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.

As acknowledged in the plan, community resilience to the impacts of climate change is essential. We also note that the ENV2 policy on sustainable drainage is proposed as a non-strategic policy, but that this LWL5 strategic policy includes the ‘stewardship’ arrangements that can often apply to sustainable drainage systems. Southern Water strongly supports the inclusion of sustainable design principles within planning policy. For the reasons explained further below, we would therefore like to see this policy go further and include sustainable urban drainage features in the design requirements for all development. We therefore request wording is added to strengthen the effectiveness of this LWL5 planning policy, as explained further below:

Requested changes:
(iv) Existing Assets. Use existing assets as anchor features, such as natural drainage routes and mature trees, and …
(vi) Futureproofing and Safeguarding. Ensure that land is reused/used efficiently, effectively and ensuring resilience to future impacts of climate change, and… For planning permission to be granted, applicants must demonstrate that sustainable drainage is an integral part of the proposed development and its design.

Further explanation and justification:
Southern Water supports all policy requirements which seek to ensure that surface water is appropriately managed, as close to source as possible. We need planning policy to consider carefully the measures called for in response to the climate crisis, and ensure sustainable development is central to the local planning framework for planning applications coming forward. This is also in line with the requirements of paragraph 167(c) of the NPPF (2023). Measures should support the attenuation of flows of surface water run-off from rainfall, as well as surface water infiltration into the ground wherever possible in the local environment. Please see our policy statement on Sustainable Development here:
https://www.southernwater.co.uk/media/ny0nb3qu/our-policy-statement-on-sustainable-development-a4.pdf

Southern Water is working across our region to remove surface water from our networks in key areas. Even as we deliver this work, development continues to increase surface water run-off. To be resilient to the evolving impacts of climate change we must plan to ensure that rainwater is separated from wastewater in the design and construction of our communities. For more information on our work, and the root causes of releases from storm overflows, please see –
https://www.southernwater.co.uk/our-region/clean-rivers-and-seas-task-force/pathfinders/
https://www.southernwater.co.uk/our-performance/storm-overflows/storm-overflow-task-force

Over time, the expansion of urban settlements as well as ‘urban creep’ (home extensions, conservatories and paving over front gardens for parking) have incrementally added to the amount of rainwater entering pipes and storage tanks connected via roads, roofs and paved areas. As stated in Water UK’s 21st Century Drainage Programme;
“The country’s built environment is constantly changing and “urban creep” – home extensions, conservatories and paving over front gardens for parking – can all add to the amount of water going into our sewers and drains. Green spaces that would absorb rainwater are covered over by concrete and tarmac that will not. In fact, studies show that “urban creep” results in a larger increase in predicted flooding than new housing, because it adds more rainwater to these systems’.
Stronger integration of sustainable drainage solutions within policy should ensure SuDS are incorporated into new development and public places, whilst also securing truly sustainable development.

Preamble:

I am submitting these objections to the Local Plan. Whilst I do not doubt that the local plan has numerous errors I am only addressing 'The High Weald Housing Design Guide' and its cross over's and implications.

Under Regulation 19 I wish to attend the Public Hearing held by the Planning Inspectorate so as to make personal representations. I require notification, in good time, by you of when the Inspectorate, in regard to this local plan, will issue the guidance Notes and the accompanying structured questions, with an internet link to them, thank you.

OBJECTIONS TO LOCAL PLAN:

High Weald Housing Design Guide' (HWHDG)

a. The 'High Weald Housing Design Guide' has been adopted into Local Council Plans in 2019. There were 3 consultants used on this guide, two are Surveyor (RICS) Town Planners and one is a Landscape architect and Archaeologist. But no Architects nor the RIBA have been used. Thus competence is absent in respect of Architecture. As this document is a Housing Design Guide in relation to aesthetics i.e. Architecture it is invalid as an authoritarian document.
To reiterate Landscape architects, archaeologists and RICS Town Planners or historians have no qualifications in Architecture. They are not competent as Authorities in Architecture.

b. In the Guides forward by Merrick Denton-Thompson, he claims that the High Weald Landscape is a "Medieval Landscape*" with an emphasis on preserving this delusion.

This Medieval Landscape claim is repeated in the Introduction of the guide.

c. In the guide it states "provides an objective approach". This is fanciful at best and wrong on multiple occasions. Objectivity is the reserve of the hard sciences and even they do not claim absolute objectivity but always qualify their laws with "as far as we know". That the word 'Objective has been used for some time in publications like 'Guidelines for Landscape and Visual Impact Assessment' pub. Spons. All this means is, it just has an uncritical readership or publisher. As an example of its lack of objectivity :- as an overriding principle it uses an 'Iterative' design approach. This is a process known to compound errors and that's exactly what it does. Hardly Objective.

Lets look at some of this objectivity in relation to the Medieval claims of the Guide(HWHDG).

The Medieval Period is from 4th century to 15th century between the Roman Occupation to the start of the Renaissance. That's about 1,000 years. Which part of the 1000 years does the guide refer to? e.g. If you look at different time periods- at the Anglo Saxon compared to Norman buildings they vary considerably. Many Anglo Saxon Buildings had basements or semi basements where are these in the guide? . The Anglo Saxons had large halls where communal living took place- where are the communal living accommodations in the Guide(HWHDG). Where are the building forms such as for example the Hall at Yeavering? or where are the structures of buildings like that in the Guide? Where are the elevations of buildings like the 'Jews House' at Lincoln; Where are the Norman arched stone windows with triple lights such as the Jews House has? They are nowhere to be seen in the Guide.

The Guides (HWHDG) selection of Architecture and its components are so limited as to produce tiny bubbles of what really existed during the medieval. Notwithstanding that precious little is known about domestic buildings during the medieval period especially the early period. The guide produces another spotted illusion of the reality of those times. The houses currently being built and reproducing these elements /components are being done on mass, in far greater quantities than they ever were in the medieval. What is currently being built is not even reproduction but disproportionate copy catting with random additions.

When asking for a reproduction you are really asking for a falsity. It gets worse as the actual House designs now being passed are a mish mash of the Guides(HWHDG) recommendations whilst using current technologies and materials all with a fake it up, copy cat ethos. This may mimic government culture but does this produce a healthy, worthy Culture? Quite clearly -NO.

d. Whilst the AONB has statutory protection S85(1) Countryside & Rights of Way Act 2000 "...........a relevant authority shall have regard to the purpose of conserving and enhancing of the natural beauty of the AONB" .This is does not extend to the building design per se. A Conservation Area is a separate legal designation.

The Guides introduction also claims to 'conserve and enhance the beauty'. But it does this for any buildings proposed and not just in the context of the wider landscape. It tries to bring the 'Guide' into the realms of 'A Legally designated Building Conservation Area' and a AONB is not, automatically, under Building Conservation Area Law. To repeat, the guide is pushing conservation ideas which can really only apply to Legally designated Building Conservation areas and historic buildings. That is the guide is a subversive attempt to turn the AONB into a Building Conservation area.

e. The HWHDG should concentrate on a 'landscape guide' Produced by Landscape architects but it has turned itself into a 'housing guide' for which Landscape architects or RICS Town Planners are ill qualified

f. As a Housing Guide it has no legitimacy unless it is expressly approved by the RIBA and not separate individuals or groups. Landscape architects can, are competent, to design the land around and with a building but they can not, are not competent, to design the building. They can fit the land to the building but they can not reverse the process to fit the building to the land . They are not qualified . 'Architect' is a protected title, it has been in place for a long time despite political and legal challenges, and for good reason.

g.(i) The Guide(HWHDG) ignores the pre Medieval and all history from the Renaissance onwards!. A glance at works such as 'A New Historical Geography of England' by H C Darby' pub CUP should dispel any ideas that the English landscape has not significantly changed and changed again and again over the Medieval period and over the Modern History period etc. Take for example:- compare the (1087)Doomsday book population of 1.5 million with today's population of 68 million and the exponential housing growth, that has caused on the land to be extensively built on in all areas. E.g. what about the effect of some 5,000 Enclosure Acts on the land/fields and so it goes on multitudinously.

(ii)Any guide can not be retrogressive with preservation as its key note as change is inevitable and architecture that brings people into the time they are living and offers hope for the future is not just beneficial but a necessity for mental health and social progress. An environment that predominates and accentuates the living in the past and the fantasy world it requires is no doubt a part of why mental ill health is so great in British society and locally. 30% of the UK populace suffer a Psychopathology every year ( the charity MIND) and it's getting worse. Being in the present is exonerated by all Psychologies e.g. Gestalt, Medical ADD & ADHD and Dissociative Disorder Psychiatrists and psychologists

h. Why does the High Weald Landscapes (AONB) history start and stop with the Medieval period? Anyone in touch with reality knows that it does not but that the landscape is continuous from earths habitation to the Present day. The Guide(HWHDG) attempts to stop history and in so doing creates a Fraud & Fantasy.

i. The examples (HWHDG) of the Oak Heights (the photos on the Guide cover etc.) estate in Northiam . This is exemplified as high level design by the Guide. These houses are timber framed and fail the durability test (60 year life) and require them to be rebuilt six times as compared with a standard brick built building. The so called white timber weatherboarding panels are actually cement, a fake it up component. The chimneys on the houses are not connected to any fireplaces they are also fake. Deception is the name of the game. The houses on the estate are also shoddily built and degradation of the environment is inevitable without heavy maintenance an uneconomic consequence.

j. The Guides(HWHDG) choice of materials is also limited with a bias emphasis on the 'Decorative'. Where in the Guide is Asphalt for instance. It's been used since Sumerian times and was in extensive use ,during the Renaissance, in the Sussex costal areas because of ship building. It would have also been used for waterproofing such as roofs.

Where are the daubed and smudge pointing common in stone and brick buildings (see Jews House).

As the design guide debars modern, by implication not just in the it has to be medieval, building so are the material innovations that go with it.

k. Medieval Woodlands ranged from 5% land coverage, whereas in Sussex today we have 20%. Perhaps in line with this scenario the Design Guide creators want to revert to the 5% tree coverage as being OK?

l. Then there is the iron & smelting industry of the Weald and all the other industries from the Renaissance onwards and the effect that has had on the landscape and building and the precedent it sets. These are some more examples of historical building that the HWHDG ignores

m. The detail in the guide needs to be gone into much more than I have done here. However when one does go into it, it becomes clear, as addressed above, it fails its intended purpose. Very little of what is stated in the Guide is sufficiently comprehensive, as to be adequate to guide the building design of housing, and can thereby be misleading.

n. The HWHDG is being used to fail planning application and this extends into DEFRAs Inspectorate. This is insidious and a Tyranny. Any housing guide is at best only a jumping of point for designers and nothing like a definitive set of principles to judge a scheme.

Summary:

(i) This Guide (HWHDG) is not approved by any competent Authority i.e. The RIBA. Other bodies such as the RICS, Town Planning Institute, Institute of Landscape Architects nor Historians- none of which are Architecture experts (Architect is a protected title) of which 'Housing Design' constitutes a part.

(ii) This Guide gives an extremely false, biased and limited view.

(iii) It's results are a fake environment and poor quality design.

(iv) 2% of the housing stock are listed buildings and all medieval buildings are historic buildings. Thus the medieval HWHDG ignores 98%* of the buildings, now in existence in England, constructed in the Renaissance and Modern History period (the last 500 years) and the developments of the Modern World; thus it not only considers 98% of the housing stock as irrelevant save that it may have a coincidental applicable element/s, it oppresses progress and innovation.

* It is taken that Sussex and High Weald generally has the same proportion of historic buildings as does the rest of England. i.e. 2%

(v)The Guide is produced with limited imagination and does not address the required skill set, and learning, that Architects develop as part of the necessary application of design to the real world ; of which perceptual development is a part.

(vi) The Guide (HWHDG) is ill conceived.

(vii) That this guide is being used to fail peoples planning applications by both Local Authorities and the Planning Inspectorate alike, makes it an oppressive document a Tyrannical Document. It's a piece of rubbish.

Requirements:

1. The HWHDG should be scraped. Certainly it should have no weight on deciding a planning application. The HWHDG is being used as a back door to apply design idiosyncrasies of the planning department and friends.

2. Any housing design guide should be RIBA approved, no other body are building design experts. Pretence by other Institutes or bodies should be shunned.

3. Formal adoption of the HWHDG is a fraud. Frauds are not permissible. Complicity is a crime.

4. Promoting Mental Ill Health must stop. By pushing people into a fantasy built environment of the past. An environment that portrays the Present and present cultural development are a necessity.

5. Be aware of the Human Rights Act(HRA) Article 6 'The Right to a Fair Hearing'

6. Be aware of the HRA to Property Article 1 Protocol 1 and the interference of 'design preferences' by the state over the 'Peaceful enjoyment of the Land' by its owner.

Please see attached comments from Burwash Parish Council.

Please refer to attachment

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