The term 'Net Zero Carbon Ready' fails to make new developments carbon zero. Making them simply 'Ready' means a development will rely entirely on the decarbonisation of the grid as opposed to being carbon zero in themselves.

The word 'ready' should be removed from this vision.

I do not see how this can be achieved in this time frame. Building houses impacts every thing and the plan to build so many houses negates the ability to have an "attractive, desirable and affordable place to live" let alone the needs of the local community. No BOLD solution will help the climate with more houses, already the most carbon comes from houses and transport so how are more houses built going to help achieve this? Let alone the carbon produced building houses. Will these housing estates have hedges etc etc as we cannot off-set with trees in ANOB.

Sustainable development includes protecting plants and animals from the adverse effects of artificial light at night.
Quality of life also includes the ability to enjoy the intrinsically dark skies of much of Rother DC.
These points should be reflected in the Vision, Overall Priorities and Objectives.

Pleased to see that Rother intent to work with Neighbourhood Plan areas and Parish Councils.
Do the flood risk areas only include current areas or expected new flood risk due to climate change and rising sea levels?
It would be great if renewable energy and energy efficiency in developments was mentioned specifically, rather than under the rather vague "net zero carbon ready" banner.

It's good to know the RDC has a vision but it must know that it can offer no 'bold solutions' that will have any effect on the 'climate emergency.' Regarding health and well being, it is hard to see how this will be enhanced by building houses on areas of outstanding natural beauty. There is a lack of GPs in our areas as elsewhere, which will be exacerbated by an increased population. Sadly, there is almost no chance of this situation improving. In 1982 when Martins Oak Surgery advertised for a new partner, there were 88 applicants. When the senior partner retired in 2021 there were no applicants to replace him at all.

Battle: The bottom line in the proposal to build more houses is that the current infrastructure cannot cope with more people and cars in Battle. The high street and North Trade Road are often congested, and the state of the roads is laughable. Access to general practice health care and dentistry is on it's knees nationally, let alone in Battle, where it is definitely struggling.

Please see attached comments.

Please refer to attachment

Please see attached submission.

Please see attached submission.

Please see attached submission.

Draft Rother Local Plan 2020-2040 – Public Consultation

Hastings Borough Council welcomes the opportunity to formally comment on the Rother District Council Regulation 18 draft Local Plan. Hastings Council is broadly supportive of the Rother Local Plan and its vision, aims and objectives. Specific comments are made here on those areas of the Draft Plan where there are strategic cross-boundary issues. We wish to continue to work with the Rother District Council on these and other matters in the Plan, as work on the Plan progresses as part of meeting Duty to Cooperate requirements.

- Joint Statement:

The Council is supportive of the joint statement and is committed to continuing to work closely together on strategic matters affecting both of our councils’ Plans.

- Housing requirement and Development Strategy:

The joint Housing and Economic Development Needs Assessment (HEDNA) identifies a need for 14,740 net new homes over Rother’s Plan period. The draft Plan outlines the potential to meet this need through the delivery of between 5,158 and 7,287 new homes. This equates to meeting approximately 50% of the district’s identified housing need, and places a potential pressure on Hastings Council, as a neighbouring authority within the same housing market area, to assist Rother in meeting their full housing need. Rother Council, has, after the start of their Regulation 18 consultation, now formally requested this council’s assistance in meeting their unmet housing need. As established through joint working with Rother planning officers, we will regrettably be unable to assist in meeting any of Rother’s potential unmet need owing to the challenges we face in meeting our own housing targets.

We note that at this draft Regulation 18 stage of the plan making process, (with an additional final public consultation to follow) this draft Plan does not provide any specific allocations but presents sites that have been assessed as part of the Housing Economic Land Availability Assessment (HELAA) process. The draft Plan’s preferred development strategy policy includes development around the Hastings Fringe (as referenced in option SD05 set out in the Development Strategy Background Paper) and identifies small-scale sensitive development around the fringe.

From the HELAA document it can be identified that there are only three sites identified in the Hastings Fringe that would be considered as potentially suitable sites that have not been rejected as part of the HELAA process. Hastings will be keen to discuss these potential sites on the Hastings Fringe and surrounding area as the Rother Plan progresses and further details of specific site allocations come forward. However, in principle, the Council is broadly supportive of the residential development within the Hastings Fringe, subject to the details of specific sites and their constraints.

Furthermore, the council is supportive of the assessment within the HELAA of land at the Breadsell (HAF0007), which indicates that the site is not currently suitable for allocation.

- Strategic Gap:

The Council is broadly supportive of the strategic gaps between Bexhill, Crowhurst and Battle in relation to Hastings, given the importance of the Combe Valley Countryside Park, environmental constraints and the lack of suitability in sustainability terms of these locations to accommodate significant levels of development. The supporting land supply evidence documents should clearly set out how these broad locations have been assessed and discounted for significant development.

- Employment Land:

The draft Plan indicates that it will be possible to meet overall employment needs in terms of having a sufficient supply of land suitable for employment-related development. However, there is an identified undersupply of land suitable for meeting storage and distribution needs. Given the undersupply of land suitable for storage & distribution within Hastings Borough, this could result in a significant under-delivery across the district and borough functional market area combined. The Council would therefore welcome more discussion on meeting employment needs across the two authorities’ areas.

- Flood Risk:

We recognise that flood risks may cross our respective district and borough boundaries. Some watercourses have interactions with, or originate from, watercourses beyond the Hastings borough. In some cases, surface water can enter these watercourses over quite a wide area (the Combe Haven is an example of this). The Council would welcome at this stage in the development of Rother’s Plan, the opportunity to explore whether the Rother Strategic Flood Risk Assessment (SFRA) is able to consider how surface water discharge may impact on flood risk in Hastings, either through runoff or interaction with watercourses.

- Whole Plan Viability:

As already stated, the Council is generally supportive of the policies that have been proposed in the Draft Local plan and their alignment with Draft Plan objectives. However, the Council notes that there is no whole plan viability assessment underpinning the policy proposals at this time. The Council is therefore keen to understand the viability of Regulation 18 policy proposals set out, as the plan progresses.

We also look forward to the continuing dialogue between the two councils as part of the duty to cooperate process.

The original reponse has been saved as an attachment, titled: 'Regulation 18 Representation - Hastings Borough Council'

Q2 I agree in principle that houses should be built in places with services but existing infrastructure needs to be taken into account, eg in Robertsbridge, key roads are too narrow to accommodate more traffic even if more people walk or cycle.
Q6 Agree Rother should require more than the minimum energy efficiency standards.
Q11 Good
Q13 Rainwater harvesting should always be required- I cannot see how you met the 110l pp pd target without it.
Q19 Encourage solar arrays above supermarket car parks before any greenfield sites.
Q33 "Short trips of up to 3 miles can be easily made on foot or bicycle...." Rather depends on your fitness and the gradients, not easily for many people.
Q44 This should also include designing to keep houses cool.
Q120 I would like a more robust attitude towards developers who say it is not viable to include houses for rent. Instead of just caving in , the choice should either be comply with the rules or offer the site to someone who will.
Q127 If anything, increase size standards.

Draft HELAA Part1: Report: 1 Introduction
para 1.2 &1.3: Comment:

The HELAA is for the Rother District Local Plan (RDLP) 2020 - 2040, yet the Draft Version HELAA is only now out for consultation April - July 2024.

Q1 - The HELAA informs the Rother District Local Plan (RDLP), why isn't consultation with the public undertaken prior to the RDLP?

Q2 - Will the RDLP be published as 2025 - 2040 to incorporate the outcome of the HELAA?

Q3 - During the period of 2020 - 2025 there may have been sites approved that were not included in the previous Development and Site Allocations Local Plan (DaSALP) adopted in 2019, which had been subject to public consultation and accepted by a Planning Inspector. There has been a DaSALP since 2019 why was it not being used to steer developers to the sites identified by Rother District Council as suitable for development.
2 National Planning Policy position para 2.1 & 2.2: Comment:
'The overall aim should be to meet as much of RDC's identified housing need a possible' - which is for the residents of the area of Rother. The majority of which live in Bexhill where 45% of residents are over 65 years old, the 2nd highest in England.

Q1 - What factors have more than doubled the requirement of dwellings per annum in Rother, from 335 to 733. Especially when a Planning Inspectors Report in 2019 confirmed that the identified number of sites more than met the then identifed requirement?

Q2 - Will Rother District Council and in particular Bexhill be developed to provide housing for other area's outside of Rother?

Chapter 1 Bexhill North site id BEX 0112: Comments:
1 - In November 2019 the Development and Site Allocation Plan was adopted. BEX0112 is not identified in this plan as a site for potential development. This plan will be extant until the draft HELAA is adopted.
2 - In December 2023 the Developer submitted a planning application for approval which was refusedby the Planning Committee.
2a -The main reason given for refusal was that it was an inappropriate location for a housing development due to potential economic impact on the Brickworks and the various pollution generated during the 24x7 manufacturing process on the new residences.
2b - There are also drainage/flooding issues not identified during the scheme design both on and off site (adjacent and down stream). The photographic evidence of down stream flooding is a concern for the Pevensey and Cuckmere Water Management Board, as the situation is likely to be further compounded by developments currently in progress or planned together by land drainage schemes.
3 - In April 2024 BEX0112 is included in the HELAA as a site that is potentially available
4 - In May 2024 the Developer appealed the decision and an appeal is being held mid August 2024.

5 - In conclusion the site BEX0112 as identified, should not be included in the HELAA as it is the subject of an appeal by the developer.
The outcome of which will either be:
5a - approved and not now a site to be included in the HELAA as available for development.
5b - refused and as determined by the Planning Committee as not a site suitable for development, for the reasons given in 2 above.

Please see attached submitted document for full comments.

Please see attached submitted document for full comments.

Please see attached submitted document for full comments.

Please see attached submitted document for full comments.

Please see full the Environment Agency's representations, please see attached submission document.