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....

I think it is important to have local nature recovery areas. Existing areas should be used where possible and avoid building on nature sites.

The snappy punchline of 'Green to the core' and 'Live well locally' is a bold attempt to show a commitment to protecting rural communities and local ecology but your HELAA land allocation of CAT0001 and potential site CAT0016 in Catsfield fly in the face of these claims/promises.
The proposal of 60 new houses (some proposing to be built on protected AONB land) in this small rural village (doubling the size of the main village), is absolutely shocking and I object strongly to these sites being included for allocation in this plan.
These proposals would not only destroy ancient woodland, biodiversity and protected wildlife habitats, they would also severely impact the lives of local residents with increased pollution and a serious decline in the already insufficient utilties and local infrastructure.

Key Objections
Loss of ancient hedgerows featuring protected wildlife, veteran trees and endangered flora and fauna

Please see attached:

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

Far too vague, leaves developers with any number of loopholes to exploit. The base requirement should be that any development a) improves wildlife habitat and increases biodiversity on the site of the development b) connects or pays to connect that development via a nature corridor or corridor(s) with other similar habitats c) for every area of green field or woodland lost to man-made materials, an area with equal or greater habitat value is created somewhere else within the county or in immediately bordering counties

A local nature recovery area is not going to offset the damage done by building on greenfield.

SWT strongly supports the inclusion of this policy. It is vital that Local Nature Recovery Strategies (LNRS) are embedded into the planning system to ensure that development avoids our most important sites for biodiversity, in line with the mitigation hierarchy, and avoids sites in recovery. LNRSs will also be key to directing BNG efficiently to achieve the highest gains for biodiversity possible.

Strongly support the policy to incorporate the emerging LNRS mapping and priorities into the local plan.

It is not clear what the policy is or what an LNRA is.

Please see attached comments from Burwash Parish Council.

Dear Sirs,

Despite being degree educated I found your website and the process for commenting on the draft local plan incredibly confusing and difficult to navigate. Therefore, please accept my comments included in this email and as follows:

Berners Hill Traveller site TIC0039
The local area is one of outstanding natural beauty, alas we were not permitted to include a window at the front of a recent extension to our unlisted property. As such we do not agree with the land earmarked as a potential site for the development of a traveller site or any development for that matter. The proposal contradicts R2 policy in Ticehurst’s Neighbourhood Plans to maintain green spaces between settlements and the same site features in the HEELA as a rejected site as it does not meet RDC’s objectives due to historical field boundaries and substantial ancient woodland to the north. Additionally, the site slopes to west – northwest and would be prominent and encroach on the countryside.

Land at Seacoxers for traveller site TIC0038
Covered by a woodland tree preservation order and abuts ancient woodland to the south. The land owner has made two unsuccessful attempts to gain planning for two properties and four properties which were refused and then dismissed at appeal. In breach of tree preservation order - in breach of dwelling on site without permission - in breach of forming an access on to the highway without permission from ESCC. In the HEELA assessment it is a rejected site as unsuitable for dwellings.

‘Live Well Locally’ Policy LWL2 Facilities and Services
The existing infrastructure does not support further development. One main concern is the lack of paving and speed restrictions along the stretch of road through the village. The B2087 and A268 has a history of serious accidents owing to the speed of which vehicles enter the area after exiting the A21 (one of the UK’s most dangerous roads). Development of an area in which residents rely heavily on the use of cars will also increase congestion (there is only one bus an hour until early evening). This goes against the ‘Green to the Core’ policies of the draft local plan.

Policy GTC7 Local Nature Recovery Area
Development should not ‘harm or adversely affect an area or areas identified as being important for biodiversity.

Policy GTC8
I fail to see how these proposals can demonstrate a biodiversity gain plan. Development should be small-scale and in keeping with the settlement pattern, this includes back-fill which has always been resisted, especially with the proximity to Bedgebury.

See attached document

Please see attached submission.

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.

Please see attached comments by Historic England on the Rother draft Local Plan 2020-2040 (Regulation 18), including representations on:

Policy GTC1
Policy GTC2
Policy GTC6
Policy LWL1
Policy HER1
Policy HER2

Requirement for Development Management policies

Draft Local Plan evidence base documents

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.

Please see the attached full submission from the Home Builders Federation.

See attached document for the representation.

See attachment for the full representation.

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?

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

Please accept my comments below on the draft local plan, which I am including in this email as I found your website unclear and confusing, despite my postgraduate level of education and vast experience in print media.


Berners Hill Traveller site TIC0039
Our area is one of outstanding natural beauty. However, we were not permitted to include a window at the front of a recent extension to our unlisted property. Thus we disagree with the land earmarked as a potential traveller site, or any development for that matter. The proposal contradicts R2 policy in Ticehurst’s Neighbourhood Plans to maintain green spaces between settlements and the same site features in the HEELA as a rejected site as it does not meet RDC’s objectives due to historical field boundaries and substantial ancient woodland to the north. Furthermore, the site slopes to west – northwest so it would be a conspicuous sight and encroach on the countryside.

Land at Seacoxers for traveller site TIC0038
This is covered by a woodland tree preservation order and abuts ancient woodland to the south. The land owner has made two unsuccessful attempts to gain planning - for two properties and four properties, respectively - both of which were refused and then dismissed at appeal: in breach of tree preservation order; in breach of dwelling on site without permission; in breach of forming an access on to the highway without permission from ESCC. In the HEELA assessment the site is deemed unsuitable for dwellings.

‘Live Well Locally’ Policy LWL2 Facilities and Services
The current infrastructure does not support further development. One main concern is the lack of paving and speed restrictions along the stretch of road through the village. The B2087 and A268 have a history of serious accidents owing to the speed at which vehicles enter the area after leaving the A21 (one of the UK’s most dangerous roads). Development of an area in which residents rely heavily on the use of cars will also increase congestion (there is only one bus an hour until early evening). This goes against the ‘Green to the Core’ policies of the draft local plan.

Policy GTC7 Local Nature Recovery Area
Development should not 'harm or adversely affect an area or areas identified as being important for biodiversity.'

Policy GTC8
These proposals fail to demonstrate a biodiversity gain plan. Development should be small-scale and in keeping with the settlement pattern, this includes back-fill which has always been resisted, especially with the proximity to Bedgebury.

Policy TIC007 Fruitfields
The area earmarked for potential development forms part of the Ancient Woodland Inventory 2010. An irreplaceable habitat of ecological value for nature recovery as well as carbon sequestration and cultural and landscape importance.

Please see attachment