See attachment for the full representation.

I would like to submit my response to Q.64 of The Draft Rother Local Plan 2020-40 P.145

Q64. What are your views on the potential sites identified in the draft HELAA that could accommodate more growth in Battle and surrounding settlements?

I am writing to make a record of my concerns after reviewing Rother District Council’s draft Local Plan (2020 – 40) and draft housing and economic land availability assessments (HELAA). Specifically Chapter 3 of the HELAA document, Battle and surrounding settlements. P.31

I am writing to strongly object to the proposed development of land at Almonry Farm, North Trade Road. Site ID BAT0014

I have examined the plans and I know the site well. I wish to object strongly to the development of houses in this location for the following reasons:

1.The area proposed for development lies within the High Weald AONB and any planned housing would cause significant damage to the immense biodiversity of the area which comprises of ancient woodland, ancient and veteran trees, meadows, ancient hedgerows/boundaries and habitats for endangered plants, fungi, birds, bats, reptiles and mammals. The infrastructure required to build 100 houses (sewers, piping systems, cables, foundations etc) would decimate the ecology of the site and endanger wildlife thus not fulfilling the National Policy of affording AONB sites ‘highest status of protection.’

2. 3.63 The NPPF specifically states that the scale and extent of development within an AONB should be limited and advises that planning applications for major development should be refused other than in exceptional circumstances. (p.60) Rother draft local plan 2020-40

The classification of a major development is 10 houses or more, this proposal is for 100 houses. Why? There are no ‘exceptional circumstances’ of housing need in Battle. Several houses at Lillybank (most recent development) are unsold and now reduced in price. There are many family-sized homes currently for sale in Battle that have been advertised for 6 months + Added to this is the current development of the Blackfriars site which is for 200 houses.

3. Urban Sprawl. A poor decision on a planning application on this site (100 houses) could set a precedent for a pattern of development that could lead to massive expansion and exploitation of the site as it is over 18 hectares leading to urban sprawl.

4. Battle is a hugely important market town, home to one of the UK’s most important historical sites and brings thousands of visitors every year. Building over historic land would change the look and feel of Battle from a small town to a conurbation and a less attractive place to visit. This would have a direct impact on local businesses and the economy.

5. Viable farmland ruined. The site comprises of Grade A, viable farmland. It is currently used for livestock, haylage and hay. Building over this site would rob the opportunity of this area ever being farmed again thus demeaning food security.

6. Historic site decimated. The fields of Almonry farm were formerly part of Battle Abbey and are of historical importance. The fields, ancient woodland and hedgerows provide a green buffer between the town and Battle Abbey

7. Road. Battle High Street and North Trade Road are heavily congested and at times Battle High Street is gridlocked. North Trade Road and Battle Highstreet are ancient thoroughfares with many listed and Historically significant buildings. The traffic generated by 100 extra houses will put enormous pressure on the already strained road network and old buildings.

8. Infrastructure. What are the plans for extra school places? GP surgeries and dentists?

9. Access via Tollgates residential area is unworkable. The planned access road would put immense pressure on the small, residential road into Tollgates (an area which has just recovered from expansion). There is no junction capacity.

10. The proposed access road will bisect 2 buildings of historical importance via a residential garden. Almonry Farmhouse (a Grade 2 listed building) and Almonry Oast House. A substantial amount of mature trees and shrubs would have to be removed in order to build an access road.

11. There is significant surface water flooding across several areas of the proposed site, underground springs and streams. Any removal of woodland/shrubs will have a negative impact on the water table and clay soil with the potential to upheave homes.

12. The planned road would bisect a public footpath which is currently heavily utilised by the public and most especially the pupils of Claverham School and Battle Langton School as a safe route to school. A road bisecting the footpath would compromise the safety and independence of children travelling to and from school.

13. After the reneged promises of the developers at the current Blackfriars site and the inability of RDC to compel the developers to make good their promise of affordable housing and social housing it is clear there is absolutely NO appetite for any further large-scale housing developments in Battle.

https://www.rother.gov.uk/housing/housing-development/rother-dc-housing-company-makes-significant-progress-to-deliver-its-first-housing-scheme

14. The people of Battle are not NIMBY’s, moreover a concerned populace that believes their heritage and green future are at stake. The main tenet of the RDC draft development plan is ‘Green to the core.’

‘Green to the Core emphasises the need to consider the impact of our planning decisions on the climate emergency, biodiversity crisis and the High Weald National Landscape.’ Rother District Council’s draft Local Plan (2020 – 40).

RDC need to listen to the responses of this consultation and consider the implications for future generations, in a declining population, of the impact decisions today have on Battle’s Green future. There are other sites to consider that don’t choke the life out of Battle. Leave our precious AONB alone.

I would like to submit a response to Q.64 of The Draft Rother Local Plan 2020-40 P.145

Q64. What are your views on the potential sites identified in the draft HELAA that could accommodate more growth in Battle and surrounding settlements?

I am writing to make a record of my concerns after reviewing Rother District Council’s draft Local Plan (2020 – 40) and draft housing and economic land availability assessments (HELAA). Specifically Chapter 3 of the HELAA document, Battle and surrounding settlements. P.31

I am writing to strongly object to the proposed development of land at Almonry Farm, North Trade Road. Site ID BAT0014

I have examined the plans and I know the site well. I wish to object strongly to the development of houses in this location for the following reasons:

1.The area proposed for development lies within the High Weald AONB and any planned housing would cause significant damage to the immense biodiversity of the area which comprises of ancient woodland, ancient and veteran trees, meadows, ancient hedgerows/boundaries and habitats for endangered plants, fungi, birds, bats, reptiles and mammals. The infrastructure required to build 100 houses (sewers, piping systems, cables, foundations etc) would decimate the ecology of the site and endanger wildlife thus not fulfilling the National Policy of affording AONB sites ‘highest status of protection.’

2. 3.63 The NPPF specifically states that the scale and extent of development within an AONB should be limited and advises that planning applications for major development should be refused other than in exceptional circumstances. (p.60) Rother draft local plan 2020-40

The classification of a major development is 10 houses or more, this proposal is for 100 houses. Why? There are no ‘exceptional circumstances’ of housing need in Battle. Several houses at Lillybank (most recent development) are unsold and now reduced in price. There are many family-sized homes currently for sale in Battle that have been advertised for 6 months + Added to this is the current development of the Blackfriars site which is for 200 houses.

3. Urban Sprawl. A poor decision on a planning application on this site (100 houses) could set a precedent for a pattern of development that could lead to massive expansion and exploitation of the site as it is over 18 hectares leading to urban sprawl.

4. Battle is a hugely important market town, home to one of the UK’s most important historical sites and brings thousands of visitors every year. Building over historic land would change the look and feel of Battle from a small town to a conurbation and a less attractive place to visit. This would have a direct impact on local businesses and the economy.

5. Viable farmland ruined. The site comprises of Grade A, viable farmland. It is currently used for livestock, haylage and hay. Building over this site would rob the opportunity of this area ever being farmed again thus demeaning food security.

6. Historic site decimated. The fields of Almonry farm were formerly part of Battle Abbey and are of historical importance. The fields, ancient woodland and hedgerows provide a green buffer between the town and Battle Abbey

7. Road. Battle High Street and North Trade Road are heavily congested and at times Battle High Street is gridlocked. North Trade Road and Battle Highstreet are ancient thoroughfares with many listed and Historically significant buildings. The traffic generated by 100 extra houses will put enormous pressure on the already strained road network and old buildings.

8. Infrastructure. What are the plans for extra school places? GP surgeries and dentists?

9. Access via Tollgates residential area is unworkable. The planned access road would put immense pressure on the small, residential road into Tollgates (an area which has just recovered from expansion). There is no junction capacity.

10. The proposed access road will bisect 2 buildings of historical importance via a residential garden. Almonry Farmhouse (a Grade 2 listed building) and Almonry Oast House. A substantial amount of mature trees and shrubs would have to be removed in order to build an access road.

11. There is significant surface water flooding across several areas of the proposed site, underground springs and streams. Any removal of woodland/shrubs will have a negative impact on the water table and clay soil with the potential to upheave homes.

12. The planned road would bisect a public footpath which is currently heavily utilised by the public and most especially the pupils of Claverham School and Battle Langton School as a safe route to school. A road bisecting the footpath would compromise the safety and independence of children travelling to and from school.

13. After the reneged promises of the developers at the current Blackfriars site and the inability of RDC to compel the developers to make good their promise of affordable housing and social housing it is clear there is absolutely NO appetite for any further large-scale housing developments in Battle.

https://www.rother.gov.uk/housing/housing-development/rother-dc-housing-company-makes-significant-progress-to-deliver-its-first-housing-scheme

14. The people of Battle are not NIMBY’s, moreover a concerned populace that believes their heritage and green future are at stake. The main tenet of the RDC draft development plan is ‘Green to the core.’

‘Green to the Core emphasises the need to consider the impact of our planning decisions on the climate emergency, biodiversity crisis and the High Weald National Landscape.’ Rother District Council’s draft Local Plan (2020 – 40).

RDC need to listen to the responses of this consultation and consider the implications for future generations, in a declining population, of the impact decisions today have on Battle’s Green future. There are other sites to consider that don’t choke the life out of Battle. Leave our precious AONB alone.

I am writing to object to the draft version of the Rother Local Plan 2020-2040 Draft (Regulation 18) version. My brief objections / comments are as follows:

General comments

• The concept of the Local Plan was introduced in the 2004 planning reforms to create a strategic spatial planning vision for an area. A new Plan is sorely needed – as well as being a regulatory necessity – as the 2006 Plan does not reflect current realities in Battle. This is a small town with a creaking infrastructure and some of its green spaces eroded by development; it is dirty, congested and polluted by traffic emissions and its state schools and medical/dentistry facilities are at full capacity. These factors were ignored by RDC when it foisted its ill-conceived and execrably executed Blackfriars development in 2021 on unwilling residents based on policies in the out-of-date 2006 Plan to capitalise on a potential commercial opportunity.

• Instead of engaging closely with residents and businesses to create a realistic and achievable vision, consultation during Plan development has been scant and poorly communicated. The draft outcome from this process is an impenetrable 453 page tome with many hundreds of pages of background papers, inaccessible to most residents with neither the time or resources to contribute to the consultation.

• Indeed, my soundings suggest that after the Blackfriars debacle (see below), trust is absent between many residents and the planning authority which is perceived to ignore objections to its development programme.

Sites

Q64 What are your views on the potential sites identified in the draft HELAA that could accommodate more growth in Battle and surrounding settlements.

• I would reiterate the general comment that the infrastructure and facilities of the town have already stretched to breaking point following the Tollgates and Lillybank developments and that no further large-scale development should be permitted in Battle.

• I am formally objecting to the Rother Draft Local Plan reference number BAT00014, which concerns a proposed development on Almonry Farm. This site lies within the High Weald AONB and any planned housing would cause significant damage to the biodiversity of the area as well as harming the character of the town because of its proximity to its heritage assets. I strongly oppose this plan which cannot be supported by the town’s existing infrastructure and urge RDC to exclude it from the Plan to protect our community.

• I strongly object to the continued inclusion of site BAT003, Land at Blackfriars Battle in the Draft Local Plan. There have been continued delays in bringing the housing element of this white elephant project forward and it should now be abandoned without further calls on the public purse. It is worth mentioning here that with no official source of information, residents are having to resort to social media reports to ascertain progress on RDC’s own Blackfriars development. From this we learn that: (i) construction of the spine road is now costing £21m – some £16m over the original budget (who pays?); (ii) the contract with Wates has been terminated at a cost of £900,000 to the ratepayer, (iii) the affordable housing element has been removed from the scheme for cost reasons; (iv) the ‘award winning’ environmental element has been removed for cost reasons. Some commercial opportunity!

• Blackfriars proves that the planning process is not designed for local authority led schemes. A private developer would have to satisfy stringent planning requirements and objectors would have the opportunity to make their case on appeal to the planning Inspectorate; when the position is reversed and RDC’s own development company is initiating the proposals there is not the same level of protection for residents. Therefore the Plan should stipulate that residents will have the opportunity to appeal to the planning Inspectorate in the case of any council led schemes coming forward.

Please confirm receipt of these objections and keep me informed of any progress as the Plan evolves.

Comments on HELAA site BAT0014

Please see attached document for full submission text.

Matters for consideration include:
- Site is good agricultural land.
- Access to the site, if developed, should not be via Tollgates.
- Suggestion for potential suitable access, though may be too narrow.

I am writing to strongly object to the proposed development of land at Almonry Farm, North Trade Road.

My reasons are: Impacts on infrastructure, AONB, farmland, loss of biodiversity, impacts on Battle High Street and surrounding areas,and potential flooding.

Please see attached representation objecting to HELAA site BAT0014.