Draft HELAA Part1: Report: 1 Introduction
para 1.2 &1.3: Comment:

The HELAA is for the Rother District Local Plan (RDLP) 2020 - 2040, yet the Draft Version HELAA is only now out for consultation April - July 2024.

Q1 - The HELAA informs the Rother District Local Plan (RDLP), why isn't consultation with the public undertaken prior to the RDLP?

Q2 - Will the RDLP be published as 2025 - 2040 to incorporate the outcome of the HELAA?

Q3 - During the period of 2020 - 2025 there may have been sites approved that were not included in the previous Development and Site Allocations Local Plan (DaSALP) adopted in 2019, which had been subject to public consultation and accepted by a Planning Inspector. There has been a DaSALP since 2019 why was it not being used to steer developers to the sites identified by Rother District Council as suitable for development.
2 National Planning Policy position para 2.1 & 2.2: Comment:
'The overall aim should be to meet as much of RDC's identified housing need a possible' - which is for the residents of the area of Rother. The majority of which live in Bexhill where 45% of residents are over 65 years old, the 2nd highest in England.

Q1 - What factors have more than doubled the requirement of dwellings per annum in Rother, from 335 to 733. Especially when a Planning Inspectors Report in 2019 confirmed that the identified number of sites more than met the then identifed requirement?

Q2 - Will Rother District Council and in particular Bexhill be developed to provide housing for other area's outside of Rother?

Chapter 1 Bexhill North site id BEX 0112: Comments:
1 - In November 2019 the Development and Site Allocation Plan was adopted. BEX0112 is not identified in this plan as a site for potential development. This plan will be extant until the draft HELAA is adopted.
2 - In December 2023 the Developer submitted a planning application for approval which was refusedby the Planning Committee.
2a -The main reason given for refusal was that it was an inappropriate location for a housing development due to potential economic impact on the Brickworks and the various pollution generated during the 24x7 manufacturing process on the new residences.
2b - There are also drainage/flooding issues not identified during the scheme design both on and off site (adjacent and down stream). The photographic evidence of down stream flooding is a concern for the Pevensey and Cuckmere Water Management Board, as the situation is likely to be further compounded by developments currently in progress or planned together by land drainage schemes.
3 - In April 2024 BEX0112 is included in the HELAA as a site that is potentially available
4 - In May 2024 the Developer appealed the decision and an appeal is being held mid August 2024.

5 - In conclusion the site BEX0112 as identified, should not be included in the HELAA as it is the subject of an appeal by the developer.
The outcome of which will either be:
5a - approved and not now a site to be included in the HELAA as available for development.
5b - refused and as determined by the Planning Committee as not a site suitable for development, for the reasons given in 2 above.

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

Objections to HELAA site BEX0050:

1) Ancient Woodland. This site has or adjacent to an ancient semi-natural woodland since 1600AD (A5NW) being only part of the 15.5% left in the ROTHER area. which was included in the Inventory for Rother District ES survey report & inventory maps, printed October 2010. proposed and financed by Rothers head of planning David Marlow. This has to be preserved the report shows and explains this.

2) Infrastructure. The current sewage system serving Barnhorn Rd and Little Common was constructed in about 1950. It is 9 inch (23cm) in diameter. It was suitable for the amount of houses in Barnhorn Rd and Little Common built at that time. With no upgrades to the system and continued development over the years, it is at maximum capacity. The system is now not coping with the sewage. Consequently, during bad weather the raw sewage is pumped onto residents gardens. Further developments south of Barnhorn Rd would make this situation worse for Barnhorn road and Little common.

3) Balanced community. Building just houses cannot be justified without the additional shops, schools and doctors surgeries etc, just to achieve Rother’s 5 year housing target, which is at 3.09 years to date, this area cannot be traded off or sacrificed with its substantial biodiversity, habitat (including Badger sets and more) protected by Ramsar and "International Habitat Designation" policy including Pell level protection which i believe it falls into cannot be ignored.

This site is made up of farmland and partial scrub land,together with listed buildings, in spring of this year a Nightingale was resident here and nested. Sites suitable for this bird to nest in are reducing, loss of the habitat means loss of this species and many others in the Rother area.This site also contains an ancient pond which is the home to newts, frogs,and used by grass snakes and toads in the area.

This area is too important and needs protection for the future not eroded away to achieve housing targets.

4) Listed buildings. This BARNHORN MANOR AD772 site contains two ancient barns constructed of cobbled stones typical to the Bexhill area. They are grade II listed buildings, also 2 Barnhorn manor houses grade 11 built and established AD772.

5) Foot paths. There are several ancient foot paths in this area which need to be preserved in their many hundreds of years of history and not diverted.

6) Green field site. There is need for the country to feed itself, this is agricultural land which has been used since AD772 to sustain beef, dairy cattle and arable products Converting more prime land to housing the more the growing of food the more loss for the country to feed its self and the greater need to import.

7) Flooding. This area includes land that is in risk of flooding over the last hundreds of years. Also it acts as a sponge which absorbs and holds water reducing the risk of flooding in lower lands on the Pevensey levels (Hydrological Catchment). Developed into a housing development will remove the natural soil absorbing effect and revert to a runoff effect which would cause greater flooding and contamination to the Pevensey level Area.

8) Access to main roads. Proposed 340 houses and industrial area. potential of 1.3 vehicles per house hold = 442 + service vehicles,taxis and local transport plus industrial buildings.This site at present has no road link to the A 259. To access in and out creating higher levels of congestion and saturation to the A 259 having traffic increased currently with more local housing stock and industrial area would extenuate the present problem.

My wife and I object to the BARNHORN MANORS inclusion and for the above reason to have it removed from your proposed list of sites in your consultation

See the two attachments which comprise the representation from Bidwells LLP on behalf of the landowner of HELAA Site BEX0050: Land south of Barnhorn Road which comments on the Local Plan itself as well as the suitability of site BEX0050.

I would also like to comment/object that despite the many objections you have

Received these developments BEX0050 and BEX0159 are still being considered. l also do not see how Persimmon can develop such a large area without causing devastating effect on the infrastructure of the present residential area.

With a total of potentially of 1020 dwellings on the two sites, and an estimate of at least 4000 extra people it is too much for the facilities of the Little Common area.

Meads road is already a very narrow road and parking for residents and commuters is a nightmare and eventually Spindlewood Drive will be the same even worse as it is a cul-de-sac!

It already has an overloaded doctors surgery where you can wait four weeks for an appointment now a days.

Have some common sense!!!!!

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.

See attached representation regarding HELAA Site BEX0160: Land east of Fantails, Sandhurst Lane, Bexhill.

Developments: BEX0050; BEX0159; BEX0182;BEX0103; BEX0119; BEX0179; BEX0180; BEX0203; BEX0175;

Detrimental effect on the village of Little Common, Pevensey Levels, A259 (Barnhorn Rd section)

1 -Threat to Pevensey Levels. Potential of irreparable damage to protected Pevensey Levels, Ramsar, SSSI, SAC & ancient woodlands sites. The development of land involving the covering over of natural geology with impermeable materials and structures can reduce the amount of water being received and stored by the underlying geology. As a result, and without mitigation, there is an increase in the amount of overland flow, which means the amount of water being received in a shorter period of time creates greater volumes and velocities of water in the watercourses. Loss of vegetation in the catchment area of the Pevensey Levels would exacerbate this effect. The impact of development through the loss of permeability is dependant on the type of underlying geology and the topography.

2 - A259 congestion. creating high air pollution, safety issues to both walkers and cyclist.

3 - Lack of acceptable infrastructure

4 - Sewage system currently does not have compactly to deal with these developments

BEX0050 in particular (known as The Spindlewood Development) is simply not a suitable site for housing at this location. It would have major negative impact on Bexhill’s oldest recorded Historic site, possible irreparable adverse effects on the adjacent RAMSAR, SAC, SSSI & Ancient woodland site, as well as the overwhelming addition of traffic on Barnhorn Rd (A259) and the direct centre/heart of Little Common Village, with a real possibility of creating another accident ‘black spot’, not to mention, having a negative affect on the way people live, work travel and take leisure

HELAA Site BEX0050: Land south of Barnhorn Road

The proposed extra development once again shows a lack of supporting infrastructure. No thought seems to have been given to the access to the A259 Barnhorn Road. This road is already subject to considerable congestion with all the attendant problems of noise and pollution for residents. The sewage system is already inadequate according to Southern water. This and earlier plans will lead to the loss of part of my front garden, boundary wall and plant cover which gives us some relief from the road. Are we to add backed up sewage flooding our homes to this distressing list?

Please see attached representations document.

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

Please see attached representations document.

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

Please see attached representations document.

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

Please see attached representations document.

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

Please see attached representations document.

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

Please see attached representations document.

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