Generally, green issues are under national guidelines. All Rother can do is try to enforce/encourage them. To reach lower emissions, which means using electricity more, we need to address a problem particular to Brightling, .i.e. reliability of electricity supply. This is proving to be very poor indeed and many of us now run emission busting generators.

Retrofitting of insulation is only as good as the people doing the work. So far, the record has not been good. However, an important step (together with the right rules on new properties) so this needs to be addressed in a professional manner. Where is the funding coming from?

Re-use of existing properties by changing to suit modern needs is good. At the moment it is easy to say a property is no longer fit for the purpose. There should be set criteria by which it is judged. Re-using not only saves on materials costs and energy, but also on demolition, clearing site and then re-delivering of new material all with its energy consumption. Local residents should be able to compile a description of what they see as "local style". A Bank for local building materials acquired through re-claim is an excellent idea. Would it be Council controlled or private as this could be open to unscrupulous acquisitions. (some will remember all our manhole covers being stolen not that many years ago!)

Water storage is something we need to look at, but how? Underground tanks? Then it is important to educate people in health and safety on re-use of this water.

Education should also play an important part in the conservation of nature. Many people do not see the huge variety we have around us, particularly in Brightling. (see Messenger articles on What to Look out for my contribution.)

Potential employment growth of 1861people (how do they know?) has been identified at Coldharbour Farm Estate. Will this be to the detriment of locals and other road users, with traffic movement, noise and unsightly commercial builders? What would the position be with other farms in the Parish where farming is clearly not a profitable enterprise and most having a back-up plan.

Residential development potential has been spotted in surrounding villages. This needs to be watched as there is a risk of increased traffic through Brightling as it is used as a rat run to get to other main roads, stations, etc.

Good luck with the 30 years vision for the A21!

To answer question 92/93 - Brightling is a very social village which communicates well, as proved during Covid. The internet is very important here and, thanks to Andrew, we now have super fast connection. This then leads back to the question of power supply....

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

Water savings will become more essential than ever. Provision of capture and reuse systems for cleaner waste water should be insisted upon for any commercial or residential units. Risk factors for disease from stagnant water will need very careful consideration.
Measures should be costed and implemented at the planning stage before approval of new developments. More pressure may be needed to enforce this. Costs should not be used as an excuse for non-compliance.

I don't think it goes far enough considering the pressures on water in the district. While the government has certain standards, there is no "future update" on this policy like GTC1 has. The standards mentioned are already worse than RIBA (Royal Institute of British Architects) promotes which are 75l/p/day potable water usage.

SWT strongly supports this policy and particularly the encouragement of other water efficiency measures, such as grey water recycling, green walls and roofs.

It's great to see rainwater retention and other measures included but the word "should" in the policy ought to be replaced with "must"; and is "encouraged" suitable in this climate? Surely, "water efficiency measures" MUST be included, don't give the developers the wriggle room not to include them! I accept development costs will increase (minimally) but the long-term cost savings for the occupants, when weighed with the reduction of drawn water from the authority at a time when water scarcity will inevitably be close at hand, is too big a benefit for such water saving measures not to be compulsory.

Southern Water is the water supplier to parts of the Rother district and the wastewater service provider across the district. We strongly support water efficiency in the design of new homes, but request changes to this policy to enable implementation of the expected tightening of Building Regulations standards applying to water stressed areas. Please see our response to Question 14 for more on our requested changes.

The principles of the policy are supported by the client.

Excellent.

Please see attached comments from Burwash Parish Council.

Please see attached full submission from Nexus Planning on behalf of their client Devine Homes regarding the Local Plan and HELAA Site SAL0012: Land at Bishops Lane, Robertsbridge

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.

Full submission attached.

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.

Chapter 3 – Green to the Core
Proposed Policy GTC1: Net Zero Building Standards
Operational Energy (A)(i)(c) - A maximum space heating demand for new buildings (small scale housing) of 15 kWh/m2 per year.
What is small scale housing? 15KWh/m2 per year is passivhaus standard – do you think this is possible for the majority of housing? If small scale housing is only a subset of most of the houses to be built, what is their target for space heating demand?

Proposed Policy GTC2: Net Zero Retrofit Standards
What proportion of dwellings to be retrofitted do you think this will impact? Surely most do not need planning permission?
It has been stated that the current level of demolition and subsequent replacement through new build contributes five times more greenhouse gases than air travel. While unsure of the evidence for this statement, is RDC satisfied that their policy promotes retrofit strongly enough?

Proposed Policy GTC3: Construction Materials and Waste
Do you know if developers currently have designs that use a Design for Disassembly approach or is that something that needs to be promoted to architects?

Proposed Policy GTC4: Water Efficiency
Will this policy be able to keep up with potential future reductions in water usage? The RIBA (Royal Institute of British Architects) 2030 Climate Challenge promotes 75l/p/day potable water usage.
Would the policy benefit from an “update” statement as GTC1 (A, i, d) does?

Proposed Policy GTC6: Renewable and Low Carbon Energy
Why does this policy not include criteria about improving biodiversity e.g. making areas into small nature reserves and that any biodiversity improvements should be retained at the end of life of the site?

Proposed Policy GTC7: Local Nature Recovery Areas
Will planners use local Biodiversity Audits (such as Crowhurst has) to help identify areas as important?
Could iii) “it directs Biodiversity Net Gain to where it can be of most benefit” be used by developers to increase BNG offsite from developments, even to non-local areas?

Proposed Policy GTC8: Biodiversity Net Gain
How confident are you that the 20% min BNG will be allowed?

Proposed Policy GTC9: High Weald National Landscape (AONB)
Should there be more to the sentence “To support the integrity and importance of the High Weald NL and conserve and enhance its important landscape and scenic beauty the following policy approaches have been explored:” at the end of para 3.64 on p60?

Chapter 4 – Live Well Locally
Proposed Policy LWL2: Facilities and Services

This policy states that developments in village areas should be within safe walking or cycling distance of a range of seven specified local amenities. The Crowhurst developments are within range of three of the listed facilities. The policy then states that where a development does not comply, it should be within walking distance of a suitable bus stop, with transport to an area containing these facilities. In our case these facilities (food shop, GP surgery etc) are accessible in Battle or Hastings via the station or the flex bus. We suggest amending the policy to include these transport hubs.

Chapter 5 – Development Strategy and Principles
Proposed Policy DEV2: Comprehensive Development and Master planning

If a developer subsequently reneges on specified aspects of an approved planning application, e.g. by reducing the affordable housing element, will the Council consider voiding the approval?

Proposed Policy DEV3: Development Boundaries

With reference to paragraph 5.119, can you confirm how, when and in what circumstances village development boundaries may be reviewed?

Proposed Policy DEV5: Development on Small Sites and Windfall Development

Parishes are currently not able to control identification of sites of less than five dwellings through the neighbourhood planning process. Paragraph 5.132 states that it is likely that future neighbourhood plans will be able to identify smaller sites, with no site size threshold. Does this equally mean that small sites considered unacceptable through the neighbourhood plan process would have a presumption for planning permission to be refused?

Proposed Policy DEV6: Strategic Green Gaps

Policy DEV6 refers repeatedly to the vulnerability of the various strategic gaps including between Crowhurst and Hastings/Saint Leonards. How firm is your intention to maintain the strategic gap?

Chapter 11 – Environmental Management
Proposed Policy ENV1: Coastal, Water and Flood Risk Management
Does criteria ii) include during construction of new developments when vegetation that would normally slow water run-off may have been removed but any required flood alleviation has not yet been put in place? (even though this is mentioned in ENV2 (vii))?

Proposed Policy ENV2: Sustainable Surface Water Drainage
Why is only flood risk and not contamination/pollution mentioned in criteria (vii)?

Proposed Policy ENV5: Habitats and Species
Should ancient and veteran trees also be protected by TPO’s if development is taking place near them?
Will developers also be encouraged to use local Biodiversity Audits as information?

Chapter 12 - Heritage
Proposed Policy HER2: Traditional Historic Farm Buildings
Although you mention nesting birds in para 12.29, should it be specifically mentioned in the policy as conversion of farm buildings often ends up blocking access to birds’ nesting sites inside?
Will conversion to residential proposals also have to meet sustainable location criteria as farm buildings are often at a distance from other buildings?

Please see attachment

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