Generally, green issues are under national guidelines. All Rother can do is try to enforce/encourage them. To reach lower emissions, which means using electricity more, we need to address a problem particular to Brightling, .i.e. reliability of electricity supply. This is proving to be very poor indeed and many of us now run emission busting generators.

Retrofitting of insulation is only as good as the people doing the work. So far, the record has not been good. However, an important step (together with the right rules on new properties) so this needs to be addressed in a professional manner. Where is the funding coming from?

Re-use of existing properties by changing to suit modern needs is good. At the moment it is easy to say a property is no longer fit for the purpose. There should be set criteria by which it is judged. Re-using not only saves on materials costs and energy, but also on demolition, clearing site and then re-delivering of new material all with its energy consumption. Local residents should be able to compile a description of what they see as "local style". A Bank for local building materials acquired through re-claim is an excellent idea. Would it be Council controlled or private as this could be open to unscrupulous acquisitions. (some will remember all our manhole covers being stolen not that many years ago!)

Water storage is something we need to look at, but how? Underground tanks? Then it is important to educate people in health and safety on re-use of this water.

Education should also play an important part in the conservation of nature. Many people do not see the huge variety we have around us, particularly in Brightling. (see Messenger articles on What to Look out for my contribution.)

Potential employment growth of 1861people (how do they know?) has been identified at Coldharbour Farm Estate. Will this be to the detriment of locals and other road users, with traffic movement, noise and unsightly commercial builders? What would the position be with other farms in the Parish where farming is clearly not a profitable enterprise and most having a back-up plan.

Residential development potential has been spotted in surrounding villages. This needs to be watched as there is a risk of increased traffic through Brightling as it is used as a rat run to get to other main roads, stations, etc.

Good luck with the 30 years vision for the A21!

To answer question 92/93 - Brightling is a very social village which communicates well, as proved during Covid. The internet is very important here and, thanks to Andrew, we now have super fast connection. This then leads back to the question of power supply....

Generally, green issues are under national guidelines. All Rother can do is try to enforce/encourage them. To reach lower emissions, which means using electricity more, we need to address a problem particular to Brightling, .i.e. reliability of electricity supply. This is proving to be very poor indeed and many of us now run emission busting generators.

Retrofitting of insulation is only as good as the people doing the work. So far, the record has not been good. However, an important step (together with the right rules on new properties) so this needs to be addressed in a professional manner. Where is the funding coming from?

Re-use of existing properties by changing to suit modern needs is good. At the moment it is easy to say a property is no longer fit for the purpose. There should be set criteria by which it is judged. Re-using not only saves on materials costs and energy, but also on demolition, clearing site and then re-delivering of new material all with its energy consumption. Local residents should be able to compile a description of what they see as "local style". A Bank for local building materials acquired through re-claim is an excellent idea. Would it be Council controlled or private as this could be open to unscrupulous acquisitions. (some will remember all our manhole covers being stolen not that many years ago!)

Water storage is something we need to look at, but how? Underground tanks? Then it is important to educate people in health and safety on re-use of this water.

Education should also play an important part in the conservation of nature. Many people do not see the huge variety we have around us, particularly in Brightling. (see Messenger articles on What to Look out for my contribution.)

Potential employment growth of 1861people (how do they know?) has been identified at Coldharbour Farm Estate. Will this be to the detriment of locals and other road users, with traffic movement, noise and unsightly commercial builders? What would the position be with other farms in the Parish where farming is clearly not a profitable enterprise and most having a back-up plan.

Residential development potential has been spotted in surrounding villages. This needs to be watched as there is a risk of increased traffic through Brightling as it is used as a rat run to get to other main roads, stations, etc.

Good luck with the 30 years vision for the A21!

To answer question 92/93 - Brightling is a very social village which communicates well, as proved during Covid. The internet is very important here and, thanks to Andrew, we now have super fast connection. This then leads back to the question of power supply....

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.

Sedlescombe is the most sustainable village out of those identified cluster settlements around Battle. The settlement study scores the village as having a good level of essential and non essential services and therefore is capable of accommodating more growth than identified. The settlement study identifies that public transport links could be improved and that new development could help deliver a more frequent service. Further opportunities should be sought for a greater level of growth in Sedlescombe to take advantage of the existing services and provide the necessary investment into the transport links. This would deliver benefits to both new and existing residents and make Sedlescombe a more sustainable village.

Please see attached comments from Burwash Parish Council.

Please see attached document for comments regarding:

- Constraints to further development in Catsfield
- HELAA site CAT0029 – Church Road
- HELAA site CAT0001 – R/O White Hart land
- HELAA site - CAT0016 – Wilton House Equestrian Centre land (actually part of the Normanhurst Estate).

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.

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.

Mountfield Parish Council (MPC) is of the view that there is little of concern within the Draft Rother District Local Plan.
MPC notes that no potential development sites have been identified in the Draft Housing Economic and Land Availability Assessment (HELAA) within the Parish of Mountfield. However, MPC is keen to seen affordable accommodation provided for younger parishioners and households and, consequently, should any potential exception sites become available it would be keen to help facilitate the provision of lower cost and (at least) carbon neutral units of accommodation, subject to them meeting local requirements for tenure, size and housing mix – and designs that complement (rather than harm) the High Weald National Landscape.

Notwithstanding the fact that there is little prospect of new build residential development within Mountfield in the foreseeable future, MPC does have a concern about such development in surrounding parishes – particularly the larger settlements of Battle (our market town) and Robertsbridge. Any infrastructure deficiencies – for example, if health and medical services cannot meet the demands of rising local populations – are likely to impact Mountfield parishioners adversely.

Therefore, MPC would support a requirement that those applying for consent for developments above a certain number of units of accommodation should provide evidence of engagement with infrastructure providers. Adequate and accessible infrastructure should exist – or be put in place before, or shortly after, developments are completed.
Given that, because of high accommodation costs and poor public transport connectivity, younger parishioners are having to relocate to urban areas (notably Hastings/St Leonards), MPC has an interest in the provision of cheaper accommodation within neighbouring parishes/settlements.

The increasing tendency for developers to assert that 30% affordable housing is unachievable and, in fact, that even one unit of affordable accommodation would render a development unviable should be challenged regularly by Rother District Council (RDC) by way of commissioning independent viability assessments.

See attachment for the full representation.

Dallington Parish Council (DPC) is of the view that there is little of concern within the Draft Rother District Local Plan.

DPC notes that no potential development sites have been identified in the Draft Housing Economic and Land Availability Assessment (HELAA) within the Parish of Dallington. However, DPC is keen to seen affordable accommodation provided for younger parishioners and households and, consequently, should any potential exception sites become available it would be keen to help facilitate the provision of lower cost and (at least) carbon neutral units of accommodation, subject to them meeting local requirements for tenure, size and housing mix – and designs that complement (rather than harm) the High Weald National Landscape.

Notwithstanding the fact that there is little prospect of new build residential development within Dallington in the foreseeable future, DPC does have a concern about such development in surrounding parishes – particularly the larger settlements of Battle (our market town) and Robertsbridge. Any infrastructure deficiencies – for example, if health and medical services cannot meet the demands of rising local populations – are likely to impact Dallington parishioners adversely.

Therefore, DPC would support a requirement that those applying for consent for developments above a certain number of units of accommodation should provide evidence of engagement with infrastructure providers. Adequate and accessible infrastructure should exist – or be put in place before, or shortly after, developments are completed.

Given that, because of high accommodation costs and poor public transport connectivity, younger parishioners are having to relocate to urban areas (notably Hastings/St Leonards), DPC has an interest in the provision of cheaper accommodation within neighbouring parishes/settlements.

The increasing tendency for developers to assert that 30% affordable housing is unachievable and, in fact, that even one unit of affordable accommodation would render a development unviable should be challenged regularly by Rother District Council (RDC) by way of commissioning independent viability assessments.

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!