See attached document for the representation.

See attachment for the full representation.

The full submission comprises of:
- DHA Response to RDC Reg 18 Draft Local Plan; and
- Site Location Plan

Please see attachment

I am supportive of the principles of Green to the Core and Live Well Locally.

I also see the value in ranking areas of Rother according to their sustainability as a framework for decision making.

However, neither the principles or the sustainability ranking are appropriately applied in the HELAA and thus the plan fails to deliver on its vision.

Specifically, Iden is rated as a low sustainability area and yet the HELAA proposes two additional sites for development creating a total of 25 properties in the village. It is incongruous to suggest that an area that is designated low sustainability could support this level of development. If an area is low sustainability then it is not fit for development unless and until the metrics for sustainability improve.

To suggest that additional land at the rear of Conkers IDE0011 be brought forward despite previously being ruled out because of the position of listed building is ridiculous. Nothing has changed regarding the situation of the listed properties so why is land previously rejected now being considered as an option. The only reason surely is pressure from developers.

A further major shortcoming with this plan is that it does not put forward a strategy / plan for sites to be brought forward for BNG and it is therefore not clear how Rother will meet its commitment to 20% BNG. The target for 20% is good however it should be accompanied by a plan to meet that commitment within the boundary of Rother. Given the fact that much of Rother sits is in an AONB, it should be possible for Rother to make significant process in meeting its own target of 20%.

It is also the case that with no plan for sites for BNG, there are no incentives for land owners to bring forward sites and thus potentially excellent sites for BNG will be lost to development. Rother simply risks undermining its own commitments.

In summary, the vision for the plan is good from a theoretical perspective but it will fail in practical application.

Please accept this response to your consultation on the draft local plan for Rother 2020-2040 as your online consultation webpage is difficult to navigate and I became totally lost in the bureaucratic jargon and only managed to reach page 260 before burn-out.

The Draft itself is difficult to decipher what is actually being said, requires much cross referencing with other lengthy, confusing documents and I have had to deal with this draft in a ‘bite-size’ manageable way so may well miss important points, which I hope others will pick up on.

In short, the summary of many hours of reading:
Housing should be confined to brown/grey field sites, in urban surroundings that can cope with the demands of contemporary living, before greenfield sites (especially the HWNL) are even considered.
The Local Plan does not set any limits on anything so cannot possibly have any value as a plan for sustainable development. Development with no limits is unsustainable.
Please provide a map of the development boundary for Catsfield. (For example page 224, DaSA adopted 2019). Maps like this provide clarity for the lay-person rather than struggling through huge documents such as the Draft Local Plan, the HELAA reports, HEDNA etc. but unable to locate any meaningful maps.


RESPONSE TO QUESTIONS:

Q2. What are your views on proposed twin Overall Priorities to be ‘Green to the Core’ and ‘Live Well Locally’?

I have to disagree that RDCs vision is achievable. On the face of it the vision appears to indicate a respect for the environment and the rural communities within, but simply introducing the word ‘green’ does not equal sustainability and, likewise, the word ‘well’ is simply subjective. Therefore, rather than slogans which are open to interpretation or challenge by developers with their eye on today’s profit not tomorrow’s generations, perhaps something a little less open to subjective interpretation would be better. Ie. Today’s priority is tomorrow’s environment. It is clear that we need to protect our environment, both natural and built, because we won’t get a second chance tomorrow. The High Weald National Landscape must be protected as this will be our legacy to following generations – this is sustainability. A climate emergency and protecting our National Landscape is in absolute contrast to the aims of profit-driven developers and speculators, so the question is, how will RDC make developers/speculators adhere to these twin priorities and share their vision?
Regarding Catsfield where I live: The proposed number and design of dwellings on CAT0001 and CAT0016 sites in the HELAA report is really too large for the rural character of the village to subsume into the settlement and should be decreased. Large housing estates will urbanise the rural character - already seen in Ninfield in Wealden district. Therefore, such large housing estates are neither ‘green to the core’ nor beneficial to residents.
Why has Catsfield been singled out to provide 60 new dwellings when other villages have a nil target? How is this figure determined? Is the development boundary for Catsfield being altered without resident’s knowledge?
Q3. What are your views on the key issues (listed at paragraph 2.13) that have been identified and is there anything significant missing?

Simply carving up the country-side will not make houses affordable. Brown/grey field sites must be used before green spaces.
For instance, BEX008 is earmarked for industrial use. Why isn’t the site earmarked for residential buildings if there is a national housing crisis? The infrastructure is already in place.
The site MOU0012 is a vacant industrial site - why is the landowner not incentivised to free up this site? Is he holding out for residential planning?
I understand RDC has a partnership with Hastings. Have they audited empty brownfield sites and properties together, such as the old Post Office, that could be refurbished for residential dwellings?
What is significantly missing is a clear brown/greyfield register for the area if RDC is to conserve its special landscapes such a the HHWNL. Such a register should be in the public domain.

Q22. What are your views on the Council’s proposed policy for Biodiversity Net Gain?

Conserving special landscapes like the HW National Landscape will not be achieved by building more houses over it. By definition house building cannot leave the natural environment in a measurably better state than it was beforehand. BNG can only be achieved on brown/greyfield sites. Brownfield/grey sites should be used first and RDC should make this clear in the Local Plan. Please provide the brownfield maps to the public.

Q25. What are your views on the Council’s proposed policy for the High Weald National Landscape? Q26. Are there any alternatives or additional points the Council should be considering.

Hopefully, these policies will protect the HWNL. However, for the policy to be sustainable there must be clear limits and boundaries and there is not! Therefore, the policy has little value without limits.

Q27. What are your views on the Council’s proposed policy on compact development?

I am unsure what ‘compact development’ means in practice. I assume it means making the best use of infrastructure by building in those areas, predominantly urban, where infrastructure is already in place, which makes sense. In rural villages, like Catsfield, infrastructure is poor. Public transport is non-existent in Catsfield and residents rely on private vehicles to get to work, to shop etc. usually over poorly maintained roads and lanes. No mobile signal is available in the village and no fibre WiFi is available. Drains overflow, water pressure is low or nonexistent and the village regularly suffers from power cuts. This is all down to poor, unmaintained infrastructure but I made the choice not to live in an urban environment with its good infrastructure but enjoy our wonderful countryside of Sussex.
Again, housing should be confined to brown/grey field sites, in urban surroundings that can cope with the demands of contemporary living and if that is what ‘compact development’ means then I support that.

Q28. What are your views on the area types and densities proposed as a key driver to Live Well Locally?

Please advise where the current map of the development boundary around Catsfield can be found? 25-45 dwellings per hectare makes little sense to ordinary residents - please clarify before I can comment.

Q51. What are your views on the Council’s preferred spatial development options? Q52. Do you have any comments on the merits of the alternative Spatial Development Options, that do not form part of the preferred development options – as explained in the background paper? Q53. Are there any other development options that the Council should consider as part of its Local Plan?

These concepts are confusing to the ordinary resident and need to be explained in clear English. I cannot comment on something that is so confusing.

Q62. What are your views on the vision for Battle and surrounding settlements?

RDC’s target of 60 houses for the small village of Catsfield does not correspond with Rother’s vision quoted from Page 140 - 'Sensitive small-scale development will be delivered in villages surrounding Battle, at densities consistent with the surrounding area, where it is sustainable and does not negatively impact the setting of the High Weald NL.’
Needs a total rethink regarding the number of dwellings. However, Page 145 - para 5.60/61 introduces the idea that the target of 60 houses for Catsfield is purely hypothetical!

Q77. Do you agree with the principal identified by the Council of achieving a stepped housing delivery with greater levels of delivery planned for later in the plan period?
How will RDC incentivise developers to adhere to this principal? Without strict limits this principal is unachievable! Page 177 identifies a problem with land-banking by developers - 'there have been significant delays in the build out of sites.’ This practise needs to be penalised as it affects the price mechanism of houses thus pushing up prices. How is RDC tackling the issue of land-banking?

Q82. What are your views on the Council’s approach to development boundaries?
Page 186, para 5.119 - 'This Local Plan will review each settlement’s boundary, especially in relation to potential allocation sites.’ How can residents possibly comment on something they have not seen? Please produce the Development Boundary map for Catsfield so I can make an informed comment.

Q103. Do you feel that this policy is sufficient to protect open space?
No. The policies have no limits so developers will perpetually challenge them - mission creep.

Q104. What are your views on the Council's proposed policy on public rights of way?
PRoWs are a historic right and should remain. Not diverted nor ignored nor moved surreptitiously (which has been seen in Catsfield). New PRoW are always welcome!

Please see attached submitted document for full comments.

See attached representation which responds to:
- Certain questions within the Local Plan; and
- HELAA site Land at Grove Farm (Phase 2), Robertsbridge. This includes three appendices within the attached document.

Thank you for forwarding this document: below are our comments on policies - together with a supporting rationale.

2.13
Q2, Q3
Agree the principles embodied in 2.13.

 A ’green to the core’ approach should deliver better ‘living spaces’ for children and future generations.
 Compact and less ‘car dependent’ developments should flow from this with a strong emphasis on exploring and expanding ‘active travel’ opportunities and integrated public transport measures - bus/rail.
 The greatest efficiencies will fow from integration of ‘transport’ and ‘land use’ policies that will secure benefits for public health (both mental and physical), environment, social equity, economy - while addressing the twin crises facing biodiversity and climate change. Perhaps the greatest benefits would accrue from ‘traffic reduction’.
 We welcome the very sensible approach of having a joint statement from Hastings BC and Rother DC (the ‘wrap round’ authority). The future ‘district-wide’ and ‘neighbourhood’ infrastructure should include and prioritise sustainable/healthy modes of transport with incentives to use them and with an objective to reduce numbers of vehicles. Successful delivery also requires close working with the Transport and Health authority - ESCC.
 Good publicity to apprise residents, visitors and tourists of non-car modes available to access attractions should be standard - it currently is hugely variable from the useless through mediocre to excellent: it should be standard practice that sustainable transport opportunities are featured in well designd and attractive publicity material.


Q4 Q5
Agree principles. Opportunities that arise from reducing traffic (numbers of vehilcles) would include alternative use of land for a multitude of purposes including housing/nature /acquifer replenishment/childrens’ play/economic activity.

Q6/7/8
Given higher standards are ‘coming down the track’ and that we have a new national administration we might hope for re-energising/accelerating more ambitious energy saving solutions so RDC and all of us might well be prepared (and wish for ) a more nimble approach to delivery of ‘best available’ practice.

We note that although a building or larger housing development may be high performing, if it remains ‘car dependent’ it can hardly be described as sustainable.

Q9/10

Support ambitions for ‘retro-fit’ standards. Reduced car use/increased sustainable mode take-up would free land in existing settlements if provision is made for pedestrian/cycle/bus/train facilities.




Q17/18/19

Support expansion of solar/wind generation subject to landscape/heritage considerations. Rooftop solar is perhaps less obtrusive.

Q20/21

Welcome the focus on ‘nature recovery’. 3.39 recognises that securing ‘designated sites’ is insufficient as a means to securing recovery: the wider countryside (and well managed urban areas too) are crucial if populations/species are to thrive. We note that some areas with notional protection (for example semi-natural ancient woodland of which the HWAONB/HWNL has much) is nibbled away at so needs greater protection and monitoring. The entire east Rother catchment with its many streams also needs protection and monitoring.

Q22/23/24

Yes, go above minimum; developers’ intent to create compensatory gains against damage to existing habitat has to be independently assessed by a third party and monitored over time. Noise and light impact should be taken into account.

Q25/26

I have an interest in the HWNL as I am the owner of 6.02 acres of semi-natural ancient woodland (Fleetwood) and grew up in Etchingham between the Limden and east Rother. It was a wonderfulplace in which to spend my childhood. I accumulated quite a bit of knowledge - flora, fauna, geology, secret places and much of this was on my daily walk to school and back. Much of this environmental capital is intact but the lanes are no longer tranquil or safe places to be and the growth of traffic now limits childrens’ opportunties to learn and therefore love what’s there. Lanes have chewed up verges and ruts - restricting refuge - and taking away childrens freedoms. Add to this the sheer power and size of vehicles and the knowledge that mobile phone use while driving is endemic, the HWNL has suffered and quality of life diminished. Noise is often present with driving styles on two or four wheels tailored to maximise it: the noise footprint is up to two miles in radius. The HWNL is still beautiful but tarnished. It’s not OK. The Plan might usefully attempt to address these issues via its officers and elected members.

In the past, the High Weald Heroes inititiative to apprise its children of the elements that make it special seemed to be a good scheme and might now be expanded to include partnership schools in urban areas to spread the understanding and appreciation of such elements more widely so as to recruit more guardians of the future. Education initiatives could be included in the Plan. Health benefits would accrue, particularly for mental health.

In terms of offering safe walking/cycling family holidays, the HWNL doesn’t perform nearly well enough. Bus and rail connections have improved a little through BSIP but not enough. Adding Eurostar again to access via Ashford would help. Bus rail integration south of Tunbridge Wells is under exploited.

Q27/28/29

Agree with principles and threads.

Q33/34/35/36/37/38

Agree with principles. Flared junctions should be avoided. Cycle/pedestrian priority across junctions should be adopted aas policy. Cyclops style roundabouts should become much more commonly adopted as standard.

Q39/40/41

Agree with principles. 20mph default speed in residential streets and streets with strong character/heritage value would all be safer. Burwash example.


Q42/43/44

Agree with principles.

Q45/46/47

Agree with principles. Stimulating and supportive of social cohesion/mental and physical health objectives. Traffic must not dominate. Conversation is ioften impossible if traffic/vehicle noise pervasive.

Q48/49/50

Too much parking is simply more unnecessary road space: there will be induced traffic. Hard standing can contribute to flooding and denies the acquifers natural replenishment.

Q51/52/53

The ‘A21 development corridor’ presumes the road as the key to likely development sites and suggests road based accessiblity will therefore be key to any development’s success. That sounds a little like ‘business as usual’ However, it can’t be allowed to mask under and unexploited opportunities for movement of people by bus and rail and more locally by electric/conventional cycle and via good, safe pedestrian and cycle links.
The first Multi-Modal Study (2000) found that 68% of traffic on the A21 in the morning peak originated from south of Tunbridge Wells. It would be prudent to examine the potential for bus links to and across the Charing Cross - Hastings railway line to broaden the footprint of public transport accessibility. For example, the A265/268 could give access by bus to the train at Etchingham for Hawkhurst - Hurst Green and Burwash residents/visitors/students. This could also reduce car dependency in any village expansion developments, moreso if accompanied by supportive parking policies in urban centres. Your plan envisages the possibility of a future with less land given to car parks (and hopefully an end to free parking). This could follow future road user charging in whatever form it eventually takes.

Cars are getting bigger. Edge of town developments often feature generous parking spaces and these are often occupied by large SUV type vehicles. We strongly feel that these vehicles are not compatible with high quality living spaces and that there should be strong disincentives aimed at reducing their often intimidating presence in our streets and country lanes and anywhere near our schools.

Q54/55/121

General points:

There should be a strong component of public housing for rent; a strong component of truly affordable housing; a comprehensive cycle network that includes chldrens’ routes to school; 20mph default limits in all residential streets and dsitributor roads where appropriate (it will sometimes be appropriate). An absence of flared junctions and ‘cyclops’ roundabouts if a roundabout is deemed necessary.

Bus services under the new administration can be franchised by the transport authority. There could be some creative dialogues around services that RDC/ESCC feels might be improved by new/enhanced or extended routes.

It remains to be seen whether or not developers will still be able to renege on agreements around any form of planning gain. New policies will emerge that might benefit the community.

Q71

The ‘A21 transport corridor’ can only be examined as a multi-modal study. I already commented at Q53 but would add: there’s no bus connection between Etchingham station and Hurst Green which is a problem for locals (Management of The George - Ruth Hardy: theroyalgeorge@gmail.com).

Q72

Rother’s outstanding countryside is impaired by too much traffic with its associated negative impacts not the least of these being noise. The ridges and valleys are features that give much joy: it is hoped that the streams and rivers are unpolluted but reassurances are needed. In the case of the locally important Conquest Hospital, buses are severely delayed by queuing cars blocking access to the hospital entrance from The Ridge.


Q80

Sustainable transport provision should be designed with cumulative impacts and needs of neighbouring developments in mind. Not sure this has happened in north and West Bexhill (bus delays between Little Common and Northeye suggest that priority measures could have been installed ahead of development).

Q93

The ‘cooling effect’ of trees/shade and planted areas within urban settings is known and should be a factor in development plans, along with rainfall retention against flood risk.

Q98

Agree importance for young and old to have access to community facilities. Youth clubs’ demise has left a gap. These should be accessible by public transport/foot/cycle.

Q 104

Agree public rights of way/cycle routes hugely important for utility and leisure/education functions. These can afford great days out and should be part of the tourism leisure strategies and publicised in conjunction with public transport access in mind.

Q107

CVCP straddles the Bexhill - Hastings Link Road. Tranquillity has been lost to a large extent, but a 40mph speed restriction and acoustic cameras to deter noisy two/four wheeled vehicles would go some way to conferring on the valley some of its lost charm. The nationally important Bronze Age site seems to absent from any publicity.