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

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.
See further comments on HELAA Part 2 Chapter 3.

Please see attached representation, existing and proposed sites plans.

In westfield there are 2 halls but neither is available for group meetings during the day as one is used at the venue for playgroup and the other is used by the school, although not owned by them.
There should be suitable options for groups and organisations to meet during daylight hours

Please see attached:

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

Sport England supports this policy.

The policy sets out that all new development of one dwelling must meet a number of key criteria including being in an accessible walking distance to village centres. The sites are 1km or less from the heart of Ticehurst and 1 km from the Ticehurst GP Surgery, under 100m of the nearby Ticehurst and Flimwell Church of England Primary School, 500m to Ticehurst Village Hall, and less than 100m from the Cherry Tree Pub, and 950m from the Ticehurst Village Post Office and Londis, which sells fresh fruit and vegetables. Furthermore, there is a bus stop less than 50m from the sites’ entrance.
In terms of accessible centres, these sites meet the relevant requirements for villages.
In terms of the Public Squares and Spaces and Play, sports, Food Growing Opportunities and Recreational Facilities, in principle there is no objection to these. However, we would recommend that all contributions are agreed in the form of a Supplementary planning document.

I do agree that facilities and services would benefit new housing. However, I do not believe the council should be considering overloading existing facilities and services to already established villages. For example the village of Little Common and Battle facilities and services are already stretched to breaking point. Doing so would put unimaginable stress on those areas and others. Negatively impacting the lives and quality of those that already live in those areas. I would suggest that areas are earmarked for development that would provide new facilities and services for the new developments, which would also be shared with near small villages and developments that do not currently have their own facilities and services near by.

Whilst we agree that the draft Local Plan should seek for new development to be well serviced, flexibility must be provided so as not to preclude sustainable developments which do not meet the stringent test set out at policy LWL2. This is particularly important in the context of the current acute housing need in Rother.

We consider that the principles of local living should be embedded more broadly in the Local Plan, to reflect a longer-term aspiration and healthy and sustainable living, rather than being imposed as a restrictive policy requirement.

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.

Please refer to attachment

Q2. Council feels that both are key to our Community with equal priority.

Q24. Clarification of "all qualifying development" is sought.
Council would like to prevent pre-emptive works at sites prior to submission of planning applications.

Q28. Agree the principle but very hard to visualise dwellings per hectare. Particularly when looking at rural areas.
Examples in our location would be helpful ie number of properties in Coronation Gardens per hectare, for example.


Q30. Whilst we feel this is a positive ambition, this may be impracticle for a town such as Battle.

Q33. In agreement with proposals, but clear access must be available. Blackfriars access to Battle Railway Station is a point in case of outside site access.

Q34. Council should make developers responsible for access outside site compulsory.

Q35. Applaud this objective but would once again highlight the Blackfriars development not having easy access to the Railway Station which would make walking outside of this 400m proposal.

Q39. This is an important policy and Council would like this enforced. However, it is disappointing that the Blackfriars development has not been approved in accordance with existing Battle Civil Parish Neighbourhood Plan policies.

Q46. Council feels that consideration should be to all disabilities, not only dementia sufferers; such as less ambulant people and those with hearing difficulties etc.
In relation to play areas, these should be sited in an appropriate safe, central location.

Q64. The topography of the central area of Battle town does not lend itself to significant further dwellings to be developed within the development boundary.
There may be very small opportunties for developments outside the development boundary but within the 800m constraint.
Broadly speaking, the number of dwellings suggested seems to be most unachievable.
During the development of the Battle Civil Parish Neighbourhood Plan, despite calls for employment opportunity developments, there was only one response.

Q74. These policies should be strictly adherred to, to protect the environment.

Q75. Subsequent to this Reg 18 document, Council would like to emphasise that the "Fir Tree Cottage" site at Netherfield only has temporary permission for three years and must be returned to agricultural use.

Q76. We do not agree that Battle is placed in the "Greater opportunities for growth" column in figure 35. In main part due to the topography of the Civil Parish and, at best, should be placed in the "Medium growth opportunities".
We are pleased to see that Mountfield and Whatlington in our SDO have been recognised in the column "Limited growth opportunities".

Q104. We welcome this policy.

Q116. For planning applications where affordable housing is approved, following applications to change the conditions will be greatly deplicated.

Q119. Council does not agree with this policy. There should be a mix of housing - 'pepperpotting'.

Q121. We do not wish to see this, as above.

Q183. LAN3 paragrpah 3 should have roof lights added as an example of discouraged glazing.
Planning applicants should be encouraged to use electrochromic glass.

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.

Full submission 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.

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 see attachment