I wish to object to the proposed planning application listed for several reasons:

1. Increased traffic in an already busy lane which is narrow. Further risks of accidents happening.
2. Local Schools already full to capacity.
3. Currently unable to get appointment at GP surgery as over capacity so further residents would make this even harder.
4. The infrastructure cannot cope at present, so even more residents would put further stress on the system.

Please see attached letter and copy of representation made to The Planning Inspectorate on March 2022, regarding Appeal APP/U1430/W/21/3283287/2778.

I am writing with reference to the Draft Rother Local Plan 2020-2040 which is currently under consultation. I am a longstanding resident of Fairlight, East Sussex. I am concerned in this matter in such capacity. I am by profession a retired Senior Economist at HM Treasury with interest in planning issues.

I set out below my comments on the Draft Local Plan, in particular where it touches on matters which relate to the village of Fairlight.

GENERAL BACKGROUND AND THEMES

In the Introduction, in para 1.6, there is an explanation of the Local Plan’s vision which states the importance of delivering the Council’s housing, economic, community and infrastructure needs, and protecting the special landscapes, habitats and heritage of the Rother District.

These themes are highlighted throughout the document and there is considerable repetition of the important factors of which to be aware, and cautious, in presenting the recommendations of the Local Plan. I shall be making clear in this submission how these factors impinge on the area of Fairlight and how the proposal for building a housing complex in the East Field site along Fairlight Road will contravene many of the Local Plan’s own stated conditions. The main point I wish to make, and for which I present arguments below, is that Rother should de-allocate from its list of possible sites for development the site numbered FA10001 in the East Field, Fairlight.

There are also a number of other issues which need to be considered in relation to the themes and proposals from the different parts of the Local Plan. The Local Plan has asked for comments from residents and I shall deal with these in the order they are raised in the document.

1. The “wish list” and supporting documentation.

The Local Plan covers a huge number of development and planning issues but fails to ascribe a hierarchy of importance to the different criteria or an ordering of likely timings for proceeding with the various recommendations. It is a “wish list” with few relativities or comparators of likely costs or impacts. That is a major defect.

I am also concerned that some of the supporting documents and evidence, such as the Strategic Flood Risk Assessment which is dated 2021, are already out of date and will need to be updated by the time the Local Plan is finalised let alone implemented.

2. The need for quality and specific local planning

Right from the beginning of the Local Plan in para 1.21 it is stated that “The Local Plan should not merely repeat national planning policy. Instead it must set out strategic and non-strategic policies which are important to Rother’s local context”. This theme of locality and neighbourhood factors is of crucial importance and has my full agreement.

3. Local Development

The type and form of development must reflect the local area. This principle is helpfully referred to on page 56 under Proposed Policy GTC9 where it is stated that:

“All development within or affecting the setting of the High Weald National Landscape (AONB) shall conserve and enhance its distinctive landscape character, ecological features, settlement pattern and scenic beauty, having particular regard to the impacts on its character components, as set out in the latest version of the High Weald AONB Management Plan.”

It then continues that “developments …should be small scale, in keeping with the landscape and settlement pattern, and designed in a way that reflects its nationally designated status as landscape of the highest quality”.

This theme is referred to throughout the Local Plan and is highly relevant in the context of any proposed development in Fairlight. In particular, para 3.62 on page 60 states:

“Existing landscape features that are important to local character should be retained, while new features should be typical of the locality, fit naturally into the landscape and complement existing features.”

Para 3.63 then follows on by commentating that:

“National policy states that the highest status of protection should be afforded to the landscape and scenic beauty of the Area of Outstanding Natural Beauty (AONB) and great weight should be given to their conservation and enhancement. The NPFF specifically states that the scale and extent of development within an AONB should be limited and advises that planning applications for major development should be refused other than in exceptional circumstances.”

This is repeated with even more emphasis in Chapter 10 on Landscape Character from page 355. It emphasises that

“Priority must be given to the conservation and enhancement of the district’s nationally designed and locally distinctive landscapes and landscape features.”

Furthermore on page 89, under Proposed Policy LWL6: Build Form, it is stated that:

“Landscape Strategy. The landscape strategy must help determine the capacity of the site and hence the appropriate developable area for the development. All layout or landscape plans for multiple unit or large building developments must have accurate contour plans and information about surface water flows. Single dwelling proposals must have levels on the site and contours for the site context clearly shown on relevant plans.”

I note that at page 108 para 5.7 the Local Plan states that development will only be acceptable where it does not have an adverse impact on the natural environment. There are many constraints across the District which impact on the overall suitability of land. Development will need to be steered away from areas of high flood risk, designated habitats sites and other areas with important high landscape value. With regards to flooding, in line with the NPPF, the development strategy will take a sequential development approach to ensure that suitable land is identified in lower risk areas before development in areas at higher risk of flooding from all sources is considered, with any appropriate mitigation. This sensible approach should be applied to Fairlight but it is not so applied with regard to the development of the East Field.

4. The application of these principles to development in the East Field, Fairlight

The Local Plan at page 196 refers to the Fairlight and Hastings Green Gap . The Gap between the Hastings Borough boundary and the edge of Fairlight Cove provides an important function in protecting the general openness of the area between the Hastings Country Park and the edge of the settlements of Fairlight and Fairlight Cove. The area south of Battery Hill and Hill Road and to the east of Coastguard Lane, including The Close, is vulnerable to incremental change and infill development.

All these passages contained in the Local Plan, and the importance that is given to these features, makes it quite clear that none of these essential requirements would be met by a development of 35 additional houses in East Field, Fairlight. This argument is reinforced by the following points which are of major concern to local residents like myself:

(1) Water Issues

Fairlight is recognised and known by Rother as an area of major concern over flooding, sewerage, water flows and the problems of coastal erosion and sustainable surface water drainage. It is also intimately connected with the RAMSAR, a Special Protection Area with an important conservation value.

As a result of the problems that Fairlight has faced with these water issues, it even has a special section in the Local Plan under Proposed Policy ENV4: Fairlight Cove on page 380, and is mentioned in Proposed Policy ENV1: Coastal, Water and Flood Risk Management and ENV2: Sustainable Surface Water Drainage. Fairlight is well known to have insufficient capacity within its sewer network. The area of the East Field (known locally as “Pond Field”) is prone to regular flooding especially in the winter months. As a consequence of climate change and the greater frequency of heavy storms this situation is likely to get worse rather than improve.

To emphasise the importance of flooding and sewerage issues, and the insufficient capacity within the sewage treatment plant that covers the area of Fairlight and its neighbouring villages, Southern Water has made Fairlight one of its 6 special Pathfinder Projects for analysis and research into how to treat 5 the flooding, sewerage and drainage problems. There can be no doubt that, unless and until all the existing problems have been resolved, adding any extra homes to this already over-capacity drainage and sewer system would be dangerous, foolhardy and should be out of the question. The idea of a development on the East Field site which would add 35 new properties to this failing system should be dismissed.

(2) The impact of the 2022 Planning Appeal

Rother’s planning department will recall that in July 2022 there was a detailed appeal by an Inspector into the rejection by Rother’s Planning Committee of a proposed development of 43 houses in East Field. The developers were unsuccessful on that appeal for the reasons set out at length by the Inspector in his decision. Among those reasons reference was made to the unsuitability of the East Field for development when compared with other potential sites in Rother District (which the developer had not investigated) owing to the severe flooding, drainage and sewerage problems of the area generally and in that particular location. Regrettably, Rother planners chose not to put forward any arguments about the water issues at the Appeal and themselves withdrew that particular objection. However, the Inspector was impressed by the arguments advanced by numerous local residents including myself who drew proper attention to these vital issues. The rejection of the Appeal owed much to these arguments as can be seen from the decision. In the circumstances the Local Plan must take account of these factors to de-allocate the East Field.

Moreover, to be very specific, under Proposed Policy ENV1, on pages 366, 367 and in particular in sub-para (iv) (a) the Local Plan states that there should be modelling by the wastewater provider to demonstrate

“there is sufficient capacity within the relevant waste water treatment works for the development to be accommodated without a negative effect on the receiving environment”.

Yet, it is already known and has been acknowledged by Southern Water that the waste water treatment works at Pett, which covers the Fairlight area, has insufficient capacity. It undoubtedly requires expansion to meet the demands of the existing population, but Southern Water have indicated that expansion will require substantial further investment which would be many years into the future.

There is also major concern in Fairlight over surface water drainage. In ENV2 on page 371 it is made clear that planning applications have to demonstrate that sustainable drainage is an integral part of the proposed development and design. Also, applicants must demonstrate that arrangements are in place for ongoing maintenance of the sustainable drainage schemes (SuDS) over the lifetime of the development.

The Local Plan, on page 376 in para 11.25 states that

“There is currently a policy requirement in Policy DENS (vii) of the DaSA for surface water runoff rates within the Fairlight and Pett Level Drainage Area (which broadly covers Fairlight, Fairlight Cove, Pett and parts of Cliff End) to be no more than the greenfield rate, in terms of volume and flow. The Council is now proposing to broadly incorporate this requirement for all development…..

There is a wider drainage capacity and flooding concern both in the village and downstream at Pett Level, where there is a history of flooding from the Marsham Sewer in periods of wet weather …”

It would be unconscionable to add to these woes by allowing more properties to be built in the East Field, an area which would directly feed into these existing problems.

Hence, the East Field site should be removed and de-allocated from any chance of future development. Rother needs to reacquaint itself with the concerns of local residents, as well as all the many organisations and individuals who wrote in and spoke at the 2022 Appeal against the earlier proposal for the development of the East Field.

(3) Supporting documentary evidence

Attached to the Local Plan are some Supporting Evidence documents. These documents cover areas such as employment and land usage. The document entitled Housing and Economic Land Availability Assessment “the HELAA” is helpful in setting out some further details of policies which supplement the main document of the Local Plan.

Part 2, Chapter 2 of the HELAA, relates to Hastings Fringes and Radial Settlements. Map 2.3 on page 20 of 61 shows the areas in and around Fairlight that were considered for development potential. It is noticeable that area FA10001, the East Field, is in orange (as a potential development site) whereas the land immediately adjacent to it within the same field system at FA10003 is 7 in grey. This means that location FA10003 has been correctly dismissed as unsuitable for development, as have other sites which have also received the grey colour indicating no development potential. For example, FA10008 has been given a grey status because that site would represent “encroachment into this sensitive and distinct section of open countryside impacting on the landscape and character of the National landscape”

The very same problems arise with the East Field. The question to ask is why one part of the same agricultural farm area is correctly considered as not suitable for development, whilst the other part is thought to be suitable. The reasons given for FA10003 are very substantially the same as would apply to FA10001. There is no material distinction between the two different sections of the same site. The contrasting treatment in the Local Plan makes no sense.

Problems of access have been mentioned in relation to the other sites as a ground for their rejection for development. The East Field in location FA10001 has already been analysed as having major access problems. This was one of the reasons it was rejected at the previous planning application stage.

Furthermore, its development would be highly prominent and obstructive, impacting in an adverse sense on the outstanding landscape and character of the wider Fairlight area. This factor alone seems to have been sufficient to remove the other local sites from development potential within the Local Plan. The East Field should be treated in the same way.

(4) The absence of demand for new housing in Fairlight At para 5.3 on page 107 of the Local Plan it can be seen that the 2014 Core Strategy planned for a growth level of at least 5,700 dwellings between 2011 and 2028 in Rother, which works out at 335 homes per year. The actual number of houses built in the District each year since has averaged 219 (net additional dwellings per year). It is the role of the Local Plan to identify the number that can appropriately be accommodated, and it is this "appropriate" growth that this development strategy plans for. However, houses must be constructed in locations where there are adequate facilities and commensurate demand for homes.

I would add in relation to the need for additional homes to be constructed in Rother that there is no unsatisfied demand within Fairlight. It is a village with few amenities and no obvious employment opportunities. These 35 houses would be far better constructed nearer to Bexhill and its surrounds where there 8 is demand for additional housing and where there are employment opportunities, schools, medical facilities and other amenities, including regular public transport.

Conclusion

Accordingly, it is very surprising that the Rother Planning Department have decided to include FA10001 in the Local Plan as suitable for development notwithstanding the criticisms made of the previous planning application and the outcome of the 2022 Appeal. Rother must now retreat from its inclusion of the East Field as a site recommended for potential development of 35 properties. Rother needs to alter the Local Plan designation of the East Field site FA1001 as not suitable for development.

An example of a dreadful new development which was allowed after another planning appeal is the Market Garden Site along Lower Waites Lane in the Fairlight Cove area in which 16 new properties are being completed. This has set an appalling precedent. Rother are aware of the major issues with regard to this site in relation to sewerage, overcrowding and its failure to satisfy the size requirements of gardens (which should be a minimum of 10 metres in length). However, that site is located within the existing built-up area of the village. The East Field is most certainly not so located and is separated from the village.

Please refer to the detailed submissions previously sent by myself and other local residents to Rother in relation to the various applications for the development of the East Field, all of which will be within the records of the Rother Planning department. For ease of reference, I attach my earlier submission on the 2022 Appeal to this document.

I would be grateful if the matters raised in this document are taken into account when finalising the Local Plan. I reserve the right to supplement these submissions at a later date and in the event of any inquiry.

Please see attached letter for full representation including site photos.

The entire Wakeham’s Pond Field is a FLOOD ZONE.

Our garden abuts the North West corner of the field which floods when there is heavy rain. There was standing water in the field from early October 2023 to late April 2024.

There are drainage ditches to take the water away and protect our garden that slopes down form the North West corner of Pond Field and our garden becomes flooded following rainfall on Pond Field.

Attached are photos of the amount of flooding and firemen having to pump out our gardens in November 2023. The extent of this flooding caused us to be marooned on many occasions as the water was deeper than our wellingtons.

The garden is like a marsh through out the winter months and the flooding has killed the Trees, Shrub's and part of the Hedging in the front garden.

Following rainfall, the level of the rain water standing at the back right hand corner of our house is up to the damp course.

If houses are given permission on Pond Field even more water run-off will come on to my property and will make life quite impossible for me as well as running my garden.

I call on Rother DC to listen to the 2022 Appeal Hearing Inspector, take account of his findings that the risk of ground water flooding is too high and that extra houses would make sewage pollution matters worse and de-l locate Pond Field in the new Rother Plan.

I support the 2022 Appeal Inspector’s findings on Wakeham’s Pond Field re: the risk of groundwater flooding is too high and that extra houses would make sewage pollution matters worse and I call for Wakeham’s Pond Field to be de-allocated in the new Local Plan.

I support the 2022 Appeal Inspector’s findings on Wakeham’s Pond Field re: the risk of groundwater flooding is too high and that extra houses would make sewage pollution matters worse and I call for Wakeham’s Pond Field to be de-allocated in the new Local Plan.

We strongly object to any proposal to build additional house in Chapel Lane, Guestling.

The area is very rural and actively farmed.

The lane is used as a link from Pett and Fairlight, especially for access to the Primary School and A259. More housing would bring an increase in traffic, this would be difficult in the narrow lane for drivers, pedestrians, horse riders and farm vehicles.

There would also be an increase in noise and light pollution in an Area of Outstanding Natural Beauty. Wild and farm animals would be affected by this as well.

The sewer serving this area, to the rear of Higham Gardens, has had serious blockage problems that had to be dealt with. The pipework crosses our farmland so we aware that Southern Water have been called on to carry out urgent works at least twice in the past two years, extra dwellings would be adding to the stress on this essential utility. The impact on the small sewage treatment facility in Church lane must also be taken into account.

In our opinion Chapel Lane is not suitable for further development.

I support the 2022 Appeal Inspector’s findings on Wakeham’s Pond Field re: the risk of groundwater flooding is too high and that extra houses would make sewage pollution matters worse and I call for Wakeham’s Pond Field to be de-allocated in the new Local Plan.

Objection to GUE0012

Please see attached representation and supporting photographs.

Rother Local Plan 2020-2040 draft

Re: Page 126, Guestling Green Land Proposed to be made available for development GUE0012 Home Meadow Farm, now called Wild Meadows, with house, paddocks and outbuildings. The land is sited in Chapel Lane, Guestling, Hastings, East Sussex, where the owners once ran a riding school and livery. Since that no longer exists, the land provides grazing pasture for horses. In the 2006 Rother District Plan this land was not available for development. Now, in 2024 the above draft proposes that GUE0012 is made available for development, to build 14 houses within the next 5 years.

I wish to make representation opposing this proposal.

1. The parish of Guestling and Three Oaks lies about 4 miles NE of Hastings on and around the A259 within the High Weald National Landscape, an Area of Outstanding National Beauty, AONB.

Over the past 1000 years, the High Weald National Landscape with its medieval countryside of rolling wooded hills, scattered farmsteads with small irregular fields and ancient route ways, has been shaped by its geology, by nature and those who lived and worked here over the centuries. It was given the status in 1983 and is now protected by law, to conserve and enhance its natural beauty and this must be given highest priority.

‘Wild Meadows’ is a small part of this AONB, a quintessential English Pastoral Landscape and it is difficult to see how a change of use from agricultural to housing development would conserve or enhance its natural beauty.

2. Location and Access: The parcel of land GUE0012 runs NW to SE alongside Chapel Lane, an attractive, narrow, winding country lane. Further building development, requiring access, will increase traffic and hence hazards.

The speed limit along the lane is 30mph, with no central white lines, no pedestrian footways or refuges, just some roadside bramble verges and hawthorn hedgerows.

Opposite the site under consideration, is a pretty, grade 2 listed, thatched cottage, and further along beside the stream, are more listed, charming old cottages, creating a delightful, country lane that could be easily spoiled if there were to be more building development and become dangerous to pedestrians and drivers alike, Chapel Lane links the busy A259 trunk road with Friars Hill. At each end of the lane the junctions are particularly hazardous.

At the A259 junction, where there are five more listed dwellings, residents park roadside and on footways if there are any, leaving little space for cars to pass. At times when the local primary school begins and finishes the space becomes even more crowded, dangers increase, as parents leave their parked cars in order to take or collect their children from school.

Chapel Lane is far too narrow to accommodate the vehicles and heavy plant required to build new homes. Associated with the proposed new housing development we can expect further increase in domestic traffic. Any existing access from Wild Meadows site to Chapel Lane is not suitable for the proposed development. It may be possible to create access from Higham gardens, but new access roads would contribute to further congestion.

At the Chapel Lane junction with Friars Hill, there is a 40mph speed limit, bringing different hazards. The road approaching from the left is totally unsighted and traffic coming down the hill on the right often increases speed. It’s an accident waiting to happen!

3. One of Rother’s listed priorities is “Green to the core”. They pledge to consider the impact of planning decisions on the biodiversity crisis and natural recovery and yet this beautifully positioned meadow is to be considered for near-future housing development, (ie. within 5years).

The best place to view the site and consider its position within the AONB is partway along the public footpath GUE36 (an ancient right of way), starting opposite Guestling C of E Primary School and leading to Guestling St Lawrence Parish Church. The school has strong links with the church and on certain festival days the pupils walk in pairs in a crocodile, with their teachers to the church for a service.

From this path, looking south, the Wild Meadows site can be seen, together with an existing housing estate, Higham Gardens, of 21 houses. These houses nestle down a slope and partially fit into their landscape, but even so are not invisible and do not enhance the High Weald National Landscape. However, the land at Wild Meadows, stands even higher, along one level and any housing development there will be much more obvious, not only seen from the public right of way but also from the main road, A259.

The view is wide and wonderful across ancient woodland; Glebe Wood and Mallydams Wood, up to Fairlight where the distinctive church tower can be seen, perched on the skyline, surveying all the parishes below, and looking towards the North Downs. It would be shameful to alter this view in any way by creating new buildings or chopping down trees and deny the children of the parish their future inheritance

4. Public Right of Way. GUE 37 crosses the site from west to east. The public footpath Chapel Lane to Church Lane, avoids roads and associated traffic and is safe for pedestrians. The route is used regularly by local dog walkers and sometimes by hikers linking to the 1066 Long Distance Walk from Hastings to Rye and beyond. If the land were made available for development, permission would have to be given and money change hands in order for the path to be moved and made suitable for public use.

To whom it may concern:

I trust anyone who has read this objection relating to the Rother Local Plan will take it to heart and help to protect Wild Meadows (GUE0012) from being included in the list of sites available for building over the next 20 years.

Inga Chapman. Guestling resident for 49 years.

Please: Keep the name Wild Meadowsbut abandon the proposal to build

Objection to 14 houses in Chapel Lane: GUE0012

My reasons for objection of these plans are

1.The area is within AONB (to conserve and enhance the natural beauty of the area), the countryside and rights of way act 2000.
2. In this area are kites, Buzzards. The loss of ecology and eco systems would be devastating.
3. The pressure on local schools. Guestling primary and Hastings Academy. Already over subscribed.
4. Increase in traffic on a NARROW and already busy cut through for residents from Pett. At school times, the Lane becomes gridlock due to parents parking to collect their children. Heavy machinery such as tractors, have difficulty going about their duties. Let alone the machinery that will be used to build the houses.
5. Lanes are used by horses and children on bikes causing a rise in danger.
This is a lovely quiet rural area, this will increase noise levels and activity.

Unless you live here, you can not appreciate what a lovely area it is to live in.

Why do people feel the need to build on GREEN areas, when there are empty houses, pubs and greyland that can be regenerated.

I support the 2022 Appeal Inspector’s findings on Wakeham’s Pond Field re: the risk of groundwater flooding is too high and that extra houses would make sewage pollution matters worse and I  call for Wakeham’s Pond Field to be de-allocated in the new Local Plan.

I support the 2022 Appeal Inspector’s findings on Wakeham’s Pond Field re: the risk of groundwater flooding is too high and that extra houses would make sewage pollution matters worse and I call for Wakeham’s Pond Field to be de-allocated in the new Local Plan.

Please see attached representations on the draft Local Plan titled:

- Green to the Core submission Christopher Smart

HELAA site FAI0001

- Landscape Character Submission Christopher Smart

draft Local Plan questions: Q180, Q181, Q182

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.

Please see attached from 'Village People' resident group in Fairlight:

- Loss of Amenity survey' (Problems with the Market Garden Site, Fairlight)

- Parking Matters Survey

This is a submission requesting the de-allocation of Pond Field, Fairlight from the Draft Local Plan 2020 / 2040.
We made a representation to the appeal by Welbeck Strategic regarding the proposed development under Planning Reference RR/2020/151/P. This appeal was rejected by the Planning Inspectorate.

Attached, for your information, and to be drawn to the attention of the responsible person making decisions on this, is a copy of the representation we made.
Some of the points we made were particular to that planning application and are not germane to the general principle of housing development on the site.

The remainder still have substance and to precis them -

AONB (now High Weald Natural landscape) requirement that scenic beauty be enhanced?

Poor transport links?

Danger to all traffic. especially pedestrian, as only access is via Fairlight Rd?

Creation of an enclave without access to the rest of the village?

Little local infrastructure i.e. shops, schools?
Finally, and most importantly, increased risk of flooding and exacerbation of the sewage pollution in the local waterways?

Please see attached Appeal representation, Ref RR/2020/151/P

I am emailing to raise my concerns with regards to the planning for 14 houses in Chapel Lane, Guestling, on the field that belongs to Wild Meadows should be refused for the following reasons:

• Chapel Lane is what it is, a lane, not a road suitable for all of the extra traffic these 14 new properties would bring.
• The increase traffic would also make it the lane unsafe to the local people, dog walkers, horse riders & children walking to and from the local primary school.
• The sewage pipes are not able to handle to amount generated with the present number of properties, an extra 14 would have an huge impact on these and likely to experience blockages and over flowing into the present stream, impacting on the local farmer and their pond.
• You are wishing to build on agricultural land adjoining a working farm, in an area of Outstanding Natural Beauty. The increase in the population will have an impact on the animals that inhabit the farm through the year.
• 14 houses would then mean, at least another 14 - 28 cars on the road, this would impact the already busy lane during school hours due to the lack of packing for parents when dropping off and picking up their children.
• The primary school already is over subscribed, with children from outside areas being accepted for places.
• The public transport is unreliable, with only one bus coming through each hour, and every two hours on Sunday's and Bank Holiday's.
• There are no amenities, in terms of local shops, GP surgeries, play parks, sporting facilities or Post office now in the village. With the local GP closing their doors in recent years. Not even a farm shop in the immediate vicinity.
• There are several empty buildings around the Rother area which could be much more suitable for housing the increased population.
• The emission's from the 14 new houses, will impact on the growing light population, with the local area not even having street lights.
•
Having lived here for 70 years, born and raised within the local area, i have seen many planning applications, much much smaller than this, declined for issues that actually would have improved many of the properties that they were associated to, yet this monstrous development of a beautiful green space is being considered, not befitting to it's natural surroundings.

Why on earth would anyone in their right mind think about building houses so close to the edge of the south coast when so many buildings are being lost to the sea along the edge of Great Britain? It is unbelievable when there are so many dilapidated areas in the South that could support houses that would not be built on AREAS OF OUTSTANDING NATURAL BEAUTY.
Apart from these reasons why this is a ridiculous idea, we have to drive from Fairlight Cove along narrow dangerous roads to get to either Rye, Hastings or the A21 to access the rest of the country. To have 300 or more extra cars/lorries and buses along these narrow roads would mean even more accidents.

We have no school here in Fairlight for more children to be educated in and the nearest schools are already oversubscribed which must mean travelling afar again in cars/buses.

Sewage & flooding is a constant problem in Fairlight and many residents have to cope with this already without more houses/businesses gardens and allotments adding to this.

I cannot understand why any Councillors would want to pass any building plans attached to such a quiet & peaceful village on the edge of the Cliffs on the South Coast.

I therefore consider a Local Plan unnecessary in Fairlight.

In response to the potential construction of 14 residential units included within the draft local plan.

It is her view that this amount of additional units in the small village of Guestling Green will have a negative impact on the quality of life of current residents, in that there will be:-

• more vehicles on the road, both during and after construction
• Increased traffic on local lanes which would pose an increased level of danger to current residents
• Increased noise levels and activity in the rural setting
• A loss of ecology and local eco systems that support wildlife and our environment

I trust that the above reasons will be duly considered

I support the 2022 Appeal Inspector’s findings on Wakeham’s Pond Field re: the risk of groundwater flooding is too high and that extra houses would make sewage pollution matters worse and I call for Wakeham’s Pond Field to be de-allocated in the new Local Plan.

I support the 2022 Appeal Inspector’s findings on Wakeham’s Pond Field (Pett Level Road, Fairlight Cove, Fairlight) regarding the high risk of groundwater flooding and that extra houses would overload the already strained sewage system locally, making sewage pollution matters worse within the village and in the wetlands in Pett Level and in seawater, and therefore I call for Wakeham’s Pond Field to be de-allocated in the new Local Plan until those significant issues have been addressed.

Even once the sewage and drainage issues have been addressed, I call for Wakeham’s Pond Field to only be included as a site for house building if the number of dwellings to be built on the site is restricted to 30 (with social housing and affordable housing included), because:

• A greater number of dwellings would represent significant growth in a rural village location where access to services and infrastructure by public transport is limited, and increased car use will put a strain on narrow country roads.
• The site is physically separated from the rest of the village
• The local primary schools, doctors surgeries and dental surgeries (and other services) may not be able to support the population growth from a larger number of dwelling.

The draft Housing and Economic Land Availability Assessment (HELAA) Part 2: Site Assessment, identifies ‘Land east of Waites Lane, Fairlight Cove’ (FA10001) as having potential for up to 35 homes. The National Trust owns significant agricultural land holdings at Fairlight and Old Marsham Farm, between Fairlight village and Cliff End. This includes Marsham reed bed (3.34ha) located approximately 1.35km north-east of potential residential site FA10001. Marsham reed bed forms part of the Dungeness, Romney Marsh and Rye Bay SSSI and is identified as unit 149 Old Marsham Farm by Natural England, with a lowland, fen, marsh and swamp habitat.

The National Trust has been sampling watercourse quality over the last five years (2019-2023) and has evidence that shows a deterioration in water quality flowing into Marsham reed bed from upstream over this time, having an adverse effect and deterioration of habitat within the Ramsar site.

Fairlight’s current sewer network acts as a combined sewer, taking both surface water and foul water. The village has current and historic flooding events, particularly in times of heavy rainfall, with significant excess water entering the system causing flooding. The frequency of storm overflow discharges into the ordinary watercourse is potentially increasing with more storm events due to climate change. The significance of the problem has been identified by Southern Water who have made Fairlight one of their Pathfinder projects with the aim of trying to understand and manage the flows within the Fairlight catchment, but this will take time.

The Trust are concerned that new development on land east of Waites Lane, Fairlight Cove will add additional burdens to the existing foul and drainage infrastructure servicing Fairlight village which is currently inadequate. The key watercourse for the potential development site is a drainage ditch which flows along the southern boundary from west to east, into National Trust land at Old Marsham Farm, crossing in a northerly direction to the Fairlight Wastewater Treatment Works (FWTWs). The FWTWs sits within and is surrounded by National Trust land. The stream then flows north and drains into the Royal Military Canal, then via the River Brede to the sea at Rye. National Trust sampling using biotic index analysis shows that from the source of the Fairlight stream to the entry of the Ramsar, which is approximately 3.5km you would normally see stream water being re-oxygenated, but this does not happen, with a much lower score at the end of the stream than at the source.

The Trust therefore supports Policy ENV1, criterion iv) which will require all development within the catchment area for the Dungeness, Romney Marsh and Rye Bay SPA/Ramsar to demonstrate:
(a) ‘agreement by the wastewater provider that modelling demonstrates that there is sufficient capacity within the relevant waste water treatment works for the development to be accommodated without a negative effect on the receiving environment; or
(b) that the development can be delivered without a negative water quality effect on the Habitat Sites, and the means by which any necessary protection measures will be secured for the lifetime of the development’.

Although we support this policy, policy wording could be strengthened further by requiring development to demonstrate both criterion, rather than (a) or (b) to ensure habitat sites are protected. Policy wording for criterion (a) could also be strengthened by consideration of water volumes during storm events, for example ‘that there is sufficient capacity within the relevant waste water treatment works, including during storm events for the development to be accommodated without negative effect on the receiving environment’.

As stated at paragraph 5.7 of the draft Local Plan, development will only be acceptable where it does not have an adverse impact on the natural environment. It is therefore imperative that the development strategy takes a sequential approach to identify suitable land for development that is at lower risk of flooding from all sources. If all site location options have been exhausted and potential site FA10001 Land east of Waites Lane, Fairlight Cove does come forward, development should be used to reduce flooding within the Fairlight catchment. The Trust therefore strongly supports proposed Policy ENV2 which will require sustainable drainage to be an integral part of the proposed development and its design. For this location, we particularly endorse criterion (ii) which will require peak run-off rates to be lower than the greenfield rate in terms of volume and flow, and also criterion (vii) which will require new development to utilise opportunities to reduce the causes and impacts of all sources of flooding, ensuring flood risks are not increased elsewhere.

The Trust consider it critical that adequate wastewater treatment infrastructure is in place to serve any potential development prior to any development commencing. For site FA10001 which has the potential to impact a highly sensitive environmental site the Council should consider requiring development to pass through an additional treatment stage, as proposed for other sensitive locations, such as Pevensey Levels.

It will also be importance that appropriate pollution control measures are in place both during construction and in operation, to ensure there are no adverse impacts on the quality of receiving waters and that appropriate operation and maintenance arrangements are in place for the SuDS components for the lifetime of the development. We therefore welcome and support proposed Policy ENV2 criterion (i) which will ensure the ongoing maintenance of SuDS.

I support the 2022 Appeal Inspector’s findings on Wakeham’s Pond Field re: the risk of groundwater flooding is too high and that extra houses would make sewage pollution matters worse and I call for Wakeham’s Pond Field to be de-allocated in the new Local Plan.

I would like to raise an objection to the above site being considered for 14 new houses. The lane it sits on is a small narrow country lane. The area has no infrastructure to support these new dwellings. The character of these houses will not be in keeping with the other properties. This will have a detrimental effect on those living in the lane. By way of more noise, disruption of more vehicles and danger to those using the lane. There is a school nearby, which makes the road busy and potentially hazardous at school times, having even more traffic using it. The suggested site sits on an area of Aonb which should be protected.

FA1001 - Is in Pett Level Catchment area. Always been a wet field as it retains significant amounts of water run off. Unlikely that any development could mitigate what water the land currently holds.
FA1009 - Completely unsuitable for residential development. Narrow country lane, highly rural landscape in elevated position. Pett Level Catchment area.
GUE0012 - This is a very large development which would completely alter a small single track country lane. Access for even small lorries from the A259 is not possible due to historic road layout/green and parked vehicles. Access for large vehicles from Friars Hill is difficult. Disruptive to pick up and drop off of local primary school. Last occupant of the ESCC left due to problems with access for their vehicles.
FAI0015 - demonstrates why the Fairlight Hastings green barrier should include all of the Marsham Valley/Pett Level catchment area. Exposed location in AONB.

The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development. Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland.
The Ancient Tree Inventory (ATI) for the area may be incomplete. We therefore recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across any sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF (paragraph 186c) for the protection of irreplaceable habitats.

We support the 2022 Appeal Inspector’s findings on Wakeham’s Pond Field re: the risk of groundwater flooding is too high and extra houses would make sewage pollution matters worse and we ask for Wakeham’s Pond Field to be de-allocated in the New Local Plan.

In general terms any housing development in Fairlight would suffer for the following reasons:-

Wakeham’s Pond Field is known to hold surface water. Last winter the houses which backed on to the field, especially those on Pett Level Road, had their fronts under water for lengthy periods.

The village already has problems clearing surface water and sewage, and the new Market Garden Houses (heavily opposed locally at the planning point for adding to sewage problems) have yet to be occupied and connected.

This problem alone should exclude the site from being included in the development plan, but additionally the village has other shortcomings ;

Only one small shop just outside the village which is limited and expensive

No schools that can be reached by walking, cycling or by bus. School journeys can only be facilitated using cars on poor quality, narrow roads.

Narrow and poor pavement on Pett level road which involves three road crossings in its short length, one on a blind corner. Traffic coming down Battery Hill into Pett Level Road is frequently speeding, making crossing dangerous. The pavement is overgrown and cannot be widened.

No Post Office, no library, no doctors surgery, no other essential shops or services. All require visits to local towns. The bus is infrequent and often cancelled without notice.

I am writing to add my thoughts on the planning for 14 houses on Chapel Lane.

This would strongly affect a number of elderly family members I have within the village , in Chapel Lane and others close by in particular.
The increased traffic would be damaging for both residents and visitors to the lane and users of the surrounding roads which are already increasingly busy.

The extra housing would make a big difference to the village in general and the extra traffic would also be a safety risk for wlakers/dog walkers etc, therefore I am strongly against it.

Please see attached comments from Burwash Parish Council.

I am writing in response to the Draft Local pan 2020- 2040 ROTHER District Council and my
concerns regarding the proposed housing development in Chapel Lane Guestling.
Please see my concerns in point form:
1. This proposed site will feed off a lane not a road. by definition a country lane is A narrow
road in the countryside whereby vehicles travelling in opposite directions must slow or
stop to pass
2. At present this lane has restricted access at both junctions of the lane and most of
Chapel Lane is single track use already. By increasing the traffic flow on this lane, it will
severely compromise the residents and increase the likelihood of road/pedestrian
accidents down this lane. It is well known locally that lorries do not use this road for
access purposes because it is not suitable for large heavy vehicles.
3. The suggestion that Guestling is on the ‘fringes of Hastings’ is questionable. Ore village
is physically on the fringes not Guestling which is 3 miles away from central Hastings
town.
4. The proposed area comprises of areas of greenbelt and AONB, with ancient woodland
ancient adjacent to the proposed site. It needs to be considered and protected. Other
authorities Kent being an example have already demonstrated the ruination of rural sites
and built indiscriminatory on country land. We now have a conglomeration of housing
estates which have no delineations and have destroyed village communities and
identities. I do not want that to happen in Guestling.
5. This development will not enhance or protect the wildlife, habitats or ecosystems which
already coexist in the area. On the contrary this will have the opposite effect; any
disruption be it noise light or physical activity will alter their landscape forever. I am not
convinced any consideration has been given to this fact.
6. I have resident bats in my property and have recently had a bat survey that identified 6
species of bats occupying the local area. Bats survive in various habitats for different
periods and reasons; they will roost and socialise/mate in various habitats during the
calendar year. They will forage for food over several km every night. My house sits within
a prescribed area near the proposed housing estate therefore it is fair to assume that
any activity will seriously disrupt and interfere with the bat’s habitat and welfare. I am
not convinced any reference or consideration will be given to the bats and their rights for
the sake of building 14 houses.
7. There is no infrastructure to support new residents; the local schools and GP surgeries
are oversubscribed, and local public transport is limited.
8. I understand there is a shortage of housing stock nationally, but this building plan is
tokenistic and there other options to help the shortfall. Looking at unoccupied houses
and holiday lets/ Air BB will free up more appropriate local housing. There is always a
possibility that the proposed housing could also be purchased as holiday lets.
Reading the Draft local plan, I feel there has been very little reference or sensitivity has been
given to existing local communities and residents. I also cannot see where there is enough
emphasis and recognition that inevitably there will be a knock-on effect to the surrounding
countryside and wildlife.

Representation to oppose site in Fairlight and other general comments on the Local Plan