Please see attached comments on draft Local Plan, including Brede Valley Landscape Assessment and East Sussex Landscape Assessment.

Please see attached comments on draft Local Plan, including Brede Valley Landscape Assessment and East Sussex Landscape Assessment.

I would ask if we could have a bus service from Sedlescombe to and from Battle, after all our address is Sedlescombe, Battle!

I would like to pick up a traffic/parking issue on the North Trade Road.

The car park entrance to Battle recreation ground is dangerous to enter and leave from as there are parked cars opposite. There should be double yellow lines along the area of 1- 10 Wellington Gardens.

The cars constantly beep each other on this stretch of road and residents vehicles have been hit numerous times.

The traffic flow is too fast, from Claverham school to the roundabout, it should be dropped to 20 mile an hour, school children are at risk and children using the park.

Heavy goods vehicles should be stopped using this cut through to the A21, the houses shake and are moving, and walls cracking and again it is very dangerous for pedestrians as the larger lorries are right on the curbs.

I am a resident in Battle and am witnessing visually and hearing daily the chaos on the road outside where I live.

1-10 Wellington Gardens should have parking opened up on the front lawn area the Council maintain.

I hope someone can look at this, it's an accident waiting to happen.

Some smaller scale development is possible in more rural parts of Rother but needs sensitive planning, especially for restricted impact on the natural environment. Maybe try to put pressure on central government to incentivise smaller builders to be able to make smaller sites profitable enough to develop?

Catsfield site allocation CAT0001 (HELAA Identified) has recently had an outline planning application submitted and withdrawn before it was refused (Application RR/2019/257/P). Previous applications for much smaller developments on this site have also been rejected (Applications A/70/522 for one dwelling and A/70/526 for 3 dwellings). A FOI request made to RDC has revealed the planning officers final report recommending refusal for the most recent application of the proposed 35 dwellings (as identified and proposed by the HELAA) and other associated documentation, which showed some of the reasons for refusal. These should be reviewed and considered before finalising this future Local Plan and HELAA as they show that; - The site is actually not appropriate for development (it contravenes National and RDC's own policies). - Development of the site would cause a significant health, safety and wellbeing risks to local residents and the local community due to it being in a 'red zone' for flood risk, cause over population and cripple the already inadequate local infrastructure (highways, health provision, poor utility quality and provision, lack of education facilities in the village and surrounding area, etc). - 1.6 hectares is not adequate for a development of this size and does not meet planning guidance for density of development in a rural village location. - Development of the site would destroy the habitat of protected and endangered wildlife which currently resides there (as documented in the ecology report submitted to RDC planning dept). This site falls within the 'red zone' for Great Crested Newts and is home to a large number of protected and endangered species of wildlife, flora and fauna (inc bats, badgers, hazel dormice, etc). All of which are fully protected under the Wildlife and Countryside Act 1981 and The Conservation of Habitats and Species Regulations 2017, also making them European Protected Species. - The site falls within the High Weald AONB, which according to policy, can only be developed in 'exceptional circumstances'. This site and proposed number of dwellings does not fall within this caveat. The number of dwellings proposed for this site (35 dwellings) is classified in the planning documents as a 'Major development', which is not permitted within the HWAONB. - The site is subject to a blanket Tree Protection Order (TPO) and is adjacent to properties with listed status. These would all be severely impacted by any kind of development/construction on this site. - The northeastern boundary of the site falls within the Pevensey levels Hydrological Catchment and RAMSAR Area. - The Delegated Officer Report - Assessment of Case, should be referred to before finalising this draft Local Plan/HELAA and before any further consideration of the continued allocation of site CAT0001. The report's conclusion (and reasons for refusal of outline planning) states; - The proposal would cause significant harm to the local landscape character of the AONB and the rural settings of the nearby listed buildings. - The submitted information concerning the impact of the proposal on ecology and biodiversity and the proposed biodiversity mitigation and enhancement measures are considered to be inadequate. - The proposed development of 35 dwellings by reason of its layout and scale and disregard to landscape features such as trees and road hedgerows would be out of character with the site and surrounding pattern of development and would materially harm the intrinsic character and appearance of the locality and scenic beauty of the High Weald National Landscape (Area of Outstanding Natural Beauty). As such, the proposal is contrary to policies OSS4, EN1 and EN3 of the Rother Local Plan Core Strategy (2014), policies DIM2, DEN1 and DEN2 of the Rother Development and Site Allocations Local Plan (2019), paragraphs 135, 136 and 182 of the National Planning Policy Framework and, Objectives S2, S3 and FH2 of the High Weald Management Plan. - It has not been demonstrated that the proposal complies with policy EN5 of the Rother Local Plan Core Strategy (2014), policy DEN4 of the Rother Development and Site Allocations Local Plan (2019) and, paragraphs 180 and 186 of the National Planning Policy Framework. - The proposed development (of 35 dwellings) due to inadequate drainage strategy and lack of flood risk management strategy for high groundwater could increase risk of flooding within site and elsewhere, contrary to policies EN6 and EN7 of the Rother Local Plan Core Strategy (2014) and paragraphs 173 and 175 of the National Planning Policy Framework. The final paragraph states; - NATIONAL PLANNING POLICY FRAMEWORK: In accordance with paragraph 38 of the National Planning Policy Framework the Council works in a positive and pro-active way with Applicants and looks for solutions to enable the grant of planning permission. However, in this case the proposal is not sustainable development for the reasons set out and the Council was unable to identify a way of securing a development that improves the economic, social and environmental conditions of the area. Planning applications for other sites in Catsfield with the same features as this site (e.g. The Brooks) have been refused and the site deemed as unsuitable in the HELAA. This site should be assessed in the same way, deemed unsuitable for development for the same reasons and subsequently removed from the HELAA as an allocated site for development, as should site CAT0016 for the same reasons.

We are supportive of the Council’s vision for Battle and surrounding settlements and its acknowledgement that small levels of growth are needed to ensure the health and wellbeing of these villages are maintained and improved. However we do not believe that all opportunities for growth have been explored,especially within Sedlescombe which is identified as a sustainable village with potential for growth.

Please see attached comments from Burwash Parish Council.

I am writing to formally object to the Rother Draft Local Plan reference number BAT0083 which concerns the building of five houses on a private lane.

The lane is single track so is liable to become blocked when any emergency vehicles attend the Nursing Home there. It does not have any passing places and cannot cope with an additional ten cars serving the five houses. A lovely mixed hedge adjacent to the road would be destroyed during construction of the houses. The houses would also spoil the views from the south. The location is two miles away from the town centre and the bus service is poor, as it has recently been reduced to cut costs.

I urge the council to reconsider this plan as it damages the environment of our community for very little gain.

See attached

See attached documents containing from Wates Developments containing:
1) The Consultation Response;
2) A Vision Document for HELAA Site BAT0014: Land at
Almonry Farm, North Trade Road, Battle; and
3) A Transport Note for HELAA Site BAT0014.

See attached full representation

Please see attached full representation

On behalf of my client, I write to make submissions to the Rother District Regulation 18 Local Plan consultation. My client has control over land west of Netherfield Court, Netherfield Road, Netherfield, TN33 9PX
These representations relate in particular to the following parts of the Regulation 18 document, titled Rother Local Plan 2020-2040:
•
Housing Need
• Preferred Spatial Development Options
• Relevant Draft Local Policies
A site plan outlining the land promoted for development is included at Appendix 1 and has been considered under the HELAA under reference BAT0065.
Housing Need
The key objective to significantly boost the supply of housing remains a focus of planning policy at all levels. Paragraph 60 of the NPPF states that to support this aim it is important to ensure a sufficient amount and variety of land can come forward where it is needed.
In addition, paragraph 11b of the NPPF states:
‘Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i.
the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area;
or
ii.
any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.’
The Regulation 18 consultation identifies the housing need in the district as 14,660 homes for over the twenty-year plan period 2020 to 2040. This figure was identified in the Housing and Economic Development Needs Assessment (HEDNA, 2024), and was derived using the Standard Method, as required by the NPPF and accompanying Planning Practice Guidance (PPG). This amounts to 733 dwellings per annum. It is not clear from the Regulation 18 consultation whether this figure includes a 20% buffer to be applied as a result of under delivery as set out at paragraph 77 of the NPPF. If the 20% buffer has yet to be applied, housing requirement would increase to 879 dwellings per annum -17,580 dwellings over the plan period.
In any event, the Council have confirmed they do not in fact intend to meet their full housing need (as calculated by the standard method) for a number of reasons most notably the significant landscape and flooding constraints which exist across the district. We accept that footnote 7 of paragraph 11 of the 2023 NPPF allows for a reduction in housing delivery in areas restricted by certain designations, including National Landscape, of which a significant part of the Rother District falls within. However, we do not consider the lower housing figures offered in the Regulation 18 Consultation have been justified or that sufficient reason has been given for not meeting the higher housing need figure identified within the ‘range’ put forward by the LPA, as discussed below. It is acknowledged that the Council have stated that the final figures to be put forward for adoption will be ‘minimum’ figures. However, the history of under delivery of housing since the adoption of the Core Strategy is well documented (as set out paragraph 5.3 of the Regulation 18 Plan) which makes all the more pressing case for the Council to be taking a more radical approach to positively plan for a higher level of housing.
The Council have made a passing reference in the Regulation 18 plan to a number of reasons as to why the housing need figure calculated using the standard methodology cannot be met including:
•
Landscape constraints
•
Constraints resulting from areas lying within flood zones
Beyond a passing reference to environmental constraint, the Council has not set out in detail why they cannot meet their full identified housing need, yet seem to acknowledge the need to plan for higher levels of growth by running an additional call for sites alongside the Regulation 18 consultation. The land west of Netherfield Court would not be constrained by any of the landscape or flooding constraints cited by the Council as reason to not meet full identified housing need.
Whilst it is located within in the High Weald National Landscape (formerly AONB), the land to the west of Netherfield Court is considered to be capable of accommodating some development without adverse effect on the natural beauty of the High Weald which underpins the designation of this area. The land is located entirely within Flood Zone 1 meaning it is not in an area of the district which is at risk of adverse flooding.
Netherfield has a range of day-to-day facilities that can be accessed from the site, including a primary school and post office. There are also bus stops within Netherfield which provide a number of services to Battle and Heathfield where a wider range of day-to-day facilities can be found.
Paragraph 70 of the NPPF recognises that small scale developments can deliver housing at a faster rate. The land is owned outright by Mr Longbottom and so there are no third-party ownership issues which might prevent or delay development. It is anticipated that a small-scale development here could be delivered at a relatively quick rate.
In accordance with the Government’s objective of significantly boosting housing supply we contend the Council should pursue a higher growth strategy to fully meet the full identified housing need for the plan period. Adopting this approach will allow the Council to develop a long-term sustainable growth strategy which provides flexibility to adapt to changes in demand and allow for the inevitable cases where development does not come forward for some reason or under delivers. This is particularly the case given the history of under delivery in the district. It would also allow for a more consistent delivery rate, allowing for a wider range of smaller sites to be delivered while the infrastructure is put in place to serve larger developments.
Proposed Strategy: Overall Spatial Development Strategy
The Regulation 18 draft local plan identifies a number of spatial strategies across the district to respond to different circumstances, including small-scale development in villages surrounding Battle, at densities consistent with the surrounding area, where it is sustainable and does not negatively impact the setting of the High Weald National Landscape.
We support the principle of employing a number of spatial strategies to provide the flexibility to respond to differing circumstances. As a village on the outskirts of Battle, Netherfield is well-placed to take some additional growth. Figure 21 of the Regulation 18 plan identifies housing growth of 33 dwellings based on existing allocations in the Battle Neighbourhood Plan. The Regulation 18 plan does not seek to add any additional development to Netherfield beyond the Neighbourhood Plan allocations. The existence of allocations for housing growth in the Battle Neighbourhood Plan is an indication of the fact that Netherfield is considered to be a suitable location for housing growth and we would contend that moving forward additional allocations for small-scale development should be made in Netherfield.
This is particularly the case as the Neighbourhood Plan allocations for Netherfield have existed since 2021 yet no development has been brought forward on any and there is no guarantee that these allocations will be delivered. One allocation site (White House Farm) has been the subject of a planning application which was submitted in January 2023 and remains undecided due to a number of unresolved objections from statutory consultees. The other allocation site (Swallow Barn) has been the subject of two planning applications which have been refused on a number of grounds including concerns over the proposed access arrangements. It is worth noting that the applications at Swallow Barn have been for 5no dwellings and 4no dwellings respectively as opposed to the 10no dwellings identified in the adopted allocation policy. This factor alone provides justification for making additional allocations within the Netherfield area to ensure that at the minimum the quantum of growth identified under the Neighbourhood Plan is still delivered.
Vision for Battle and Surrounding Settlements
The vision for Battle indicates allowance for ‘small-scale development in villages surrounding Battle, at densities consistent with the surrounding area, where it is sustainable and does not negatively impact the setting of the High Weald National Landscape’. The submitted land is situated in a settlement in the area surrounding Battle so in principle is in line with this aspect of the proposed policy. The land has the potential to deliver small-scale development which is respectful of the character of the High Weald National Landscape it lies within.
Proposed Policy DEV3: Development Boundaries
Proposed Policy DEV3 states that ‘Development boundaries define the area within sustainable settlements where development will be permitted, provided it is consistent with this Local Plan’.
The explanatory text for this policy explains that settlements identified within Figure 38 (which includes Netherfield) will have their development boundary reviewed as part of the next stage of the Local Plan process.
The development boundary of Netherfield is currently set out in the Battle Neighbourhood Plan, as included in Appendix 2. The boundary on the eastern side of Netherfield is on the eastern boundary of Netherfield Primary School and the properties immediately to the south of the primary school. The development boundary as identified excludes significant amounts of existing built form within Netherfield including facilities such as the village hall and Netherfield Arms. We would contend the development boundary for Netherfield requires a comprehensive review so that it is extended to take account of existing built form and facilities. As part of such a review the development boundary should also be extended to take into account any proposed allocations which could include our clients land.
Proposed Policy DEV5: Development on Small Sites and Windfall Development
This policy recognises that historically, small sites and windfall development have played a role in the delivery of housing growth in the District and seeks to continue this reliance. We support the inclusion of this policy.
Site Specific Considerations
The submitted land identified at Appendix 1, lies on the outskirts of Netherfield.
It is noted that Netherfield has been identified within the supporting ‘Settlement Study’ as a settlement of low sustainability despite having three ‘Essential Services’. The reason for this is cited as being low scoring in terms of public transport options. We would contend that given the presence of a relatively high level of essential services (for a settlement of its scale) and the fact that it has been allocated for growth under the Battle Neighbourhood Plan the categorisation of the settlement as a settlement of ‘low sustainability’ should be reconsidered.
Notwithstanding the categorisations of Netherfield as a ‘low sustainability’ settlement it is noted that paragraph 7.25 of the Settlement Study states: ‘Some exceptions are Catsfield, Dallington, Netherfield and Woods Corner, which have each scored 3 out of 5 for access to essential services and could benefit from the provision of additional essential services and/or better public transport accessibility. They could potentially be considered sustainable locations for limited amounts of development, depending on the recommendations of the Development Strategy.’
Coupled with the identified strategy for small-scale development in villages surrounding Battle it is considered that additional growth beyond the Neighbourhood Plan allocations should be considered for Netherfield.
Our client has control over land to the west of Netherfield Court amounting to 2.42 hectares. The land benefits from an existing field access in the south-eastern corner directly onto Netherfield Road although alternative options for a new access along the site frontage could also be explored. It is understood that previous discussions with the Highway Authority secured in-principle agreement to a new access point further west along the site frontage. If this was pursued as an alternative arrangement it would enable existing trees in the south-eastern corner of the site which are subject of a Tree Preservation Order to be preserved and an appropriate buffer from any forthcoming development maintained.
The land is largely vacant agricultural grassland which is not covered by any ecological designations. The boundaries are secured by trees and hedgerows. The retention of the existing tree cover would enable development on the site to be well-screened from adjoining residential properties.
There are no public rights of way within the vicinity of the site and the sites lies within Flood Zone 1.
On the basis of a capacity of 25-45 dph dwellings per hectare (in accordance with proposed policy LWL1) the site would be capable of accommodating up to 60 dwellings as a minimum. However, taking account of the plot sizes surrounding the site and the need to set aside areas for biodiversity net gain it is considered that a lower level of dwellings would be more appropriate likely to be in the region of 6 dwellings focused on the front (southern) portion of the site. It is noted that the HELAA assessment of the site raised concerns about the landscape impacts of development on this site. We would contend that by pursuing a lower level of development focused on the front portion of the site landscape impacts could be minimised. Any forthcoming application would be supported by detailed examination of baseline and future landscape features. Through a Landscape and Visual Impact Assessment, the impact of development on the character of the High Weald NL would be assessed and the layout of any forthcoming scheme guided by this.
There are no listed buildings within the vicinity of the site which might be impacted by development of the submitted land.
Netherfield benefits from a number of day-to-day facilities including a primary school, village shop, post office & café and 2no Public Houses. These are all within walking distance of the site although it is acknowledged that a proportion of this distance there is no dedicated footpath. Netherfield lies within relatively close proximity to Battle which has a full range of day-to-day facilities. I trust that the enclosed information is clear and I look forward to receiving confirmation of receipt of this submission.
In the meantime, should you require any further information, please do not hesitate to contact me.

See attachment for the full representation.

Q1: Re: "1.7 The plan sets twin overall priorities (‘Green to the Core’ and ‘Live Well Locally’)" - I applaud the ambition, but am concerened to see, additionally, a clear statement that BOTH priorities are EQUAL, even if one has to written before the other.

Q6: This is a highly technical policy that really needs another section before ()A) for application to small developments, being undertaken without the benefit of highly qualified experts.

Q9: Agreed a good Policy

Q11: Agreed a good Policy

Q18: Re: "3.36 The opportunity for the development of wind turbines within the district, is extremely limited..." - I beleive very small scale wind power turbines down to single dwelling capability should be considered since technology could deliver economical useful machines within the timescale of this Plan.

Q22/23: RE: "All qualifying development proposals must deliver at least a 20% measurable
biodiversity net gain..." - understood but the metric for qualification is not easy to find?
Agreed a good Policy to go beyond 10%.

Q25: Agreed a good Policy

Q28: Re: "a. Urban areas in Bexhill, Battle and Rye: 60-90+ dph, with higher densities
around transport hubs and town and district centres.
b. Suburban areas in Bexhill, Battle, Hasting Fringes and Rye: 45-75 dph." - it is hard to understand the difference between Urban and Suburban, even with Fig 8? Until 4.15 work is carried out I reserve my judgemment on this Policy.

Q32: In essence a good policy, but some examples e.g. bank have long since gone even from towns within Rother so hardly an OK exemplar. I wonder if 800m is the right parameter - in my road many residents would get their car out for such a distance, few possibly only 20% would walk that distance.

Q33: Whist overall I agree this is a good Policy - I think it needs to be more clearly sectioned, maybe even several seperate Ploicies. Re: "g. Appropriate signage and wayfinding." -this has often or nearly always been overlooked - so a very welcome improvement.

Q35: I particularly like this policy and the 400m parameter, which of course certainly should apply to the Blackfriars development - so a major step forward if it is applied, since previously RDC has in effect only considered on-site access not off-site access.

Q37: I am concerned that no mention is made of former PRoW (FPs) being re-routed through development sites across multiple driveways; rather tah finding contiguous routings through or outside the site connecting to the existing network without having to contend with multiple drive crossings. Though see also Q104 comment.

Q38: Agreed about ixc) Shared Use Routes - the higher age range demographic deprecate shared use, due to (anecdotally) cyclists lack of concern for less ambulant walkers. Very little chance of people buy-in to Demand Responsive Transport, car clubs and car shares!

Q45: Agreed a good Policy; though I note: "inclusively designed so that people with visual, mobility or other limitations will be able to use the street confidently and safely.", so do not see why "iii) Dementia Friendly District" is highlighted, when it would be better to categorise as for example "those with reduced sensory perceptions and mobility"?

Q51: Agreed a good Policy. Crowhurst should be in the Battle SDO; whereas it may be better to exclude Sedlescombe for the battle SDO, due to the decisive split that the A21 causes and Sedlescombe fees more adjacent (connected) to Westfield. Quite evident in Fig 12.

Q62: Re: "5.56 Battle is a small, historic market town." Umm - not a good summary, it should be: "Battle is a small, historic FORMER market town.", since all banks now gone...

Q74: This policy area is so heavily over burdened by national and county council legislation and determination, I recommend the LP only provides for the minimal provision since there is nowadays negligible agricultural seasonal employment upon which much of the legislation appears to be based.

Q76: Fig 35/36 - I do not agree that Battle has " Greater opportunity for growth, since already the constraints discussed show minimal opportunity e.g. NPPF/NL conditions. Furtermore the employment locations expansion in Battle are, as the Neighbourhood Plan Calls showed, almost negligible and certainly not as RDC pushed for when the NP was being developed.

Q84: Agreed a good Policy.

Q90: It is hard to understand why the RDC/Inspector refused to allow the proposed Gap along the Hastings Road at Telham was not allowed in the Battle NP, given these arguments it would have enhanced the protection: "The Gap between Battle and Hastings/St Leonards provides an important function in maintaining the separate identities of Battle and the built-up area of Hastings/St Leonards. The break in the ribbon development between the edge of Telham and the Hastings Borough boundary at Breadsell Farm is highly vulnerable to change particularly in more open areas and the higher ground and ridges."

Q96: In view of the source of this Policy will it now be applied Rother wide?

Q104: Agreed a good Policy. I welcome this new Policy, especially the aspects regarding diversion of FPs within development sites be required to deliver "equivalent" access and "must be replicated" See also comment to Q37.

Q109: Agreed a good Policy.

Q112: Agreed a good Policy.

Q119: I do not favour "100% affordable housing schemes". Surely "pepperpotting" is a better solution?

Q121: Given my comment on Q119, I do not really agree with is Policy, however given the intent for "substantially affordable housing", I would accept the need could be so satisfied.

Q125: Agreed a good Policy.

Q131: I welcome further work on this need.

Q133: Agreed a good Policy.

Q147: I would like to see a strengthening to no permission would be given to changing natural boundary hedges and trees.

Q149: Conversions/extensions of an older wood construction building by using modern brick construction, for example, should not normally be permitted, since they would significantly alter the street scene.

Q153: Agreed a good Policy, however I do not agree that in 8.179 Laurel is preferred - it is too fast growing and likely to over burden other growth.

Q170: Agreed a good Policy. I particularly welcome "xi) Where practicable, the track is opened as a path for permissive public usage or as Public Right of Way, and should be accessible from the existing Public Rights of Way network", since this would make the applicant aware that they could provide a beneficial PRoW spin-off from their operations, not previously or normally offered.

Q178: Agreed a good Policy.

Q180: Agreed a good Policy.

Q182: Agreed a good Policy. Welcomed and for reasons of energy saving an emphasis on PIR use should be paramount.

Q195: Agreed a good Policy. But I am confused by this wording: "vi) For Ancient Woodland, create a development buffer zone of at least 15 metres. An impact assessment will be required where any development is proposed within 25 metres of Ancient Woodland to demonstrate that the proposed buffer zone avoids negative effects on the habitat.", since surely a single buffer zone of 25m would suffice?

Appendix 2: Surely "Market square including Jempsons shop and others should be considered as in the "Battle Town Centre and Primary Shopping Area", even if not contiguously connected? The south-eastern limit of the appears to miss out several shops/cafes of importance...

Q208: "proposed monitoring framework" appears to be a comprehensive methodology to adopt. but i wonder how it will be reported?

Please accept this response to your consultation on the draft local plan for Rother 2020-2040 as your online consultation webpage is difficult to navigate and I became totally lost in the bureaucratic jargon and only managed to reach page 260 before burn-out.

The Draft itself is difficult to decipher what is actually being said, requires much cross referencing with other lengthy, confusing documents and I have had to deal with this draft in a ‘bite-size’ manageable way so may well miss important points, which I hope others will pick up on.

In short, the summary of many hours of reading:
Housing should be confined to brown/grey field sites, in urban surroundings that can cope with the demands of contemporary living, before greenfield sites (especially the HWNL) are even considered.
The Local Plan does not set any limits on anything so cannot possibly have any value as a plan for sustainable development. Development with no limits is unsustainable.
Please provide a map of the development boundary for Catsfield. (For example page 224, DaSA adopted 2019). Maps like this provide clarity for the lay-person rather than struggling through huge documents such as the Draft Local Plan, the HELAA reports, HEDNA etc. but unable to locate any meaningful maps.


RESPONSE TO QUESTIONS:

Q2. What are your views on proposed twin Overall Priorities to be ‘Green to the Core’ and ‘Live Well Locally’?

I have to disagree that RDCs vision is achievable. On the face of it the vision appears to indicate a respect for the environment and the rural communities within, but simply introducing the word ‘green’ does not equal sustainability and, likewise, the word ‘well’ is simply subjective. Therefore, rather than slogans which are open to interpretation or challenge by developers with their eye on today’s profit not tomorrow’s generations, perhaps something a little less open to subjective interpretation would be better. Ie. Today’s priority is tomorrow’s environment. It is clear that we need to protect our environment, both natural and built, because we won’t get a second chance tomorrow. The High Weald National Landscape must be protected as this will be our legacy to following generations – this is sustainability. A climate emergency and protecting our National Landscape is in absolute contrast to the aims of profit-driven developers and speculators, so the question is, how will RDC make developers/speculators adhere to these twin priorities and share their vision?
Regarding Catsfield where I live: The proposed number and design of dwellings on CAT0001 and CAT0016 sites in the HELAA report is really too large for the rural character of the village to subsume into the settlement and should be decreased. Large housing estates will urbanise the rural character - already seen in Ninfield in Wealden district. Therefore, such large housing estates are neither ‘green to the core’ nor beneficial to residents.
Why has Catsfield been singled out to provide 60 new dwellings when other villages have a nil target? How is this figure determined? Is the development boundary for Catsfield being altered without resident’s knowledge?
Q3. What are your views on the key issues (listed at paragraph 2.13) that have been identified and is there anything significant missing?

Simply carving up the country-side will not make houses affordable. Brown/grey field sites must be used before green spaces.
For instance, BEX008 is earmarked for industrial use. Why isn’t the site earmarked for residential buildings if there is a national housing crisis? The infrastructure is already in place.
The site MOU0012 is a vacant industrial site - why is the landowner not incentivised to free up this site? Is he holding out for residential planning?
I understand RDC has a partnership with Hastings. Have they audited empty brownfield sites and properties together, such as the old Post Office, that could be refurbished for residential dwellings?
What is significantly missing is a clear brown/greyfield register for the area if RDC is to conserve its special landscapes such a the HHWNL. Such a register should be in the public domain.

Q22. What are your views on the Council’s proposed policy for Biodiversity Net Gain?

Conserving special landscapes like the HW National Landscape will not be achieved by building more houses over it. By definition house building cannot leave the natural environment in a measurably better state than it was beforehand. BNG can only be achieved on brown/greyfield sites. Brownfield/grey sites should be used first and RDC should make this clear in the Local Plan. Please provide the brownfield maps to the public.

Q25. What are your views on the Council’s proposed policy for the High Weald National Landscape? Q26. Are there any alternatives or additional points the Council should be considering.

Hopefully, these policies will protect the HWNL. However, for the policy to be sustainable there must be clear limits and boundaries and there is not! Therefore, the policy has little value without limits.

Q27. What are your views on the Council’s proposed policy on compact development?

I am unsure what ‘compact development’ means in practice. I assume it means making the best use of infrastructure by building in those areas, predominantly urban, where infrastructure is already in place, which makes sense. In rural villages, like Catsfield, infrastructure is poor. Public transport is non-existent in Catsfield and residents rely on private vehicles to get to work, to shop etc. usually over poorly maintained roads and lanes. No mobile signal is available in the village and no fibre WiFi is available. Drains overflow, water pressure is low or nonexistent and the village regularly suffers from power cuts. This is all down to poor, unmaintained infrastructure but I made the choice not to live in an urban environment with its good infrastructure but enjoy our wonderful countryside of Sussex.
Again, housing should be confined to brown/grey field sites, in urban surroundings that can cope with the demands of contemporary living and if that is what ‘compact development’ means then I support that.

Q28. What are your views on the area types and densities proposed as a key driver to Live Well Locally?

Please advise where the current map of the development boundary around Catsfield can be found? 25-45 dwellings per hectare makes little sense to ordinary residents - please clarify before I can comment.

Q51. What are your views on the Council’s preferred spatial development options? Q52. Do you have any comments on the merits of the alternative Spatial Development Options, that do not form part of the preferred development options – as explained in the background paper? Q53. Are there any other development options that the Council should consider as part of its Local Plan?

These concepts are confusing to the ordinary resident and need to be explained in clear English. I cannot comment on something that is so confusing.

Q62. What are your views on the vision for Battle and surrounding settlements?

RDC’s target of 60 houses for the small village of Catsfield does not correspond with Rother’s vision quoted from Page 140 - 'Sensitive small-scale development will be delivered in villages surrounding Battle, at densities consistent with the surrounding area, where it is sustainable and does not negatively impact the setting of the High Weald NL.’
Needs a total rethink regarding the number of dwellings. However, Page 145 - para 5.60/61 introduces the idea that the target of 60 houses for Catsfield is purely hypothetical!

Q77. Do you agree with the principal identified by the Council of achieving a stepped housing delivery with greater levels of delivery planned for later in the plan period?
How will RDC incentivise developers to adhere to this principal? Without strict limits this principal is unachievable! Page 177 identifies a problem with land-banking by developers - 'there have been significant delays in the build out of sites.’ This practise needs to be penalised as it affects the price mechanism of houses thus pushing up prices. How is RDC tackling the issue of land-banking?

Q82. What are your views on the Council’s approach to development boundaries?
Page 186, para 5.119 - 'This Local Plan will review each settlement’s boundary, especially in relation to potential allocation sites.’ How can residents possibly comment on something they have not seen? Please produce the Development Boundary map for Catsfield so I can make an informed comment.

Q103. Do you feel that this policy is sufficient to protect open space?
No. The policies have no limits so developers will perpetually challenge them - mission creep.

Q104. What are your views on the Council's proposed policy on public rights of way?
PRoWs are a historic right and should remain. Not diverted nor ignored nor moved surreptitiously (which has been seen in Catsfield). New PRoW are always welcome!

Please see attached submitted document for full comments.

See attached document for the representation which addresses:
- Housing Need
- Preferred Spatial Development Options
- The Vision for Battl eand Surround Settlements
- Proposed Policy DEV5: Development on Small Sites and Windfall Development
- Proposed Policy ECO1: Supporting New Employment Development
- Proposed Policy ECO2: Protecting Existing Employment Sites and Premises
- HELAA sites CAT0013 (Piggery, Great Park Farm, Horns Corner, Catsfield) and CAT0021 (Nursery (glasshouses), Great Park Farm, Horns Corner, Catsfield).