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

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

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

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.

There is quite a lot of unused development in battle i.e. empty houses, shops and offices. In order to conserve the enviroment these should be redeveloped first.

Please see attached representation, existing and proposed sites plans.

Missed issues:
- protect food security by safeguarding farmland (current and potential)
- provide for increased population's security, health and education needs with more schools, GPs, police and dentists.
- encourage and provide for tourism to the area
- improvements to public transport provision

Please see attached:

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

There is a key opportunity that appears to be missing from this issue:

- meeting the overall local demand and need for housing (including affordable and specialist need) and associated growth – taking a landscape and sustainability led approach across the district;

There is the opportunity to link this directly to nurturing and supporting the growth of local businesses and start-up, as well as more traditional crafts and skills associated with rothers architectural heritage. The Pheonix Development for example in Lewes, is leading on working with local materials and crafts-people to both upskill local people, and grow the market for locally grown/manufactured/produced materials and products.

Retrofitting our existing buildings is also a key opportunity here, so that the towns and villages we already have, are upgraded to be energy efficient, low carbon, climate resilient and support the well being of our people and communities.

Proper planning for a long term community spaces for Artists in Rye. Something like Cockpit studios Or Folkestone’s creative quarter. Whereby a professional establishment can attracts arts funding and offer creative ideas/ practical workshops to get the ‘green’ living across to all areas of the community.

We agree with the principles of these policies, however, would highlight in the second criterion the need to focus on housing delivery.
Rother District Council has historic issues with the delivery of new housing, granted this is due to the many landscape designations primarily. The ambition of the new local plan should be to help boost the delivery of all forms of housing on an annual basis alongside meeting the local need.
The identified housing needs as set out in the HEDNA Update sets out that Rother needs 737 dwellings per annum, and this is “considerably higher than the currently adopted housing requirement policies”. The details set out in 2.13 should have a specific target for housing delivery to meet the identified housing needs as set out in the HEDNA. Rother currently only delivers 41% of its required housing and needs to deliver more in order to meet its needs.

At para 2.13, the plan refers to "delivering carbon reduction and adaptation to climate change, and responding to
the locally declared ‘Climate Emergency" however there is no equivalent point for the biodiversity crisis, despite the earlier statement that "Being Green to the Core means considering the impact of all planning decisions on the climate emergency, the biodiversity crisis and the High Weald Area National Landscape."

It would make sense therefore to add a key issue to reflect this, e.g. "delivering nature recovery, protecting and reconnecting priority habitats, and responding to the biodiversity crisis".

Everything on the list is good. The one thing that's missing is community energy, which would reduce cost of living worries for many, provide local employment and contribute to your net zero target. Community energy is a big thing nowadays, and getting bigger. A 15-year plan needs to mention it as a key issue. Perhaps you could fit it in alongside infrastructure development, as community energy will "strengthen the sustainability of settlements and communities".

The draft Local Plan seeks to address ten key planning issues, which are stated to stem directly from the Vision for the Plan and link to the Council’s two ‘Overall Priorities’. In response, all ten 'key issues' are important and should be integrated into the overall strategy. As previously mentioned, the need to fully address housing needs should be explicitly identified as an “Overall Priority,” as it is not adequately captured by the strategic priorities of “Green to the Core” and “Live Well Locally.” We welcome the recognition of the housing need within the 10 key issues.
We support the Council’s recognition that the Plan needs to provide support to rural economies and communities, however this should include reference to the provision of new housing to meet local need.

Please see attached comments from Burwash Parish Council.

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.

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.

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.

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 attached submitted document for full comments.

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!