need to incorporate natural features supporting these artificial homes.

QUESTION 90: Do you agree with the requirements of Policy WES2? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per our general comments at the start of this section. The aerial photograph shows the degraded formal gardens and it would be interesting to see if this allocation could consider how these former gardens might be integrated into the layout of the development site, as it may enable the retention of features of interest.

QUESTION 91: Do you agree with the requirements of Policy WES3? If not, how would you wish to see it amended?

The southern section of the allocations lies within the Hasting Fringes Biodiversity Opportunity Area (BOA). We strongly support the requirement for an ecological assessment. This assessment should inform the design and layout of the development to ensure the site remains permeable to species.

Opportunities to incorporate biodiversity gains throughout the development as per the ecological surveys and aspirations of the BOA should be taken.

QUESTION 92: Do you agree with the requirements of Policy WES4? If not, how would you wish to see it amended?

We note this allocation falls outside the 2006 development boundary. However, we are supportive of measures taken to encourage modes of sustain able transport and to interlink those benefits with biodiversity gains. The text accompanying the allocated site states that there are locally present protected species. Therefore we recommend that (iii) reads:
'ecological improvements are based on up to date ecological surveys and are implemented in accordance with these findings and those of the Hasting Fringes Biodiversity Opportunity Area and Rother Green infrastructure Strategy'.

Question 93 - 103

We support the retention of gaps between settlements. While these gaps are often retained for reasons of coalescence and visual sensitivities, we highlight that the Sussex Wildlife Trust also sees the need to recognise the importance of these green gaps in delivering ecosystem services to the local communities (NPPF section 109).

QUESTION 105: Do you agree with the requirements of Policy GYP1, including the boundary as defined on the Policies Map? If not, how would you wish to see it amended?

We strongly suggest the policy includes wording relating to up to date ecological surveys and boundary features working for the benefit of biodiversity are incorporated as per are general comments at the start of this section.

QUESTION 109: Do you agree with the requirements of Policy (MAR1)? If not, how would you wish to see it amended?

We support the requirement for an ecological survey. We recommend that criterion (i) includes 'for the benefit of biodiversity' and the criterion (iv) requires the use of SuDS.

QUESTION 110: Do you agree with a policy to support the continued allocation for the re-instatement of the railway link from Robertsbridge to Bodiam along its original route?

The Sussex Wildlife Trust support sustainable modes of transport. However, we do not have enough information about this particular scheme to offer an opinion on this policy. It is unclear whether the application has been progressed with the consideration of the existing landowners and the level to which biodiversity interests have been considered.

QUESTION 111: Do you have any comments on this scope or content of the new Local Plan that are not covered by other questions?

We highlight the need for a specific Ancient Woodland Policy as per section 117 of the NPPF.
'Planning permission should be refused for developments resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland unless the need for, and benefits of, the development in that location clearly outweighs the loss.'

We welcome the inclusion of the green infrastructure study as an evidence base for the local plan. We would like to know if this will progress into a clear strategy identifying delivery mechanisms. We suggest that the local plan may benefit from a specific policy on green infrastructure/ecological networks to ensure consistent integration of this infrastructure within development.

Should you have any further questions regarding our consultation response please feel free to contact me.

Yours sincerely,
Laura Brook
Conservation Officer

Landscape

VILLAGES WITH SITE ALLOCATIONS

Yes to all questions - Agree and support all of the village boundary and other policies.

Archaeology

Please note that for most answers in this section a Red, Amber or Green rating has been assigned. In providing these responses, regard has been had to paragraph 169 of the NPPF. We are of the view that in order to satisfy this part of the NPPF, some of the proposed site allocations should be subject to archaeological assessment prior to the Pre-Submission version of the DaSA being published - these particular sites are identified below. For all the proposed allocations there will be a requirement for the subsequent planning applications to satisfy paragraph 128 of the NPPF.

VILLAGES WITH SITE ALLOCATIONS page 219

Peasmarsh

The site will require archaeological assessment to clarify risk, boundary could then be modified to exclude significant archaeological remains.
-AMBER

Ecology

VILLAGES WITH SITE ALLOCATIONS page 219

Peasmarsh

Yes

Objection to proposed site allocation PS24 in Peasamrsh

Apart from why are Rother proposing an extra 50 houses in Peasmarsh when the infustructure in Peasmarsh is so poor; 2 hourly bus service during the day, no doctors surgery, primary school full and where are the jobs? To name but a few problems.

I object to the to the proposed site PS24 because this site was previously rejected and the reasons have not changed. In addition a single large site would be most detrimental to the present character of the village. The site entrance remains too narrow, barely 10 metres wide, one house stands across the whole site at present, the garden behind is the same width before it narrows to under 6 metres. This bottleneck is the access to the 3 acres for the building land behind Pippins, to build 45 houses. How do the planners see this working? How will there be access for service vehicles like dustman, fire engines to flow in and out? How will the building contractors get access to the site? This is the only access to the site. Where will the footpaths be sited? But my main concern / worry is the access to the proposed houses, after they are built, from Main Street. The narrow site entrance from the south, is on a bend in the road and on a hill, from the north the site line in a brow of a hill with no sight of vehicles coming up the hill from that direction. Do ESCC really agree to this as ok? I feel strongly this area is an accident waiting to happen. We know from our village 'speed watch' that cars regularly exceed the speed limit here. This is unacceptable to the to the occupiers either side of Pippins. Plus this site is badly drained which is a major concern for the lower lying houses to the eastern side of the site. They already face flooding from the run off from site ponds and stream and this would be further exuberated by development here. Such damage is considered unacceptable within this proposal.

The other three suggested sites, PS5 and PS6 off Tanhouse Lane and PS7, do not have poor vehicle access and RDC, in an email dated 2014 from Richard Wilson, stating these sites as being better sites!

So why is Pippins being considered now? I can only think it is because the owners have agreed to sell the land and this makes RDC's life easier; a sad day when planners just take an easy option rather than what is best for the village.

Please read this eamil in conjunction with attached document.


Site Allocations questions
Question 81 - Do you agree with the preferred site for development at Peasmarsh? If not, which site should be preferred?
Do not agree - We do not believe that PS24 (the preferred site) is suitable and that three sites PS5 Land north east of Tanhouse or PS6 Land adjacent to Superstore and PS7s Land south of Oaklands Main Street would be more suitable as either a combination of sites (to achieve the desired number of dwellings) or as a single site
Question 82 - Do you agree with the requirements of Policy PEA1? If not, how would you wish to see it amended?
I) Statement - Some 45 dwellings-are provided as shown on the Policies Map, of which 40% are affordable
Amend to read - Some 45 dwellings-are provided as shown on the Policies Map, of which a minimum of 60% are affordable.
Reason for amendment - To provide more affordable housing for those people unable to currently purchase the high priced local housing in Peasmarsh . The stated figure of 40% is insufficient if this is in any way meant to be meaningful goal.
II) Statement - vehicle access is to Main Street to the satisfaction of the Highways Authority
Amend to read - Vehicle access to Main Street to the satisfaction of an independent authority not associated with either RDC or ESCC
Reason for amendment - To guarantee the impartiality of the decision as to the suitability of this access.
III) Statement - additional pedestrian/cycle access:
(a) To the north-east of the site, connecting down the length of the eastern boundary via a green corridor
(b) Southward connecting to the footpath network
Amend to read - (a) To the north-east of the site, connecting down the length of the eastern boundary a permeable pavement as part of the green corridor to facilitate pedestrian access from the north east of the site
Reason for amendment - A green corridor during the winter months and periods of sustained wet weather will become impractical during these periods due to mud, the limited amount of daylight hours and a general lack of street lighting in Peasmarsh
No amendments to (b)
IV) Statement - Provision of a children's play area, which should be subject to passive surveillance from residential frontages
No amendments
V) Statement - Provision of open space to the south of the site, incorporating the traditional orchard within it, with funding arrangements for on-going management to maintain as open space and biodiversity interest
Amend to read - Provision of open space to the south of the site, incorporating the traditional orchard within it, with funding arrangements for on-going management from either central government, ESCC or RDC to maintain as open space and biodiversity interest
Reason for amendment - To ensure that residents of Peasmarsh are protected from having to pay for this ongoing maintenance bill via the parish precept settlement
VI) Statement -Retention of other existing ecological and High Weald AONB character features so far as reasonably practicable, including historic field boundaries, boundary hedgerows, existing trees and existing pond
Amend to read - Retention of other existing ecological and High Weald AONB character features, including historic field boundaries, boundary hedgerows, existing trees and existing pond
Reason for amendment - So far as reasonably practicable is very loose wording and is dependent upon the interpretation of what practicable would mean
VII) Statement - Maintenance and reinforcement existing landscaped boundaries around the site and creation of new ones on exposed western edges
Amend to read - Maintenance and reinforcement existing landscaped boundaries around the site and creation of new ones on exposed western edges by either central government, ESCC or RDC
Reason for amendment - To ensure that residents of Peasmarsh are protected from having to pay for this ongoing maintenance bill via the parish precept settlement
Question 83 - Do you agree with the proposed development boundary? If not, how would you like to see it amended?
15.83. It is proposed to amend the development boundary as set out on Figure 109 below.
15.84. The proposed amendment to the development boundary will reflect the new allocation in the village
Do not agree - We believe that the three sites as specified in the response to question 81 above should be the proposed development boundary and that figure 109 should be amended accordingly to reflect these sites
Preferred site PS24 - Reasons for objection
a) Access to the A268 via Pippins is extremely problematic in terms of driver sight line when exiting the proposed site due to the proximity of the hill to the west between Tanhouse Lane and The Cock Inn as this stretch of the A268 is in a 40mph limit (which is often being exceeded by motorists) and approaching vehicles cannot be seen until they are passing The Cock Inn. To the east side there is a blind bend from The Old Post Office to approximately Crookwell and although this is a 30mph limit motorist quite often exceed it - as can be confirmed by the local Speedwatch group.
b) Entry to the site is by the Highways Authority own admission only achievable in principle and requires presumably the demolition of a perfectly habitable property 'Pippins' to achieve access to the site and even then a priority system will be required at the rear end
c) It is unclear from the proposal as to whether or not there is provision for footpath(s) on this entry / exit road
d) The creation of this access will undoubtedly have a severe impact on the occupiers of the properties that will be either side of this road who will have to endure the comings and goings of vehicles and the like to the 45 dwellings day and night.
e) As this proposal relies very much on the owners of Pippins being prepared to sell their property to any potential developer, which presumably they have said they will, what provision has been made should they change their mind or cannot agree a sale price with the developer?
f) The two options to connect the footpath to the south and west are not specified other that they require third party land so it is not possible to judge what the implications of this may be
g) Though to a lesser extent properties abounding the proposed site will also be greatly impacted by this proposed development
h) Whilst the provision of a residential children's play area is to be applauded there already exists adequate facilities at The Maltings which incorporates a children's play park, a recreation ground and a skate park and the hope would be that the residents of the new site would wish to avail themselves of these facilities and thus integrate themselves into the wider community
i) Preferred site is badly drained. Drainage problems cause the garden of the lowest level property in this vicinity to flood on a regular basis and this will only be exacerbated by this development.


Preferred sites - Reasons for choosing

The Parish Council has in its possession an email from Richard Wilson at RDC, dated 2014, in which he states "that the only feasible sites for development in Peasmarsh are near to Jempsons Supermarket".

PS5
Whilst accepting that the site would have a negative impact on ANOB it would again appear that this site is being rejected simply because of the view but that in all other aspects would seem more preferable to PS24 as it meets much of the criteria and impacts on very few existing properties.
Safer access to the A268 from the already established access road to Jempsons Supermarket.
Access could be easily obtained from the existing roundabout adjacent to Jempsons giving easy access to site.
Much closer to amenities ie Supermarket, Post Office, Pharmacy etc.
PS6
As stated in PS5 this too appears to be a site rejected purely on the grounds above despite being very accessible and fulfilling much of the criteria used to justify PS24 and again this impacts very few properties.
Links onto PS5 with the same benefits of access.
PS7s
Links onto PS6 with the same benefits of access as PS5.
Could be developed at a later stage as opposed to one large development.
Less impact on existing properties.

General observations on Peasmarsh infrastructure
a) Drainage - over the years there have been a number of issues regarding the drainage and in particular the foul water with the Iden treatment works running near to its maximum capacity.
b) With the re-development of The Maltings complex adding ten extra dwellings and the addition of another 45 dwellings this will increase the population of the village by around 120 (2.3 people per household 2011 census) an approximate 10% increase yet there is no provision in the document for any of the following
1) Doctors surgery residents at present have to go to either The Rye Medical Centre of The Northiam Surgery both of which will be under increased pressure by developments within the surrounding villages and may have to start limiting their patients to those within their catchment area
2) Dentist - again there is no provision for this
3) Bus service - This has effectively been cut from an hourly service to a two hourly service and looks set to be reduce even further due to budgetary constraints at ESCC
4) The local primary school is nearing capacity and will almost certainly struggle to accommodate an influx of children particularly as it becomes more successful and is obliged to take children whose parents do not live in the village thus forcing village children to be located further afield.

We acknowledge that there is a need for more affordable housing and this is not a case of 'NIMBY' ism but simply that the proposed site, PS24, is ill conceived and fraught with potential problems. However, notwithstanding the points made regarding infrastructure we would urge you to reconsider the proposed site and give careful consideration to the alternative sites we have suggested.