How can you have agreed development for Guestling Green with poor sustainability? Additionally why is there no mention of another development, a rural Exception site at Fairview which is equally unsustainable? It beggars belief that you can consider such development when there is no infrastructure to sustain such developments.

Q1.

Sadly the vision feels unachievable. Rother Officers avoid dialogue or face to face contact with some residents, who as a result have little trust in RDC’s integrity and competence. Disillusion with poor quality planning includes perceptions of cronyism and corruption. How will an infrastructure baseline be established? For example “Sensitive, sustainable and well-designed development that meets local housing and employment needs will be complemented by the timely delivery of supporting infrastructure.” RDC should revisit past developments that fall short of this criteria, where community complaints have been high. In Fairlight Cove we’ve lost amenity for 2 years caused by a poor quality, cramped, steep development of 16 houses. Residents dispute it’s built to the planning consent approved on appeal by the Planning Inspectorate. Storm overflows cover the lane with sewage, before the 16 new houses are even connected. A resident survey describes the gridlock of parked vehicles on our bus route, obstructing junctions and folk struggling to get on/off their driveways. Over decades there appears to have been no imaginative attempts to meet village overflow parking needs. For example removing wide grass verges to create parking spaces. We can’t see strategic joint working by RDC with our Parish Council. Our precept has increased by 40% in the past few years without extensive consultation and Parish Councillors spend our tax on their high running costs, meetings and social projects for retired people that duplicate existing locally funded voluntary sector provision by professional staff. Accountability and evaluation systems are lacking for Parish Councils to maintain infrastructure. Parts of Fairlight are lanes with high numbers of walkers, no pavements or footpaths, very few seats and signage clutter. A baseline study would show village assets in poor repair, with an increase in vehicle movements. Parking and speeding are increasing problems. Results from the 2023 Parish Council Residents Survey are not in the public domain. In relation to ‘Quality of Life’ residents regularly state a priority is public toilets. The decision by RDC to not cover the cost of public toilets at our local beach and in Rye indicates how removed you are from meeting basic expectations and needs of your residents, visitors to our area and local businesses.

Q2.

‘Conserving and enhancing the significant landscape and environmental quality across the district’ It would help if RDC insisted on professional quality Construction Management Plans or contractors signed up to the ‘Considerate Contractor’ Scheme. Also if RDC Enforcement Officers were resourced and supported to penalise construction sites in the same way they penalise residents or local builders, especially for radios, drug use and aggressive behaviours on site. Planting Management Plans and TPO’s are ignored, trees and hedgerows are cut, with no apparent penalties. Residents are encouraged to provide free labour to report alleged breaches of planning consent, but then Developers break the rules with impunity. The perception is that Rother Officers are too close to Developers, whilst being unwilling to meet with residents. There appears to be no monitoring of what the CIL funds are spent on in parishes in relation to the exisiting Local Plan and no minimum standard of “community consultation”.

Q3.

‘By supporting strong, safe and sustainable communities’ In Fairlight Cove there is a minimal bus service, which unfortunately can be disrupted at very short notice by road closures. Leaving school children or people without mobile phones disorientated and abandoned. Plus there is poor access to travel around our village for people with disabilities. There appears to be no baseline of how many village roads are difficult to use for disabled people, due to issues such as rough surfaces/moonscapes, pavement parking, cracked pavements or speeding traffic. New charges for car parks across RDC and HBC means people now drive into Fairlight Cove to park for free and some camp overnight outside residents homes. HBC is commonly perceived online as having corrupt working practices in relation to planning and development sites.

Q5.

SO 9 feels very important, but unless there are new initiatives in villages, there appears to be no resources to make this happen. It is difficult to get a face to face appointment at Hill Surgery, Hastings, few people can get through to reception. For people on low incomes, without a computer or mobile phone it is especially hard.

Q.27

There seems to be an opt out clause on Density. There seems little point in having policies, if you then create ways for property developers not to meet them.

Q.33

LWL3 Facilities at bus stops and iii Coastal Access This would be very important if it could be implemented.

LWL5

We welcome these policies in terms of height and steep sites, for example if a village is predominantly small low dwellings, very tall buildings stand out. For example at the entrance to Fairlight Cove and in the “transition” of the new Market Garden Site to the south.

LWL6

We welcome these policies in terms of height and steep sites, for example if a village is predominantly small low dwellings, very tall buildings stand out. For example at the entrance to Fairlight Cove and in the “transition” of the new Market Garden Site to the south.

Q45.

Streets For All. We welcome the shared streets policy especially “street furniture, good signage and way finding that is accessible to all to encourage walking and prioritise vulnerable users.” It would be beneficial to identify who currently lives in a ‘street’ or a ‘road’ and whether 4.62 SUDS and 4.64 could be implemented across the District. If RDC had clear design standards and guidelines, this would help Parish Councils who may not have access to professional expertise in planning. Community pride and cohesion is undermined by dirty and deteriorating infrastructure, Pett Level Road, Pett Level Toilets, Highways Pavement repairs, Southern Water sewage etc

Q.48

RDC needs to work with Parish Councils to create Parking Strategies for villages where parked vehicles now dominate the public realm, block footways, crossing points and sight lines.

Paragraph 5.16

Quiet Lanes and Slow Ways should be introduced on the 1066 walk and popular coastal footpaths as a priority.
This is a key issue for Fairlight enabling all generations to stay in rural communities for their lifetime and a source of frustration that new homes have not addressed the housing needs of local residents.

Q.54

The notion of “Hastings Fringes” feels unclear and ‘sensitive growth’ lacks a number, clarification would help.

Q.59

We object to the notion that a minimum of 35 dwellings in Fairlight is “sensitive” growth, we assume the site is East Field. This has been contested so many times over the years and the Field continues to flood, the sewage continues to overflow on Lower Waites Lane and Stream Lane. The increased traffic puts enormous pressure on village lanes which are in a poor state of repair. Pett Level Road is unpassable during the evening time due to the size of the pot holes. Access to a Post Office, Doctors Surgery and Dentists is limited.

Q.72

“Including the undeveloped coast, also has high intrinsic amenity value and is an important resource for nature conservation, leisure and tourism.” This would be more convincing if Pett Level Road were usable as a road, the moonscapes by the road side could be used for parking and the public toilets were open throughout the year.

Q.82

DEV3 The development boundary concept sounds confusing. If Fairlight Cove has a development boundary in the Local Plan surely the boundary of Waites lane is facing the ‘countryside’. Therefore an allocation of East Field for 35 houses would not meet the policy?

Q.90

DEV6 The Strategic Green Gap between Fairlight and Hastings is warmly welcomed, as are all the Gaps in the Plan. There are regular incidents where large vehicles e.g two buses/lorries etc get wedged along the narrow lanes travelling east along Fairlight Road which is claustrophobic and parked vehicles dominate. The areas open character feels essential to demarcate the start of the countryside.

Q.101

HWB5 Green and Blue Infrastructure
There is no minimum length for new development to be built away from a water course. In the case of the Market Garden Site in Fairlight, three new builds are on the banks of the stream and the earth has subsided as a result.

Q.102

A minimum precise measurement length should be insisted upon for all new developments near a water course. There is also no clear mention in Construction Management Plans for Site workers not to litter or pollute a water course. Also to store construction materials such as water proof insulation, glass etc a few metres from the edge so as they don’t fall into the water course.

Q.123

HOU5 Rural Exception Sites
This feels like another ‘get out’ clause. There is no clarity as to what RDC mean by “meaningful community engagement” If RDC has any examples of how this had worked in practice that would be helpful. Otherwise it could be removed.

Q.129

HOU8 Access to Standards Paragraph 8.72 This feels like another ‘get out’ clause

Paragraph 8.137

ESCC parking guidance is an under estimate, for the number of people who actually use a garage. The number of cars owned per household in rural areas and the fact that most dwellings have visitors and delivery vehicles. The car parking spaces are mean on new build developments, causing parked vehicles to over flow onto rural lanes and bus routes.

Q.144

”… private rear garden spaces of at least 10 metres in length will normally be required, other than in exceptional circumstances where this cannot be achieved in an otherwise acceptable development” We strongly object to the wording and opt outs within this Policy. At the Market Garden Site in Fairlight residents allege the 10 metre gardens have not been created. Allowing flexibility on the 10 metre rule makes a mockery of it being a Policy. This allows for Developers to erect cramped buildings on irregular and sloped sites. This is very disappointing. Similarly the policy can be avoided if “future occupiers of the dwellings will have a lesser requirement for amenity space” How can this be proven if properties are sold on the open market, another loophole for allowing dwellings with low amenity. It leaves little room for outdoor washing lines which have an environmental impact if clothes is dried indoors. Also the capacity for play equipment, to plant veg/fruit trees, store bicycles/canoes etc. We object to 8.136.

Q.146

The Policy is inappropriately flexible. Getting away with squashing the tiniest housing units onto a plot seems to be the game for a few Developers and RDC are encouraging it with this type of policy.

Q.166

Like most of our responses our comments relate to balancing new developments with maintaining infrastructure or improving strategic working with ESCC or Parish Councils. If the majority of visits are day trips then the issue of parking, overflow parking and public toilets remain very high on the list of problems to be addressed, which currently fail to meet customer expectations. The poor state of ESCC roads is a major factor in putting off visitors.

Q.180

LAN1 This is very important, especially to the undeveloped coast.

Page 356 (ix) The failure of RDC to stop Developers clearing trees and hedges is depressing.

Q.191

ENV 4 Fairlight Cove Coastal Change Management Area is important to support the work of the Fairlight Preservation Trust.

Q25.

Local housing needs necessitate that some development will be required within the High Weald National Landscape area and it is appropriate that any such development within this area is well-related to existing built-up areas and services. References to 'major development' within the policy are not well defined and lack the additional context provided within footnote 64 of the NPPF and could therefore mislead decision-makers into thinking this should apply to any 'major applications'. The policy as worded is therefore contrary to paragraph 16 of the NPPF which requires that policies are "clearly written and unambiguous, so it is evident how a decision maker should react to development proposals".

Reference to the High Weald Design Guide is supported and the proposed development concept at the Wild Meadows site has been considered in line with this Design Guide.

The proposed development reflects the positive characteristics of the built environment throughout the High Weald and makes effective and efficient use of the development site. The key principles that have determined the overall design and layout include:

• Prioritising walking and cycling routes within the site and ensuring permeability for those walking past, through and around the site, including improved access to both local facilities in Guestling Green (and those within the proposed development) and the surrounding countryside;
• Incorporating a central green public space that is addressed by the buildings around it;
• Meaningful public realm throughout the rest of the site with soft edges to streets, new tree planting and a rural character that reflects the character of the wider area;
• Residential layout that defines the streets within the site and provides strong street frontages offering both discernible building lines and architectural variety;
• An appropriate unit mix that reflects the local housing need for smaller dwellings and affordable housing;
• Parking integrated into the design and layout, with a mix of parking solutions to ensure that parking is discretely located where possible and not overly dominant at street level

Q51, 53

The Council's authority monitoring reports show that the Council have delivered between 98- 283 homes a year since 2011/12. Although completions have been rising over time, the scale of delivery falls significantly short of identified local housing needs (733 homes a year), as well as the agreed housing trajectory within the adopted Core Strategy (335 homes a year) and the proposed spatial development strategy for the Rother Local Plan 2020 - 2050 (258 to 364 homes a year).

The Council's existing housing policies and allocations are therefore significantly under-delivering on the agreed minimum housing requirements for the District and local need has grown since the adoption of the previous Core Strategy. Housing delivery will only improve consistently through the adoption of a new Local Plan with additional housing allocations and a revised policy framework that provides a more aspirational framework for housing delivery.
Without deliberate policy interventions to improve delivery, local supply and affordability issues will continue to worsen.

We therefore welcome the Council's intention to allocate additional sites for development and adopted a new Local Plan. It is essential that the new Plan does not impose constraints to development that suppress housing delivery unnecessarily. It is therefore essential that the local planning authority scrutinise its own evidence on supply and capacity to determine whether these figures are robust and whether there are further sources of supply that could
be relied upon or identified sites are capable of delivery additional housing.

It is noted that the housing requirement identified in the draft Plan currently is a supply-led figure that would not come close to meeting the identified local housing needs of the area and therefore all efforts must be made to find additional sources of supply.

The Wild Meadows site is one such location where the identified capacity of the site is being unnecessarily suppress within the Regulation 18 Plan. The site has been assessed as capable of delivering 14 new dwellings, but the Council's own minimum density target (25 dwellings per hectare (dph) in village locations) suggests that any allocation of this site should be seeking to
achieve a minimum of 28 new homes.

We have previously submitted a development concept that shows 29 new homes within the site alongside new community infrastructure including public greenspace and equipped playspace, and have provided a copy of this concept plan as part of this consultation response.

As mandatory housing targets have been re-established by central Government and national policy is likely to shift in favour of housing delivery (particularly on sites that can be delivered within the first five years of the Plan), there is a clear policy shift towards additional housing delivery. The delivery of at least 28 new homes on the Wild Meadows site would not only
deliver additional housing overall in the short term, but would also double the number of affordable homes that would be delivered on this site compared to the 14 unit estimate currently shown.

Q 59, 60, 61

We support the strategy for sustainable villages within this area and the concept plans for the proposed residential development at Wild Meadows already seek to enhance the public realm and provide new community facilities in Guestling Green, in accordance with this vision.

Guestling Green is an appropriate location for new housing growth and the allocation of the Wild Meadows site would deliver an appropriate scale of development that is commensurate to the size of the settlement. We believe that additional homes could be delivered on the Wild Meadows site in accordance with the Council's own minimum density target.

Q76

We welcome the recognition of Guestling as an appropriate location for growth.

Guestling Green provides an important local Primary School that serves the wider rural area, and the village also provides opportunities for development that can deliver new family housing, affordable homes and community infrastructure that will ultimately improve the overall sustainability of the settlement.

As set out in our response to other questions, the Wild Meadows site has the capacity to deliver new community infrastructure, including public amenity greenspace and equipped playspace that would provide a benefit to the entire settlement. The Wild Meadows site can also deliver 29 new homes at the Council's minimum density target (25 dwellings per hectare), which would
deliver a wide range of market and affordable homes and new family housing within walking distance of the Primary School.

The development can therefore improve the sustainability and viability of the settlement through appropriate growth and a gentle residential density. The settlement has been identified as a potential growth location in the past but the tightly drawn development boundary has prevented new development from coming forward and therefore the new Local Plan needs to be proactive in allocating the Wild Meadows site to ensure that the appropriate scale of growth and delivery of new community infrastructure can be achieved.

The scale of development proposed at Wild Meadows is commensurate to the size of the settlement and provides an excellent opportunity to sustain the settlement and address local
housing needs over the Plan period.

Q77.

We have serious concerns that the Council's intention to build a stepped housing trajectory into their strategy reflects a lack of aspiration to urgently address the under-delivery occurring within the District.

If delivery rates do not improve in the short term then the scale of unmet need will only worsen and the challenge to improve delivery at a later date will be potentially unachievable.

We are concerned that the Council is over-optimistic about its ability to achieve higher rates of delivery without immediate interventions and a step-change in the approach to housing delivery within this Local Plan.

One way to ensure that housing delivery if maximised throughout the Plan period is to review the potential capacity of sites identified as suitable for development and to ensure that the recommended minimum density targets are achieved on all these future allocations.

Sites which are deemed to be poor sustainability should mean no development otherwise whats the point of HELAA. I suspect poor sustainability means it also lacks infrastructure, not much chance of living well locally but is green to the core. I also think calling it Hastings Fringes allows Hastings to put people in those properties when local connections cannot be found. The area should be called Southern Rother as per the District Councillors area.

We agree that further substantial new development in Winchelsea is no feasible

Please see attached representation.

Please see attached comments from Burwash Parish Council.

Please see attached the full submission regarding Land at Breadsell Farm covering background information to the site as well as detailed responses to questions 27, 28, 32, 51, 52, 54, 55, 60, 61, 77 and 90.

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

Please find my comments on the Rother planning document. My focus relates mostly to Guestling Green as this is the area in which I am resident. I tried to add comments to the plan but found it was constructed in a way that makes telling a coherent story very difficult and the plan is segmented in a way that does not match with my comments and concerns.

Rother, and particularly Guestling, is a rural area with an older population – 32 percent is 65 years old or older compared with 18 percent for the south east. The housing stock is also old and tends towards larger houses. The plan calls for a higher share of affordable housing and identifies this as one and two-bedroomed houses as this relates to what is most affordable for first time buyers. However, attracting first time buyers would be difficult in the area as there is little focused employment in the Rother district and particularly in Guestling. One and two-bedroomed houses tend to attract transient house owners, on their first step towards building a family, which tends to need three and four bedroomed houses. This runs counter to building a community in the area because of the short-term housing occupants spend in their first or second homes. As employment in Guestling is likely to be seasonal and service based or agriculture based, which tends again to be towards the lower end of the pay scale, this makes it difficult to attract first time buyers because of their lower income. Typical employment would be working in services (pubs, hotels) or farm and shop working.

Most occupants of affordable housing are likely to look towards the towns (e.g., Hastings, Ashford) for their jobs which means they will either drive to their work locations or use public transport. Public transport in the Guestling area can be weak and sporadic, and many new house owners are likely t o drive to work. This adds to the parking issues in the towns, contributes to the poorer air quality, higher carbon emissions, and more traffic. The local roads are at best in a poor condition with inadequate maintenance and not wide enough to cater for the increased traffic. There seem to be few, if any, plans to improve the road infrastructure.

As one and two-bedroomed houses attract more transient occupants, and one of the biggest industries in the region is tourism: providing holiday homes these houses are more likely to be bought by investors looking for affordable holiday homes to rent out during the summer. There is already a substantial holiday home stock in the Guestling and Pett areas and building smaller homes that investors can afford is more likely to attract holiday lets or Airbnb owners. These will again attract cars driven by people less used to rural roads and clog the roads during the summer.

Specifically looking at the HEELA assessments – most of the sites identified for the Guesting Green areas have been rejected – mostly for the same reasons of access and view, unknown ownership or availability, together with the sites being in an Area of Outstanding Natural Beauty. Only one site is identified as a candidate, and it is no different to the rejected sites other than its availability is known. This site is also visible from the valley and from houses on Pett Road so also should be rejected because of that. It is also on a narrow road (Chapel Lane) which recently saw accidents partly because of the narrow nature of the road and poor views along its length. The site has been considered for 4-6 houses in the recent past and planning permission was rejected because of the view and access, so adding 14 affordable houses will be worse than 6 – meaning this should also be rejected. Finally, there is a significant risk of flooding, as was seen over the past winter, with torrents of water pouring down Pett Road and Chapel Lane, which would pour into the proposed development at Wild Meadow (GUE0012)

An alternative consideration might be to focus on 3–4-bedroom houses in the Guestling and Pett areas to encourage increased longer-term occupation by families, building a greater sense of community. There is a definite poverty of community resources in the area with fewer and fewer shops, post offices, school places, transport connections, doctors, and dental surgeries: and these will need to be encouraged and included in the plan to strengthen the attraction for families to the area. Without this the aged population will pass on and there will not be a new generation to carry on the village-like communities in the district – at best Guestling and Pett would become a collection of dormitory villages supporting employment and services in Hastings and other towns.

Considering the strategic initiatives proposed in the plan:

Green to the core:

A better option might be to encourage less car transport or increased public transport. More frequent bus services, subsidising the installation of vehicle charging to again encourage electric vehicles rather than petrol- or diesel-powered ones. This could be the provision of lower cost home charging or charging stations in and around town centres to make the transition to electric vehicles easier and more transparent.

Many houses in the Guestling and Pett areas a old and use wood burners, gas or oil boilers, and are likely to be poorly insulated. Encouraging the transition to heat pumps and solar through education, recommended installers, subsidies, and through education for insulation is more likely to have an effect in the longer term and will continue to reap rewards over time as the carbon footprint of the area is reduced.

Live Well Locally:

Encouraging a village existence would attract people more likely to move or live in the area and stay here, contributing to a better community. The gradual demise of local services such as shops, libraries, schools, discourages people from moving to the area, so patchwork building of affordable housing will not attract people that want to remain in the area. Part of this plan must be the attraction of industry that is not seasonal to provide the bedrock for household income, but also the building of hamlets or villages with enough houses to support these shops and services. Guestling Green in particular had many shops and services in the past so there is scope to build these up again. There are many village halls around the Rother area, with Pett, Guestling, and Fairlight hosting halls. These can be extended or expanded to provide local services. Already there are some services such as doctors weekly visits and these can be extended and enhanced to build a stronger sense of community. I think the different services provided at the village hall are not well advertised, and there should be a plan to publicise these better, as well as to enhance them. In particular there is a significant elderly population in the district that can benefit from healthier living through exercise, education for new technologies that might be difficult for those less used to technology impact, and also education about plans and activities from the local elected officials and council workers. I am conscious of a large number of women-oriented activities, but there are precious few activities targeted towards the older men in the area. I think particularly of the Men In Sheds activities in Ore – I think Guestling, Pett, Fairlight in particular could learn from that, and this can contribute to living well locally for the older male population. Many of these men have valuable skills they could pass on to younger members too and contribute to the community. This needs encouragement as part of the plan.

See attached full representation

See attached document for the representation.

Please see attached full representation on the draft Local Plan in relation to HELAA site ICK0017.

Representation by Stantec on behalf of Welbeck Strategic Land III Limited in support of Land East of Waites Lane, Fairlight Cove - HELAA site ID FAI0001.

Submission also responds to questions 59, 60, 61, 76, 27 and 191 in the Regulation 18 draft Local Plan.

Please see attached submission for full comments.

See attached documents which comprise the submission for the Regulation 18 Local Plan and HELAA site ICK0002: Seven Acres, Watermill Lane, Icklesham.