Hurst Green needs a fly over. I am currently in bed listening to Lorrie's ignoring the speed limit and cannoning down the road. Put them on a proper A road and allow us to live in a nice peaceful village

Please see attached comments on draft Local Plan, including Brede Valley Landscape Assessment and East Sussex Landscape Assessment.

Q1.

Sadly the vision feels unachievable. Rother Officers avoid dialogue or face to face contact with some residents, who as a result have little trust in RDC’s integrity and competence. Disillusion with poor quality planning includes perceptions of cronyism and corruption. How will an infrastructure baseline be established? For example “Sensitive, sustainable and well-designed development that meets local housing and employment needs will be complemented by the timely delivery of supporting infrastructure.” RDC should revisit past developments that fall short of this criteria, where community complaints have been high. In Fairlight Cove we’ve lost amenity for 2 years caused by a poor quality, cramped, steep development of 16 houses. Residents dispute it’s built to the planning consent approved on appeal by the Planning Inspectorate. Storm overflows cover the lane with sewage, before the 16 new houses are even connected. A resident survey describes the gridlock of parked vehicles on our bus route, obstructing junctions and folk struggling to get on/off their driveways. Over decades there appears to have been no imaginative attempts to meet village overflow parking needs. For example removing wide grass verges to create parking spaces. We can’t see strategic joint working by RDC with our Parish Council. Our precept has increased by 40% in the past few years without extensive consultation and Parish Councillors spend our tax on their high running costs, meetings and social projects for retired people that duplicate existing locally funded voluntary sector provision by professional staff. Accountability and evaluation systems are lacking for Parish Councils to maintain infrastructure. Parts of Fairlight are lanes with high numbers of walkers, no pavements or footpaths, very few seats and signage clutter. A baseline study would show village assets in poor repair, with an increase in vehicle movements. Parking and speeding are increasing problems. Results from the 2023 Parish Council Residents Survey are not in the public domain. In relation to ‘Quality of Life’ residents regularly state a priority is public toilets. The decision by RDC to not cover the cost of public toilets at our local beach and in Rye indicates how removed you are from meeting basic expectations and needs of your residents, visitors to our area and local businesses.

Q2.

‘Conserving and enhancing the significant landscape and environmental quality across the district’ It would help if RDC insisted on professional quality Construction Management Plans or contractors signed up to the ‘Considerate Contractor’ Scheme. Also if RDC Enforcement Officers were resourced and supported to penalise construction sites in the same way they penalise residents or local builders, especially for radios, drug use and aggressive behaviours on site. Planting Management Plans and TPO’s are ignored, trees and hedgerows are cut, with no apparent penalties. Residents are encouraged to provide free labour to report alleged breaches of planning consent, but then Developers break the rules with impunity. The perception is that Rother Officers are too close to Developers, whilst being unwilling to meet with residents. There appears to be no monitoring of what the CIL funds are spent on in parishes in relation to the exisiting Local Plan and no minimum standard of “community consultation”.

Q3.

‘By supporting strong, safe and sustainable communities’ In Fairlight Cove there is a minimal bus service, which unfortunately can be disrupted at very short notice by road closures. Leaving school children or people without mobile phones disorientated and abandoned. Plus there is poor access to travel around our village for people with disabilities. There appears to be no baseline of how many village roads are difficult to use for disabled people, due to issues such as rough surfaces/moonscapes, pavement parking, cracked pavements or speeding traffic. New charges for car parks across RDC and HBC means people now drive into Fairlight Cove to park for free and some camp overnight outside residents homes. HBC is commonly perceived online as having corrupt working practices in relation to planning and development sites.

Q5.

SO 9 feels very important, but unless there are new initiatives in villages, there appears to be no resources to make this happen. It is difficult to get a face to face appointment at Hill Surgery, Hastings, few people can get through to reception. For people on low incomes, without a computer or mobile phone it is especially hard.

Q.27

There seems to be an opt out clause on Density. There seems little point in having policies, if you then create ways for property developers not to meet them.

Q.33

LWL3 Facilities at bus stops and iii Coastal Access This would be very important if it could be implemented.

LWL5

We welcome these policies in terms of height and steep sites, for example if a village is predominantly small low dwellings, very tall buildings stand out. For example at the entrance to Fairlight Cove and in the “transition” of the new Market Garden Site to the south.

LWL6

We welcome these policies in terms of height and steep sites, for example if a village is predominantly small low dwellings, very tall buildings stand out. For example at the entrance to Fairlight Cove and in the “transition” of the new Market Garden Site to the south.

Q45.

Streets For All. We welcome the shared streets policy especially “street furniture, good signage and way finding that is accessible to all to encourage walking and prioritise vulnerable users.” It would be beneficial to identify who currently lives in a ‘street’ or a ‘road’ and whether 4.62 SUDS and 4.64 could be implemented across the District. If RDC had clear design standards and guidelines, this would help Parish Councils who may not have access to professional expertise in planning. Community pride and cohesion is undermined by dirty and deteriorating infrastructure, Pett Level Road, Pett Level Toilets, Highways Pavement repairs, Southern Water sewage etc

Q.48

RDC needs to work with Parish Councils to create Parking Strategies for villages where parked vehicles now dominate the public realm, block footways, crossing points and sight lines.

Paragraph 5.16

Quiet Lanes and Slow Ways should be introduced on the 1066 walk and popular coastal footpaths as a priority.
This is a key issue for Fairlight enabling all generations to stay in rural communities for their lifetime and a source of frustration that new homes have not addressed the housing needs of local residents.

Q.54

The notion of “Hastings Fringes” feels unclear and ‘sensitive growth’ lacks a number, clarification would help.

Q.59

We object to the notion that a minimum of 35 dwellings in Fairlight is “sensitive” growth, we assume the site is East Field. This has been contested so many times over the years and the Field continues to flood, the sewage continues to overflow on Lower Waites Lane and Stream Lane. The increased traffic puts enormous pressure on village lanes which are in a poor state of repair. Pett Level Road is unpassable during the evening time due to the size of the pot holes. Access to a Post Office, Doctors Surgery and Dentists is limited.

Q.72

“Including the undeveloped coast, also has high intrinsic amenity value and is an important resource for nature conservation, leisure and tourism.” This would be more convincing if Pett Level Road were usable as a road, the moonscapes by the road side could be used for parking and the public toilets were open throughout the year.

Q.82

DEV3 The development boundary concept sounds confusing. If Fairlight Cove has a development boundary in the Local Plan surely the boundary of Waites lane is facing the ‘countryside’. Therefore an allocation of East Field for 35 houses would not meet the policy?

Q.90

DEV6 The Strategic Green Gap between Fairlight and Hastings is warmly welcomed, as are all the Gaps in the Plan. There are regular incidents where large vehicles e.g two buses/lorries etc get wedged along the narrow lanes travelling east along Fairlight Road which is claustrophobic and parked vehicles dominate. The areas open character feels essential to demarcate the start of the countryside.

Q.101

HWB5 Green and Blue Infrastructure
There is no minimum length for new development to be built away from a water course. In the case of the Market Garden Site in Fairlight, three new builds are on the banks of the stream and the earth has subsided as a result.

Q.102

A minimum precise measurement length should be insisted upon for all new developments near a water course. There is also no clear mention in Construction Management Plans for Site workers not to litter or pollute a water course. Also to store construction materials such as water proof insulation, glass etc a few metres from the edge so as they don’t fall into the water course.

Q.123

HOU5 Rural Exception Sites
This feels like another ‘get out’ clause. There is no clarity as to what RDC mean by “meaningful community engagement” If RDC has any examples of how this had worked in practice that would be helpful. Otherwise it could be removed.

Q.129

HOU8 Access to Standards Paragraph 8.72 This feels like another ‘get out’ clause

Paragraph 8.137

ESCC parking guidance is an under estimate, for the number of people who actually use a garage. The number of cars owned per household in rural areas and the fact that most dwellings have visitors and delivery vehicles. The car parking spaces are mean on new build developments, causing parked vehicles to over flow onto rural lanes and bus routes.

Q.144

”… private rear garden spaces of at least 10 metres in length will normally be required, other than in exceptional circumstances where this cannot be achieved in an otherwise acceptable development” We strongly object to the wording and opt outs within this Policy. At the Market Garden Site in Fairlight residents allege the 10 metre gardens have not been created. Allowing flexibility on the 10 metre rule makes a mockery of it being a Policy. This allows for Developers to erect cramped buildings on irregular and sloped sites. This is very disappointing. Similarly the policy can be avoided if “future occupiers of the dwellings will have a lesser requirement for amenity space” How can this be proven if properties are sold on the open market, another loophole for allowing dwellings with low amenity. It leaves little room for outdoor washing lines which have an environmental impact if clothes is dried indoors. Also the capacity for play equipment, to plant veg/fruit trees, store bicycles/canoes etc. We object to 8.136.

Q.146

The Policy is inappropriately flexible. Getting away with squashing the tiniest housing units onto a plot seems to be the game for a few Developers and RDC are encouraging it with this type of policy.

Q.166

Like most of our responses our comments relate to balancing new developments with maintaining infrastructure or improving strategic working with ESCC or Parish Councils. If the majority of visits are day trips then the issue of parking, overflow parking and public toilets remain very high on the list of problems to be addressed, which currently fail to meet customer expectations. The poor state of ESCC roads is a major factor in putting off visitors.

Q.180

LAN1 This is very important, especially to the undeveloped coast.

Page 356 (ix) The failure of RDC to stop Developers clearing trees and hedges is depressing.

Q.191

ENV 4 Fairlight Cove Coastal Change Management Area is important to support the work of the Fairlight Preservation Trust.

These seem to be appropriate and cover all the key areas.

Please see attached representation, existing and proposed sites plans.

They are clearly laudable priorities.

Perhaps if a draft plan could be published that reflects these, we could have something to support.

Please see attached:

- Draft Local Plan Representations
- Site Location Plan
- Existing Site Layout Plan
- Call for Sites Illustrative Layout Plan

SWT supports the twin priorities. We strongly support the principle of the biodiversity crisis being central to all planning decisions, however we feel that the explanation of ‘Green to the Core’ needs to be more explicit. We suggest that the second bullet point should be amended as follows:

‘playing a key role in the UK’s nature recovery and carbon sequestration through protecting, enhancing and expanding our landscape and environmental assets and prioritising nature based solutions.’

Overall great - I appreciate the fact that these inter-linked challenges are at the heart of the strategy.

Greener houses is the way to go but it’s not the only factor. Reducing the green areas and felling trees to build them rather takes away from the net carbon reduction. If for example some of the large sites were made to give a third of it over to woodland planting and management it could work, in other words, small developments only. Every house that is built in a village is going to mean at least one, and more probably two or three cars that will be making daily journeys, not to forget deliveries and the impact of construction traffic. If the plans go ahead for Catsfield there will be the start of a move toward a more urban style settlement all of which has to travel to Battle at the very least and probably much further for work, provisions, schools etc etc.
Any green development should have the possibility of travel to amenities and work by foot or cycle. This is not possible in Catsfield and never will be. Anybody who looks at a map and thinks it is a reasonable thing to do needs to come and try it.
Catsfield developments CAT0001 and CAT0016 do not fit in with the overall priority.

The principles of Live Well Locally as set as the Overall Priority 2 are supported by our client and through their proposals. The priority to ensure that rural communities are able to live in connected and compact neighbourhoods is one of the key elements for our client’s proposed development. The two sites mentioned are adjacent to the development boundary set out in the Ticehurst Neighbourhood Plan (Policy H1) and are roughly 1km from the Centre of Ticehurst meaning it would take 13 minutes to walk or 4 minutes to cycle into Ticehurst Village Centre.
Furthermore, there are bus stops on Lower Platts (180m away) which would connect residents onto the many bus services between Hawkhurst, Hastings and Flimwell.
The proximity of the sites to the village ensures that there is sustainable and inclusive access to the facilities of the village and will help inspire a sense of belonging whilst also reducing the high reliance on the use of private cars by its sustainable location and would help promote active travel.

The village of Ticehurst is also identified as a Moderately Sustainable settlement as set out in the Settlement Study Report. This shows that the settlement can accommodate new homes due to its high sustainability score. It will be able to accommodate new residents and provide many essential services to future residents.
Our clients’ sites both benefit from a local primary school in Steellands Rise in the immediate vicinity, the Ticehurst and Flimwell Church of England Primary School.

Excellent priorities. Thank you.

The consultation document asks respondents to comment on the extent to which they agree with the overall vision and objectives of the Local Plan.

According to the Vision, by 2040, "bold solutions will have successfully addressed the climate and biodiversity emergencies and the housing crisis.” These are translated into two Overall Priorities: "Green to the Core" which means considering the impact of all planning decisions on the climate emergency, the biodiversity crisis and the High Weald National Landscape, and "Live Well Locally." The latter means considering the goal of creating healthy, sustainable communities, supporting residents in terms of access to jobs, services and facilities, connected and compact neighbourhoods and new places that foster a sense of belonging, identity and shared experience. While we agree with the overall thrust of these priorities, neither adequately go to the heart of the urgent need for housing, including specifically addressing the current housing crisis.

The housing crisis is acute in Rother and getting a Local Plan in place is the first step to ensure proper, planned delivery of housing in a consistent and sustainable manner to ensure the Council can realise its two overall priorities. However, the Local Plan needs to honestly address the scale of the housing shortfall and the importance of meeting the local housing need in full. Accordingly, we recommend that “Live Well Locally” is expanded to specifically confirm that it will be the aim of the Council to address the housing crisis, meeting local housing need in full and maximising housing delivery.

Please see attached comments from Burwash Parish Council.

Q2. Council feels that both are key to our Community with equal priority.

Q24. Clarification of "all qualifying development" is sought.
Council would like to prevent pre-emptive works at sites prior to submission of planning applications.

Q28. Agree the principle but very hard to visualise dwellings per hectare. Particularly when looking at rural areas.
Examples in our location would be helpful ie number of properties in Coronation Gardens per hectare, for example.


Q30. Whilst we feel this is a positive ambition, this may be impracticle for a town such as Battle.

Q33. In agreement with proposals, but clear access must be available. Blackfriars access to Battle Railway Station is a point in case of outside site access.

Q34. Council should make developers responsible for access outside site compulsory.

Q35. Applaud this objective but would once again highlight the Blackfriars development not having easy access to the Railway Station which would make walking outside of this 400m proposal.

Q39. This is an important policy and Council would like this enforced. However, it is disappointing that the Blackfriars development has not been approved in accordance with existing Battle Civil Parish Neighbourhood Plan policies.

Q46. Council feels that consideration should be to all disabilities, not only dementia sufferers; such as less ambulant people and those with hearing difficulties etc.
In relation to play areas, these should be sited in an appropriate safe, central location.

Q64. The topography of the central area of Battle town does not lend itself to significant further dwellings to be developed within the development boundary.
There may be very small opportunties for developments outside the development boundary but within the 800m constraint.
Broadly speaking, the number of dwellings suggested seems to be most unachievable.
During the development of the Battle Civil Parish Neighbourhood Plan, despite calls for employment opportunity developments, there was only one response.

Q74. These policies should be strictly adherred to, to protect the environment.

Q75. Subsequent to this Reg 18 document, Council would like to emphasise that the "Fir Tree Cottage" site at Netherfield only has temporary permission for three years and must be returned to agricultural use.

Q76. We do not agree that Battle is placed in the "Greater opportunities for growth" column in figure 35. In main part due to the topography of the Civil Parish and, at best, should be placed in the "Medium growth opportunities".
We are pleased to see that Mountfield and Whatlington in our SDO have been recognised in the column "Limited growth opportunities".

Q104. We welcome this policy.

Q116. For planning applications where affordable housing is approved, following applications to change the conditions will be greatly deplicated.

Q119. Council does not agree with this policy. There should be a mix of housing - 'pepperpotting'.

Q121. We do not wish to see this, as above.

Q183. LAN3 paragrpah 3 should have roof lights added as an example of discouraged glazing.
Planning applicants should be encouraged to use electrochromic glass.

See attached document

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Rurban Estates Limited.

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Catesby Strategic Land Ltd and Rurban Estates Limited.

Full submission attached.

See attached.

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Rurban Estates Limited.

Please see attached document for the full submission from Westfield Parish Council.

We welcome the Overall Priority 1 - Green to the Core and the Proposed Policy HWB7: Combe Valley Countryside Park. However it is unfortunate that the Park is not referenced by name in the Proposed Policy DEV6: Strategic Green Gaps, where it is referred to as Bexhill and Hastings/St Leonards Strategic Green Gap. The park is clearly important as part of the policy relating to health and well being, but it also needs to be emphasised that it is land which is protected from development as part of the strategic green gap between Bexhill and St Leonards

Please see attached representation from Bell Cornwell on behalf of the Trustees of Steellands Farm, in relation to HELAA sites TIC0043 and TIC0044 which contains an indicative layout plan.