The cumulative effects of new building needs more forethought. The main A259 road is already becoming overly busy, even during off-peak hours. St. Mary's Lane and Ellerslie Lane have significantly increased traffic volumes since the link road was built and these lanes are now used as a "rat-run" through route. Neither lane has any provision for a safe pavement. Junctions will be challenging to the point of being unsafe if adequate traffic impacts are not fully considered and dealt with at an early stage. Turning right onto the A259 from Broadoak Lane is already very challenging as it is on a bend and a hill with some limited visibility especially due to the high speed of many vehicles. These impacts on road safety are imperative for strong action.
Other roads locally are already under more pressure. Before we reach gridlock, more research should be done about cumulative traffic pressure.

Please see attached submission

It is my view that the proposed development of West Bexhill, particularly West Little Common, flanking the A259 behind existing homes will destroy the Village. Threat the Pevensey Levels, lack suitable infrastructure, from school places, doctors, water and many more. Also would create a high level of air pollution in the area. We are already suffering from the stand still traffic along the A259.

Its obviously a terrible idea to permit traffic to access the A259 via meads road and cooden sea road. Plus we have nearly run out of water in this area more than once in the past few years.

Please see attached comments from Burwash Parish Council.

Potential development sites close to Wealden’s boundary:

The most significant impacts of growth to Wealden would be in areas close to the district’s
boundary. We are aware that RDC has and will continue to consider sites in areas close to
the WDCs boundary, particularly to the north and west of Bexhill. The vision for Bexhill
within the draft Rother Local Plan (page 123) confirms that there is potential to deliver a
minimum of between 2,163 and 3,398 dwellings in the Bexhill sub area with the vast
majority of those dwellings coming forward to the north and west of Bexhill (only 298-353
dwellings within the urban area).

We note that there are no draft site allocations in the Regulation 18 version of the Plan.
Whilst we recognise that the site allocation process is still in an early development stage, it
should still be possible for both Council’s to discuss and consider the detail of the impacts of
potential sites close to Wealden’s boundary, including the cumulative impacts on the key
routes within the transport network such as the A259 Strategic Road Network and other
secondary routes into Wealden, along with wider infrastructure impacts. We note that RDC
is currently carrying out a further ‘Call for Sites’ and is being proactive in looking to see if
there are additional sites that will be put forward to be considered through the HELAA as
part of the new Rother Local Plan. We would also suggest that RDC revisits all the sites
previously submitted to ensure the Council has exhausted all avenues, ‘leaving no stone
unturned’. We welcome the opportunity for cross-boundary joint working on this matter.

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.

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Rurban Estates Limited.

The full submission comprises of:
- DHA Response to RDC Reg 18 Draft Local Plan; and
- Site Location Plan

Please see attached letter with representations on the Regulation 18 consultation. The representation includes general comments in addition to responses to a number of questions raised within the Emerging Local Plan.

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.