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

Hedgerows and prairie planting plus trees possibly to follow along road routes could be implemented.

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.

The Council should redevelop existing buildings such as shops and offices that have been empty for years and stop building homes on farmland and the countryside as proposed in BAT0014

Q25.

Local housing needs necessitate that some development will be required within the High Weald National Landscape area and it is appropriate that any such development within this area is well-related to existing built-up areas and services. References to 'major development' within the policy are not well defined and lack the additional context provided within footnote 64 of the NPPF and could therefore mislead decision-makers into thinking this should apply to any 'major applications'. The policy as worded is therefore contrary to paragraph 16 of the NPPF which requires that policies are "clearly written and unambiguous, so it is evident how a decision maker should react to development proposals".

Reference to the High Weald Design Guide is supported and the proposed development concept at the Wild Meadows site has been considered in line with this Design Guide.

The proposed development reflects the positive characteristics of the built environment throughout the High Weald and makes effective and efficient use of the development site. The key principles that have determined the overall design and layout include:

• Prioritising walking and cycling routes within the site and ensuring permeability for those walking past, through and around the site, including improved access to both local facilities in Guestling Green (and those within the proposed development) and the surrounding countryside;
• Incorporating a central green public space that is addressed by the buildings around it;
• Meaningful public realm throughout the rest of the site with soft edges to streets, new tree planting and a rural character that reflects the character of the wider area;
• Residential layout that defines the streets within the site and provides strong street frontages offering both discernible building lines and architectural variety;
• An appropriate unit mix that reflects the local housing need for smaller dwellings and affordable housing;
• Parking integrated into the design and layout, with a mix of parking solutions to ensure that parking is discretely located where possible and not overly dominant at street level

Q51, 53

The Council's authority monitoring reports show that the Council have delivered between 98- 283 homes a year since 2011/12. Although completions have been rising over time, the scale of delivery falls significantly short of identified local housing needs (733 homes a year), as well as the agreed housing trajectory within the adopted Core Strategy (335 homes a year) and the proposed spatial development strategy for the Rother Local Plan 2020 - 2050 (258 to 364 homes a year).

The Council's existing housing policies and allocations are therefore significantly under-delivering on the agreed minimum housing requirements for the District and local need has grown since the adoption of the previous Core Strategy. Housing delivery will only improve consistently through the adoption of a new Local Plan with additional housing allocations and a revised policy framework that provides a more aspirational framework for housing delivery.
Without deliberate policy interventions to improve delivery, local supply and affordability issues will continue to worsen.

We therefore welcome the Council's intention to allocate additional sites for development and adopted a new Local Plan. It is essential that the new Plan does not impose constraints to development that suppress housing delivery unnecessarily. It is therefore essential that the local planning authority scrutinise its own evidence on supply and capacity to determine whether these figures are robust and whether there are further sources of supply that could
be relied upon or identified sites are capable of delivery additional housing.

It is noted that the housing requirement identified in the draft Plan currently is a supply-led figure that would not come close to meeting the identified local housing needs of the area and therefore all efforts must be made to find additional sources of supply.

The Wild Meadows site is one such location where the identified capacity of the site is being unnecessarily suppress within the Regulation 18 Plan. The site has been assessed as capable of delivering 14 new dwellings, but the Council's own minimum density target (25 dwellings per hectare (dph) in village locations) suggests that any allocation of this site should be seeking to
achieve a minimum of 28 new homes.

We have previously submitted a development concept that shows 29 new homes within the site alongside new community infrastructure including public greenspace and equipped playspace, and have provided a copy of this concept plan as part of this consultation response.

As mandatory housing targets have been re-established by central Government and national policy is likely to shift in favour of housing delivery (particularly on sites that can be delivered within the first five years of the Plan), there is a clear policy shift towards additional housing delivery. The delivery of at least 28 new homes on the Wild Meadows site would not only
deliver additional housing overall in the short term, but would also double the number of affordable homes that would be delivered on this site compared to the 14 unit estimate currently shown.

Q 59, 60, 61

We support the strategy for sustainable villages within this area and the concept plans for the proposed residential development at Wild Meadows already seek to enhance the public realm and provide new community facilities in Guestling Green, in accordance with this vision.

Guestling Green is an appropriate location for new housing growth and the allocation of the Wild Meadows site would deliver an appropriate scale of development that is commensurate to the size of the settlement. We believe that additional homes could be delivered on the Wild Meadows site in accordance with the Council's own minimum density target.

Q76

We welcome the recognition of Guestling as an appropriate location for growth.

Guestling Green provides an important local Primary School that serves the wider rural area, and the village also provides opportunities for development that can deliver new family housing, affordable homes and community infrastructure that will ultimately improve the overall sustainability of the settlement.

As set out in our response to other questions, the Wild Meadows site has the capacity to deliver new community infrastructure, including public amenity greenspace and equipped playspace that would provide a benefit to the entire settlement. The Wild Meadows site can also deliver 29 new homes at the Council's minimum density target (25 dwellings per hectare), which would
deliver a wide range of market and affordable homes and new family housing within walking distance of the Primary School.

The development can therefore improve the sustainability and viability of the settlement through appropriate growth and a gentle residential density. The settlement has been identified as a potential growth location in the past but the tightly drawn development boundary has prevented new development from coming forward and therefore the new Local Plan needs to be proactive in allocating the Wild Meadows site to ensure that the appropriate scale of growth and delivery of new community infrastructure can be achieved.

The scale of development proposed at Wild Meadows is commensurate to the size of the settlement and provides an excellent opportunity to sustain the settlement and address local
housing needs over the Plan period.

Q77.

We have serious concerns that the Council's intention to build a stepped housing trajectory into their strategy reflects a lack of aspiration to urgently address the under-delivery occurring within the District.

If delivery rates do not improve in the short term then the scale of unmet need will only worsen and the challenge to improve delivery at a later date will be potentially unachievable.

We are concerned that the Council is over-optimistic about its ability to achieve higher rates of delivery without immediate interventions and a step-change in the approach to housing delivery within this Local Plan.

One way to ensure that housing delivery if maximised throughout the Plan period is to review the potential capacity of sites identified as suitable for development and to ensure that the recommended minimum density targets are achieved on all these future allocations.

Please see comments raised under 3.54 that are relevant here. If you are serious about protecting the rural landscape, the wording needs to be far more robust as to make development on these sites 'not at all likely' as opposed to still being 'likely' because you give greater weight to other factors.

The policy as I see it seeks to restrict building within the AONB to small scale and appropriate developments. In Catsfield, the only designated site is within AONB and is for the building of 35 homes, along with parking and roads. It will be the first estate in Catsfield and swell the central village to more than 100% of its current size, many of the current older houses not having their own parking. This does not comply with the aim to build “in keeping with landscape and settlement pattern”. A “major development of more than 10 houses” are indeed inappropriate here.

The client’s sites are located within the High Weald National Landscape. We agree with the overarching objective to ensure that new development should fit into the landscape and not harm the said landscape. We recognise that this has the highest status of protection, but it must be made clear that due to the historic lack of delivery of housing in the district, sites which can deliver housing in sustainable locations within the High Weald National Landscape should be supported, as long as they are sensitive to the objectives set out within the NPPF. There is a clear need for housing development and given the significant portion of Rother District Council being located within the High Weald National Landscape, that it is necessary for the council to support development within it.

There should be reference to Dark Skies being a High Weald NL core component of natural
beauty.

Support reflecting the importance of the High Weald in the local plan and ensuring that the goals of the HW AONB management plan and associated policies are suitably reflected. The wording on woodland should be strengthened, given the nationally significant ancient woodland sites within the High Weald.

Whilst we recognise the importance of the National Landscape and the protection given to it, 83% of the district is located within the High Weald National Landscape, therefore it should be recognised that in order to meet the Council’s housing need, there will need for development to be located within these areas.

Please see attached the full response from Etchingham Parish Council regarding the draft Local Plan.

Please see attached the full response from Etchingham Parish Council regarding the draft Local Plan.

Please see attached comments from Burwash Parish Council.

See attached document

Full representation 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.

See attached 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?

Please see attachment

Please see attachment

Q1: Re: "1.7 The plan sets twin overall priorities (‘Green to the Core’ and ‘Live Well Locally’)" - I applaud the ambition, but am concerened to see, additionally, a clear statement that BOTH priorities are EQUAL, even if one has to written before the other.

Q6: This is a highly technical policy that really needs another section before ()A) for application to small developments, being undertaken without the benefit of highly qualified experts.

Q9: Agreed a good Policy

Q11: Agreed a good Policy

Q18: Re: "3.36 The opportunity for the development of wind turbines within the district, is extremely limited..." - I beleive very small scale wind power turbines down to single dwelling capability should be considered since technology could deliver economical useful machines within the timescale of this Plan.

Q22/23: RE: "All qualifying development proposals must deliver at least a 20% measurable
biodiversity net gain..." - understood but the metric for qualification is not easy to find?
Agreed a good Policy to go beyond 10%.

Q25: Agreed a good Policy

Q28: Re: "a. Urban areas in Bexhill, Battle and Rye: 60-90+ dph, with higher densities
around transport hubs and town and district centres.
b. Suburban areas in Bexhill, Battle, Hasting Fringes and Rye: 45-75 dph." - it is hard to understand the difference between Urban and Suburban, even with Fig 8? Until 4.15 work is carried out I reserve my judgemment on this Policy.

Q32: In essence a good policy, but some examples e.g. bank have long since gone even from towns within Rother so hardly an OK exemplar. I wonder if 800m is the right parameter - in my road many residents would get their car out for such a distance, few possibly only 20% would walk that distance.

Q33: Whist overall I agree this is a good Policy - I think it needs to be more clearly sectioned, maybe even several seperate Ploicies. Re: "g. Appropriate signage and wayfinding." -this has often or nearly always been overlooked - so a very welcome improvement.

Q35: I particularly like this policy and the 400m parameter, which of course certainly should apply to the Blackfriars development - so a major step forward if it is applied, since previously RDC has in effect only considered on-site access not off-site access.

Q37: I am concerned that no mention is made of former PRoW (FPs) being re-routed through development sites across multiple driveways; rather tah finding contiguous routings through or outside the site connecting to the existing network without having to contend with multiple drive crossings. Though see also Q104 comment.

Q38: Agreed about ixc) Shared Use Routes - the higher age range demographic deprecate shared use, due to (anecdotally) cyclists lack of concern for less ambulant walkers. Very little chance of people buy-in to Demand Responsive Transport, car clubs and car shares!

Q45: Agreed a good Policy; though I note: "inclusively designed so that people with visual, mobility or other limitations will be able to use the street confidently and safely.", so do not see why "iii) Dementia Friendly District" is highlighted, when it would be better to categorise as for example "those with reduced sensory perceptions and mobility"?

Q51: Agreed a good Policy. Crowhurst should be in the Battle SDO; whereas it may be better to exclude Sedlescombe for the battle SDO, due to the decisive split that the A21 causes and Sedlescombe fees more adjacent (connected) to Westfield. Quite evident in Fig 12.

Q62: Re: "5.56 Battle is a small, historic market town." Umm - not a good summary, it should be: "Battle is a small, historic FORMER market town.", since all banks now gone...

Q74: This policy area is so heavily over burdened by national and county council legislation and determination, I recommend the LP only provides for the minimal provision since there is nowadays negligible agricultural seasonal employment upon which much of the legislation appears to be based.

Q76: Fig 35/36 - I do not agree that Battle has " Greater opportunity for growth, since already the constraints discussed show minimal opportunity e.g. NPPF/NL conditions. Furtermore the employment locations expansion in Battle are, as the Neighbourhood Plan Calls showed, almost negligible and certainly not as RDC pushed for when the NP was being developed.

Q84: Agreed a good Policy.

Q90: It is hard to understand why the RDC/Inspector refused to allow the proposed Gap along the Hastings Road at Telham was not allowed in the Battle NP, given these arguments it would have enhanced the protection: "The Gap between Battle and Hastings/St Leonards provides an important function in maintaining the separate identities of Battle and the built-up area of Hastings/St Leonards. The break in the ribbon development between the edge of Telham and the Hastings Borough boundary at Breadsell Farm is highly vulnerable to change particularly in more open areas and the higher ground and ridges."

Q96: In view of the source of this Policy will it now be applied Rother wide?

Q104: Agreed a good Policy. I welcome this new Policy, especially the aspects regarding diversion of FPs within development sites be required to deliver "equivalent" access and "must be replicated" See also comment to Q37.

Q109: Agreed a good Policy.

Q112: Agreed a good Policy.

Q119: I do not favour "100% affordable housing schemes". Surely "pepperpotting" is a better solution?

Q121: Given my comment on Q119, I do not really agree with is Policy, however given the intent for "substantially affordable housing", I would accept the need could be so satisfied.

Q125: Agreed a good Policy.

Q131: I welcome further work on this need.

Q133: Agreed a good Policy.

Q147: I would like to see a strengthening to no permission would be given to changing natural boundary hedges and trees.

Q149: Conversions/extensions of an older wood construction building by using modern brick construction, for example, should not normally be permitted, since they would significantly alter the street scene.

Q153: Agreed a good Policy, however I do not agree that in 8.179 Laurel is preferred - it is too fast growing and likely to over burden other growth.

Q170: Agreed a good Policy. I particularly welcome "xi) Where practicable, the track is opened as a path for permissive public usage or as Public Right of Way, and should be accessible from the existing Public Rights of Way network", since this would make the applicant aware that they could provide a beneficial PRoW spin-off from their operations, not previously or normally offered.

Q178: Agreed a good Policy.

Q180: Agreed a good Policy.

Q182: Agreed a good Policy. Welcomed and for reasons of energy saving an emphasis on PIR use should be paramount.

Q195: Agreed a good Policy. But I am confused by this wording: "vi) For Ancient Woodland, create a development buffer zone of at least 15 metres. An impact assessment will be required where any development is proposed within 25 metres of Ancient Woodland to demonstrate that the proposed buffer zone avoids negative effects on the habitat.", since surely a single buffer zone of 25m would suffice?

Appendix 2: Surely "Market square including Jempsons shop and others should be considered as in the "Battle Town Centre and Primary Shopping Area", even if not contiguously connected? The south-eastern limit of the appears to miss out several shops/cafes of importance...

Q208: "proposed monitoring framework" appears to be a comprehensive methodology to adopt. but i wonder how it will be reported?

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!