Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 24759
Received: 31/05/2024
Respondent: Sedlescombe Parish Council
The terms small and large should be defined. Is small 5 or 15? Is large 10? Less subjective wording should be used.
Please see attached comments on draft Local Plan, including Brede Valley Landscape Assessment and East Sussex Landscape Assessment.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25113
Received: 10/07/2024
Respondent: Mr Reuben French
I struggled to find the section where we could make an objection to the development at Almonry Fram. Battle infrastructure is simply not adequate to sustain such a huge influx of people. Constant traffic. I think you will find that every restaurant/pub/ shop in battle is full every weekend in Battle also.
I do not feel as if this development is suitable for Battle, potentially the development of 20 units or so in this area. However this will cause a massive damage to some of Battles most preserved wildlife.
Saxon Woods is one of the main if not only woods in Battle that is accessible to dog walkers, children, and family. I feel like this development would completely counteract your policies and everything the council is doing to protect our environment and completely obliterate any efforts to develop our community safely and effectively.
I struggled to find the section where we could make an objection to the development at Almonry Fram. Battle infrastructure is simply not adequate to sustain such a huge influx of people. Constant traffic. I think you will find that every restaurant/pub/ shop in battle is full every weekend in Battle also.
I do not feel as if this development is suitable for Battle, potentially the development of 20 units or so in this area. However this will cause a massive damage to some of Battles most preserved wildlife.
Saxon Woods is one of the main if not only woods in Battle that is accessible to dog walkers, children, and family. I feel like this development would completely counteract your policies and everything the council is doing to protect our environment and completely obliterate any efforts to develop our community safely and effectively.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 25172
Received: 11/07/2024
Respondent: Mrs Emma Weller
**PLEASE READ FULL COMMENTS** Catsfield site allocation CAT0001 (HELAA Identified) has recently had an outline planning application submitted and withdrawn before it was refused (Application RR/2019/257/P). Previous applications for much smaller developments on this site have also been rejected (Applications A/70/522 for one dwelling and A/70/526 for 3 dwellings). The site falls within the High Weald AONB, which according to policy, can only be developed in 'exceptional circumstances'. This site and proposed number of dwellings does not fall within this caveat. The number of dwellings proposed for this site (35 dwellings) is classified in the planning documents as a 'Major development', which is not permitted within the HWAONB. The Delegated Officer Report - Assessment of Case, for application RR/2019/257/P, should be referred to before finalising this draft Local Plan/HELAA and before any further consideration of the continued allocation of site CAT0001.
Catsfield site allocation CAT0001 (HELAA Identified) has recently had an outline planning application submitted and withdrawn before it was refused (Application RR/2019/257/P). Previous applications for much smaller developments on this site have also been rejected (Applications A/70/522 for one dwelling and A/70/526 for 3 dwellings). A FOI request made to RDC has revealed the planning officers final report recommending refusal for the most recent application of the proposed 35 dwellings (as identified and proposed by the HELAA) and other associated documentation, which showed some of the reasons for refusal. These should be reviewed and considered before finalising this future Local Plan and HELAA as they show that; - The site is actually not appropriate for development (it contravenes National and RDC's own policies). - Development of the site would cause a significant health, safety and wellbeing risks to local residents and the local community due to it being in a 'red zone' for flood risk, cause over population and cripple the already inadequate local infrastructure (highways, health provision, poor utility quality and provision, lack of education facilities in the village and surrounding area, etc). - 1.6 hectares is not adequate for a development of this size and does not meet planning guidance for density of development in a rural village location. - Development of the site would destroy the habitat of protected and endangered wildlife which currently resides there (as documented in the ecology report submitted to RDC planning dept). This site falls within the 'red zone' for Great Crested Newts and is home to a large number of protected and endangered species of wildlife, flora and fauna (inc bats, badgers, hazel dormice, etc). All of which are fully protected under the Wildlife and Countryside Act 1981 and The Conservation of Habitats and Species Regulations 2017, also making them European Protected Species. - The site falls within the High Weald AONB, which according to policy, can only be developed in 'exceptional circumstances'. This site and proposed number of dwellings does not fall within this caveat. The number of dwellings proposed for this site (35 dwellings) is classified in the planning documents as a 'Major development', which is not permitted within the HWAONB. - The site is subject to a blanket Tree Protection Order (TPO) and is adjacent to properties with listed status. These would all be severely impacted by any kind of development/construction on this site. - The northeastern boundary of the site falls within the Pevensey levels Hydrological Catchment and RAMSAR Area. - The Delegated Officer Report - Assessment of Case, should be referred to before finalising this draft Local Plan/HELAA and before any further consideration of the continued allocation of site CAT0001. The report's conclusion (and reasons for refusal of outline planning) states; - The proposal would cause significant harm to the local landscape character of the AONB and the rural settings of the nearby listed buildings. - The submitted information concerning the impact of the proposal on ecology and biodiversity and the proposed biodiversity mitigation and enhancement measures are considered to be inadequate. - The proposed development of 35 dwellings by reason of its layout and scale and disregard to landscape features such as trees and road hedgerows would be out of character with the site and surrounding pattern of development and would materially harm the intrinsic character and appearance of the locality and scenic beauty of the High Weald National Landscape (Area of Outstanding Natural Beauty). As such, the proposal is contrary to policies OSS4, EN1 and EN3 of the Rother Local Plan Core Strategy (2014), policies DIM2, DEN1 and DEN2 of the Rother Development and Site Allocations Local Plan (2019), paragraphs 135, 136 and 182 of the National Planning Policy Framework and, Objectives S2, S3 and FH2 of the High Weald Management Plan. - It has not been demonstrated that the proposal complies with policy EN5 of the Rother Local Plan Core Strategy (2014), policy DEN4 of the Rother Development and Site Allocations Local Plan (2019) and, paragraphs 180 and 186 of the National Planning Policy Framework. - The proposed development (of 35 dwellings) due to inadequate drainage strategy and lack of flood risk management strategy for high groundwater could increase risk of flooding within site and elsewhere, contrary to policies EN6 and EN7 of the Rother Local Plan Core Strategy (2014) and paragraphs 173 and 175 of the National Planning Policy Framework. The final paragraph states; - NATIONAL PLANNING POLICY FRAMEWORK: In accordance with paragraph 38 of the National Planning Policy Framework the Council works in a positive and pro-active way with Applicants and looks for solutions to enable the grant of planning permission. However, in this case the proposal is not sustainable development for the reasons set out and the Council was unable to identify a way of securing a development that improves the economic, social and environmental conditions of the area. Planning applications for other sites in Catsfield with the same features as this site (e.g. The Brooks) have been refused and the site deemed as unsuitable in the HELAA. This site should be assessed in the same way, deemed unsuitable for development for the same reasons and subsequently removed from the HELAA as an allocated site for development, as should site CAT0016 for the same reasons.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26245
Received: 17/07/2024
Respondent: Burwash Parish Council
Consideration should be given to protecting mature trees in and around developments.
Please see attached comments from Burwash Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26247
Received: 17/07/2024
Respondent: Burwash Parish Council
Over reliance on High Weald Management Plan that is a real concern. The plan isn’t comprehensive enough in protecting the National landscape and the local plans reliance on the HWMP leaves large gaps in protection.
Please see attached comments from Burwash Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26588
Received: 29/07/2024
Respondent: Stephen Nicholls
Please see attached representation on Q26 of the draft Plan regarding Proposed Policy GTC9: High Weald National Landscape (AONB).
Please see attached submission.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 26990
Received: 22/07/2024
Respondent: Northiam Parish Council
Development where suitable should be allowed within the HWNL, small scale and to a high standard. It will be interesting to see if the new administration applies the concept of ‘grey belt’ to ANOBs.
See attached.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27051
Received: 22/07/2024
Respondent: Westfield Parish Council
See points 42-48 in the attached submission.
Please see attached document for the full submission from Westfield Parish Council.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27393
Received: 22/07/2024
Respondent: Catsfield Parish Council
Reference sites allocated in the HEELA.
“Impact on the High Weald AONB. Catsfield is a very attractive and highly desirable place to live within an area designated for landscape beauty. This landscape is of national importance and should be preserved. Green open spaces incorporating trees, natural boundaries, views and both managed and unmanaged open land are intrinsic to the qualities of the AONB. The overdevelopment of these sites and the substantial growth proposed to the village will have an irrevocable impact on the landscape. The sites are not sheltered, screened or visually mitigated. The sites if developed will constitute a fundamental change to the character and appearance of the village and the wider area. The 2014 Core
Strategy makes it a key vision principle that essentially rural areas falling mainly within the High Weald AONB retain their essential character, and the new draft local plan supports this.
There is a strong presumption in the NPPF that areas such as the AONB are important to be protected and should shape the extent and scale of development. The Core Strategy recognises the restriction but states that sustainable growth can happen but should not happen without harming the individual character and amenities. The construction of 35 and 20 dwellings on the respective sites in the HEELA involving the removal of several trees and the encroachment into the setting of listed buildings is a significant impact on the character and (visual) amenities of Catsfield. Development on these sites fails to recognise the strong steer given by policy DEN2 in the current Local Plan which states that development within the High Weald AONB should be small scale an in keeping with the landscape and settlement pattern; major development (greater than 10 homes) will be inappropriate except in exceptional circumstances. The new draft plan also supports this. In determining the site allocations in the Current Local Plan, CAT0001 should not have been entertained at all and both CAT0001 and CAT0016 do not align with the polices in the new draft plan.
Catsfield is a village with a very linear pattern of development with a single row of properties facing onto three or four key streets such as Church Lane/Church Road, Skinners Lane and The Green. There is very little intensification and dense urbanisation. A deeply projecting and very large sites such as CAT0001 and CAT0016 would be beyond the existing urban grain and would be out of character. Furthermore, this incongruous form of development would be highly visible and harmful to the qualities of the AONB by being visible from within the AONB.
Paragraphs 3.63 and 3.63 in the Regulation 18 Commentary set out policy approaches to protect and enhance the High Weald.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Representation ID: 27562
Received: 23/07/2024
Respondent: Southern Housing
Where reference is made to paragraph 183 of the NPPF, we suggest re-wording to reference the fact major development should also be in the public interest e.g. “Major development should not take place in the AONB save in exceptional circumstances and where the scheme is in the public interest as outlined at paragraph 183 of the NPPF.”