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.

The most distinctive aspect of Rother is it greenfield so any proposal to build on our greenfield will destroy what makes Rother so distinctive.

Please see attached comments from Burwash Parish Council.

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.

Full representation attached

Please see attached document for the full submission from Westfield Parish Council.

See attached full representation

Please see attachment

Please see attached submitted document for full comments.

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

We welcome most of the draft Local Plan, although there are points of particular concern for us which we describe below.

For clarity, as there are two different versions of the Local Plan draft in circulation, the text and page numbers mentioned below relate to the ‘Cabinet version” of the Local Plan found at:

https://rother.moderngov.co.uk/documents/s9244/Appendix%20A%20-%20Rother%20Local%20Plan%202020-2040%20-%20Draft%20Regulation%2018%20Version.pdf

- Housing allocation for Hurst Green (p.148)

Unless and until the village is bypassed from the A21, we feel we should not be the subject of any more major housing developments (i.e. of more than five houses) because of the exceptionally heavy traffic we experience. For substantial parts of the day there are lorries and cars passing continuously through Hurst Green, one approximately every two seconds. That means high levels of pollution and noise; it means anyone turning into London Road often has a long wait and dangerous exit; or if they are turning from London Road into their driveway they cause significant traffic to build up behind them. All this is set to worsen when the 26 new houses at London Road West (RR/2021/2798/P) are ready. Ditto the 20 houses being built at Foundry Close (RR/2019/2194/P) and if the 28 houses proposed at London Road East (RR/2022/1526/P) are built.

New village housing should above all take account of the nature of the village. Quotas and allocations should not be made on a population basis. They should be made where the landscape, the roads and townscape make development sensible, convenient and sustainable. New village housing is only appropriate where there is walkable access to a GP or chemist (we have neither), where children living in the new houses can be walked to school on adequate pavements (ours are narrow and unsuitable for families), where the roads are relatively safe and where lorries are not always thundering past, where the village has an obvious and thriving central core and hub, where good quality shops and restaurants can be walked to, where if you’re in a car to shop or dine out on the main street you can park. There are lots of villages in East Sussex that fit this bill. Until it is bypassed Hurst Green cannot be one of them.

- Construction waste being dumped on farmland for profit (pp.39-40).

Building-waste dumping is a significant problem around the villages in the north of Rother because it is lucrative for the farmers and landowners who allow builders to do it. If Rother’s planning permission rules were changed so that new buildings could not be occupied until planners were content that waste had been disposed of correctly it would discourage landowners from allowing these waste dumping trucks onto their land. We think there is scope under the 2012 (no. 767) Town and Country Planning (Local Planning) (England) Regulations for Rother to add such planning conditions to its ‘development management policy’ under section 5, para 1 (a) (iv) of the Regulations.

- Solar panels on roofs

The Local Plan says (p.47) ‘Proposals for roof-mounted solar energy supply infrastructure will be supported and encouraged wherever possible, subject to other policies and Policy HER1 (Heritage Management)”. Policy HER1 is an admirable policy designed to protect heritage assets but it is vague and subjective. We think that the Local Plan should oppose solar panels being added to a visible roof on any listed building in the High Weald National Landscape, because they tend to compromise the character and appearance of historic buildings. We think the same should be true of any Victorian or Edwardian building within a conservation area within the HWNL (such as in central Robertsbridge or Burwash). We also think there is a case for requiring planning permission for mounting solar roof panels on a non-listed building if it is adjacent to a listed building.

- Design of new buildings

Page 80 of the Local Plan says that new development should be visually attractive, understand and respond positively to local landscape and townscape character and should “conserve, enhance, and draw inspiration from this context and character in either a traditional or contemporary style”. We do not feel this is clear or strong enough guidance for developers. We would like to see the Plan say proposed developments in the High Weald National Landscape will be refused planning permission unless they can demonstrate they have followed the High Weald Housing Design Guide. Developers should be required to identify local design features that characterise the village or landscape they are building in and show how they will adopt these features. We would also like to see the Local Plan say that in the HWNL ‘contemporary style’ buildings would only be permitted where of truly exceptional quality and where a traditional style would be manifestly unsuitable.

- Wind farms

On page 45 the Local Plan’s policy wording says that wind farms will be supported if ‘they will not result in significant adverse impacts on landscape character that cannot be satisfactorily mitigated, including the High Weald National Landscape; trees, woodland and hedgerows; agricultural land use and local heritage.” The explanatory text on p.46 says “The opportunity for the development of wind turbines within the district, is extremely limited and is not appropriate in, or within the setting of, the High Weald National Landscape.”

We would like to see this language toughened and made clearer. There can be no satisfactory mitigation of a 300ft high wind turbine in our exceptional landscape. We would like to see the policy wording rewritten as “Wind farms will not be permitted in, or adjacent to, the High Weald National Landscape because they undermine its outstanding natural beauty and historic character.”

- Solar Farms

Pages 45 and 46 of the Local Plan say that “Stand-alone ground mounted solar installations will be supported, subject to other policies, on previously developed land or where evidence of community support can be demonstrated….. Stand-alone ground mounted solar installation opportunities are limited within the district, however a policy that supports suitable schemes in appropriate sustainable locations, with community support is necessary.”

We do not share the view that there are any opportunities for solar farms in the High Weald National Landscape that would not cause visual damage to the landscape and surrounding heritage assets so we would like them ruled out altogether in the HWNL.

Thank you for forwarding this document: below are our comments on policies - together with a supporting rationale.

2.13
Q2, Q3
Agree the principles embodied in 2.13.

 A ’green to the core’ approach should deliver better ‘living spaces’ for children and future generations.
 Compact and less ‘car dependent’ developments should flow from this with a strong emphasis on exploring and expanding ‘active travel’ opportunities and integrated public transport measures - bus/rail.
 The greatest efficiencies will fow from integration of ‘transport’ and ‘land use’ policies that will secure benefits for public health (both mental and physical), environment, social equity, economy - while addressing the twin crises facing biodiversity and climate change. Perhaps the greatest benefits would accrue from ‘traffic reduction’.
 We welcome the very sensible approach of having a joint statement from Hastings BC and Rother DC (the ‘wrap round’ authority). The future ‘district-wide’ and ‘neighbourhood’ infrastructure should include and prioritise sustainable/healthy modes of transport with incentives to use them and with an objective to reduce numbers of vehicles. Successful delivery also requires close working with the Transport and Health authority - ESCC.
 Good publicity to apprise residents, visitors and tourists of non-car modes available to access attractions should be standard - it currently is hugely variable from the useless through mediocre to excellent: it should be standard practice that sustainable transport opportunities are featured in well designd and attractive publicity material.


Q4 Q5
Agree principles. Opportunities that arise from reducing traffic (numbers of vehilcles) would include alternative use of land for a multitude of purposes including housing/nature /acquifer replenishment/childrens’ play/economic activity.

Q6/7/8
Given higher standards are ‘coming down the track’ and that we have a new national administration we might hope for re-energising/accelerating more ambitious energy saving solutions so RDC and all of us might well be prepared (and wish for ) a more nimble approach to delivery of ‘best available’ practice.

We note that although a building or larger housing development may be high performing, if it remains ‘car dependent’ it can hardly be described as sustainable.

Q9/10

Support ambitions for ‘retro-fit’ standards. Reduced car use/increased sustainable mode take-up would free land in existing settlements if provision is made for pedestrian/cycle/bus/train facilities.




Q17/18/19

Support expansion of solar/wind generation subject to landscape/heritage considerations. Rooftop solar is perhaps less obtrusive.

Q20/21

Welcome the focus on ‘nature recovery’. 3.39 recognises that securing ‘designated sites’ is insufficient as a means to securing recovery: the wider countryside (and well managed urban areas too) are crucial if populations/species are to thrive. We note that some areas with notional protection (for example semi-natural ancient woodland of which the HWAONB/HWNL has much) is nibbled away at so needs greater protection and monitoring. The entire east Rother catchment with its many streams also needs protection and monitoring.

Q22/23/24

Yes, go above minimum; developers’ intent to create compensatory gains against damage to existing habitat has to be independently assessed by a third party and monitored over time. Noise and light impact should be taken into account.

Q25/26

I have an interest in the HWNL as I am the owner of 6.02 acres of semi-natural ancient woodland (Fleetwood) and grew up in Etchingham between the Limden and east Rother. It was a wonderfulplace in which to spend my childhood. I accumulated quite a bit of knowledge - flora, fauna, geology, secret places and much of this was on my daily walk to school and back. Much of this environmental capital is intact but the lanes are no longer tranquil or safe places to be and the growth of traffic now limits childrens’ opportunties to learn and therefore love what’s there. Lanes have chewed up verges and ruts - restricting refuge - and taking away childrens freedoms. Add to this the sheer power and size of vehicles and the knowledge that mobile phone use while driving is endemic, the HWNL has suffered and quality of life diminished. Noise is often present with driving styles on two or four wheels tailored to maximise it: the noise footprint is up to two miles in radius. The HWNL is still beautiful but tarnished. It’s not OK. The Plan might usefully attempt to address these issues via its officers and elected members.

In the past, the High Weald Heroes inititiative to apprise its children of the elements that make it special seemed to be a good scheme and might now be expanded to include partnership schools in urban areas to spread the understanding and appreciation of such elements more widely so as to recruit more guardians of the future. Education initiatives could be included in the Plan. Health benefits would accrue, particularly for mental health.

In terms of offering safe walking/cycling family holidays, the HWNL doesn’t perform nearly well enough. Bus and rail connections have improved a little through BSIP but not enough. Adding Eurostar again to access via Ashford would help. Bus rail integration south of Tunbridge Wells is under exploited.

Q27/28/29

Agree with principles and threads.

Q33/34/35/36/37/38

Agree with principles. Flared junctions should be avoided. Cycle/pedestrian priority across junctions should be adopted aas policy. Cyclops style roundabouts should become much more commonly adopted as standard.

Q39/40/41

Agree with principles. 20mph default speed in residential streets and streets with strong character/heritage value would all be safer. Burwash example.


Q42/43/44

Agree with principles.

Q45/46/47

Agree with principles. Stimulating and supportive of social cohesion/mental and physical health objectives. Traffic must not dominate. Conversation is ioften impossible if traffic/vehicle noise pervasive.

Q48/49/50

Too much parking is simply more unnecessary road space: there will be induced traffic. Hard standing can contribute to flooding and denies the acquifers natural replenishment.

Q51/52/53

The ‘A21 development corridor’ presumes the road as the key to likely development sites and suggests road based accessiblity will therefore be key to any development’s success. That sounds a little like ‘business as usual’ However, it can’t be allowed to mask under and unexploited opportunities for movement of people by bus and rail and more locally by electric/conventional cycle and via good, safe pedestrian and cycle links.
The first Multi-Modal Study (2000) found that 68% of traffic on the A21 in the morning peak originated from south of Tunbridge Wells. It would be prudent to examine the potential for bus links to and across the Charing Cross - Hastings railway line to broaden the footprint of public transport accessibility. For example, the A265/268 could give access by bus to the train at Etchingham for Hawkhurst - Hurst Green and Burwash residents/visitors/students. This could also reduce car dependency in any village expansion developments, moreso if accompanied by supportive parking policies in urban centres. Your plan envisages the possibility of a future with less land given to car parks (and hopefully an end to free parking). This could follow future road user charging in whatever form it eventually takes.

Cars are getting bigger. Edge of town developments often feature generous parking spaces and these are often occupied by large SUV type vehicles. We strongly feel that these vehicles are not compatible with high quality living spaces and that there should be strong disincentives aimed at reducing their often intimidating presence in our streets and country lanes and anywhere near our schools.

Q54/55/121

General points:

There should be a strong component of public housing for rent; a strong component of truly affordable housing; a comprehensive cycle network that includes chldrens’ routes to school; 20mph default limits in all residential streets and dsitributor roads where appropriate (it will sometimes be appropriate). An absence of flared junctions and ‘cyclops’ roundabouts if a roundabout is deemed necessary.

Bus services under the new administration can be franchised by the transport authority. There could be some creative dialogues around services that RDC/ESCC feels might be improved by new/enhanced or extended routes.

It remains to be seen whether or not developers will still be able to renege on agreements around any form of planning gain. New policies will emerge that might benefit the community.

Q71

The ‘A21 transport corridor’ can only be examined as a multi-modal study. I already commented at Q53 but would add: there’s no bus connection between Etchingham station and Hurst Green which is a problem for locals (Management of The George - Ruth Hardy: theroyalgeorge@gmail.com).

Q72

Rother’s outstanding countryside is impaired by too much traffic with its associated negative impacts not the least of these being noise. The ridges and valleys are features that give much joy: it is hoped that the streams and rivers are unpolluted but reassurances are needed. In the case of the locally important Conquest Hospital, buses are severely delayed by queuing cars blocking access to the hospital entrance from The Ridge.


Q80

Sustainable transport provision should be designed with cumulative impacts and needs of neighbouring developments in mind. Not sure this has happened in north and West Bexhill (bus delays between Little Common and Northeye suggest that priority measures could have been installed ahead of development).

Q93

The ‘cooling effect’ of trees/shade and planted areas within urban settings is known and should be a factor in development plans, along with rainfall retention against flood risk.

Q98

Agree importance for young and old to have access to community facilities. Youth clubs’ demise has left a gap. These should be accessible by public transport/foot/cycle.

Q 104

Agree public rights of way/cycle routes hugely important for utility and leisure/education functions. These can afford great days out and should be part of the tourism leisure strategies and publicised in conjunction with public transport access in mind.

Q107

CVCP straddles the Bexhill - Hastings Link Road. Tranquillity has been lost to a large extent, but a 40mph speed restriction and acoustic cameras to deter noisy two/four wheeled vehicles would go some way to conferring on the valley some of its lost charm. The nationally important Bronze Age site seems to absent from any publicity.

It is important that any development that takes place is sustainable, supported by suitable infrastructure and protects and wherever possible enhances the local environment. Working with parish councils to ensure planning priorities are supported by local communities is key, and Neighbourhood Plans are central to this.
Whilst it is important that we provide new homes that local people can afford to buy locally, affordability and supply concerns should not override everything else. Similarly, eco-friendly design should not be the sole consideration- beauty and a design code in keeping with existing design elements are also important.

I note that ‘delivering district-wide and neighbourhood infrastructure to support growth, and strengthening the sustainability of settlements and communities’ are identified as key planning issues. It is essential that the local transport infrastructure and services fully support these ambitions, if they are to be achieved.

I support the Council’s vision that future development should support biodiversity wherever possible.

To alleviate flooding risk and support bio-diversity net gain, application assessment, monitoring and planning enforcement are as, if not more, important and require greater resources going forward.

Please find below some specific concerns and issues I want to raise regarding housing, the environment and sustainability, infrastructure and services, stakeholder and community engagement, as well as some final economic considerations.

1. Distribution of Housing:

There appears to be a heavy concentration of new housing developments in certain areas, such as Bexhill North, while the Urban environment appears to have a lower housing growth potential. This may lead to overburdened infrastructure and services in certain areas, while others remain underdeveloped.

2. Affordable Housing Provision:

The plan sets a target of a percentage affordable housing. I welcome the Plan’s commitment to ensure “that a sufficient number and range of homes can be provided to meet the needs of present and future generations”. However, consider:

Affordable Housing targets: The plan mentions the provision of affordable housing, but specific numbers and how they align with actual need (e.g. population growth) need to be clearer.

Viability and Delivery: The plan allows for financial contributions in lieu of on-site affordable housing under certain circumstances. This could lead to fewer affordable homes being built in practice, as developers might prefer to pay contributions rather than integrate affordable units into their projects.

3. Environmental and Sustainability Concerns:

Several allocated sites involve greenfield land, raising concerns about environmental impact and sustainability. As the proposal notes, it may be necessary to develop on some greenfield land to meet targets, however redevelopment of existing brownfield sites should be prioritised.

The importance of local beauty: As stated above, while eco-friendly design is undoubtedly crucial, it should not be the only consideration in our planning process. It is equally important to ensure that new developments adhere to a design code that emphasizes local beauty, aesthetic appeal and harmony with existing architectural elements. This will preserve and enhance the unique character and beauty of our communities.

Impact on Green Spaces and Agricultural Land: Some site allocations may involve the development of greenfield sites. This might conflict with some sustainability goals and local opposition from communities valuing these green spaces. Likewise, it is necessary to make sure that adequate infrastructure, connectivity and services exist for further development in these areas.

4. Infrastructure and Services

The Infrastructure Delivery Plan identifies the need for significant investment in transport, education, health, and utilities to support the new housing developments.

There may be insufficient planning for the necessary infrastructure (e.g., roads, public transport, schools, healthcare) to support the new housing developments, particularly in areas seeing significant growth. The Plan acknowledges the needs of older people and individuals with disabilities, so the link between housing and infrastructure provision in local development need close attention.

5. Community and Stakeholder Engagement

The document acknowledges the need for ongoing consultation with local communities and stakeholders to refine site allocations and development plans. However:

Expanding community Involvement: The process of site allocation may not always have met community expectations of involving local communities and stakeholders, leading to decisions that do not fully reflect local needs and priorities. It would be ideal for the proposal to outline the specifics of how consultations regarding new housing will be carried out to maximise the input of local communities.

Transparency and Justification of Choices: The criteria and rationale for selecting specific sites over others may not be clear to local communities, leading to potential criticisms of bias or insufficient justification. This may cause undue concern in local areas, where residents may feel they are excluded from decision making but have the most impact.

6. Economic Considerations:

Economic Viability and Job Creation: While the plan includes employment floorspace, it is crucial to ensure that these developments will genuinely lead to job creation and economic benefits for the local population. There should be a clear link between housing growth and employment opportunities. The housing strategy could detail the steps taken to improve employment opportunities in local areas; which would mean residents have shorter commutes and thus less strain on the transport network.

I also welcome the Plan’s support for diversification of traditional rural businesses as basis for development in our countryside and planning aims.

Finally, consideration should be given to further ensuring a diversity of employment types are supported e.g., higher skilled/technical opportunities as part of this.


These points highlight potential areas for further scrutiny and discussion to ensure the local plan is comprehensive, balanced, and meets the needs of all community members effectively.

Please see attached representations document.

Please also see StoryMap detailing Gladman's portfolio of using the following address: https://storymaps.arcgis.com/collections/315747d6c3ef40069b1b886958aaedaf