Consultation on Draft Housing and Economic Land Availability Assessment – land at Conkers, Main Street, Iden

We are instructed on behalf of local residents in the village of Iden to object to the status of two plots within the Draft Housing and Economic Land Availability Assessment (HELAA). My clients note Rother District Council has announced a 12-week public consultation on the draft new Rother Local Plan, which started mid-April 2024. This includes the council’s HELAA, which looks at the feasibility of sites to bring forward for the council’s development plan.

The two plots in question are highlighted below at Figure 1 (please see attachment). These comprise the ‘Land rear of Conkers, Main Street’ site (under reference IDE0011) which has been listed as an orange ‘potential site’. My clients also object to the status of the already allocated site directly to the north of IDE0011, under reference IDE0001, and coloured purple. For the reasons outlined below, this site has been allocated on a false pretence, and therefore should be reviewed as part of the HELAA process.

The land under reference IDE0001 was originally allocated under the Development and Site Allocations Local Plan (DaSA), adopted 16 December 2019. Whilst the policy sets out that there are various locational drawbacks to the site, including a limited bus service to Rye and Tenterden, and that there is no primary school in the village, the site was nevertheless put forward as an allocated site.
The allocated site can be seen below at Figure 2 (please see attachment). This site has been allocated for specific reasons. Chief amongst these reasons is that the access way for the site is designated as being off the more sedate Elmsmead, rather than Main Street, ensuring that the historic layout of the village is not spoiled or interrupted, and allowing for a slower and safer flow of traffic into any potential development. This access can clearly be seen in the allocated site plan below.

The DaSA goes on to explain that: “Access would be delivered off Elsmead to the north-west, via third party land to which there is an “in principle” agreement”. However, due to statements that have been made in connection with a recent planning application for this land it has become apparent that the owner of the site has made no attempt to acquire such rights. We are therefore left questioning what happened to the “in principle” agreement to allow access off Elmsmead. Was there ever a realistic prospect of the Elmsmead access going ahead? If this was never a feasible access, then residents may well ask whether the land was allocated in the DaSA on a mistaken basis?

The land to the south, under reference IDE0011, is now put forward as being required in order to access the land under reference IDE0001. The council has already addressed the proposed location of an access road on Main Street in their DaSA consultation and concluded: “The creation of a new access road to the land from Main Street alongside the listed buildings would be clearly detrimental to their setting”.

The council has therefore explicitly outlined why the Main Street access is inappropriate for the site referenced IDE0011. It would be equally inappropriate for the site referenced IDE0001. If access from Elmsmead is not feasible, then the allocated site no longer stands on its own merits. The site should no longer be considered as suitable for an allocated site. We ask that the council reconsider this site allocation as part of the HELAA. If the site is to remain allocated there should be a clear commitment on the Council’s part to the use of compulsory purchase powers to unlock the necessary access via Elmsmead.

Objection to land under reference IDE0011

Local residents are surprised to see that the land under reference IDE0011 (previously referred to as ID1r in the DaSA) is being brought forward again as part of the HELAA, despite the clear rejection by the council last time around. They are also surprised that all but one of the other potential sites around the village are listed as ‘rejected sites’, presumably on the basis that they have previously been deemed unsuitable. However, the ‘Land rear of Conkers, Main Street’ site, under reference IDE0011, is now listed as a ‘potential site’. It is not clear why that would be. The HELAA repeats the comments from the previous site allocation summary:

“While this site was previously rejected through the SHLAA (2013) due to the potential impact on the setting of the adjoining listed buildings, its development could potentially help bring forward the adjoining allocated site and achieve an alternative access directly from Main Street, while providing a small extension to the developed area and a small increase in dwelling numbers. The impact on the adjoining listed buildings could potentially be mitigated through careful design. Initial Highway Authority comments confirm that further design and safety assessment is required to inform a new access from Main Street”.

This statement acknowledges that there is no longer an easy fix with regards to access to and from the allocated site, IDE0001. Why further land, which has already been deemed by the council as unsuitable for development, should also be brought forward as an allocated site, merely to make a now inaccessible allocated site usable is unclear.

In 2016 the council launched a consultation on possible development sites in Iden. This considered the suitability of site ID1r, now referred to under reference IDE0011, as seen below at Figure 3 (see attachment), showing the DaSA consultation plan.

The site assessment for ID1r reads as follows:

“This site lies immediately behind the Listed Conkers. It forms the southern part of the paddock; the northern part being site reference ID1a. This part of the field has a closer relationship with the listed buildings. The creation of a new access road to the land from Main Street alongside the listed buildings would be clearly detrimental to their setting. Its development would represent an unnecessary and inappropriate loss of open land that contributes both to the setting of listed buildings and to the character of this rural fringe of the village.

Recommendation: Not a preferred site.”

This is a damning indictment of the suitability of the land under reference IDE0011 for development. We cannot see how the council could possibly add the site to the allocated sites when they have clearly indicated that any residential development in this area “would be clearly detrimental” to the setting of the listed buildings.

Harm to the setting of listed buildings – Access to the land under reference IDE0011 requires a road to be constructed immediately adjacent to two listed buildings, whilst being directly adjacent to four listed buildings. The possibility of inclusion of IDE0011 as an allocated site was rejected by the council as “Its development would represent an unnecessary and inappropriate loss of open land that contributes both to the setting of listed buildings and to the character of this rural fringe of the village”.

Any road to access the land under reference IDE0011 would clearly be within the immediate court surrounding Conkers, and therefore within the curtilage of the listed building. As the PPG outlines, works within the curtilage of a listed building are inarguably within the setting of the listed building. The immediate curtilage of the listed building contributes immensely to its setting.

Conkers has deliberately been designed and built set back from the main carriageway through the village. This is a typical design feature of many the grander dwellings in historic villages that have developed along a linear pattern. It was a status symbol reserved for those owners who could afford a larger plot and could enjoy the added peace and quiet that this could lend a dwelling. Any road would diminish from the grandeur of the approach to Conkers, by removing a good deal of the listed building’s curtilage. We believe that this would go beyond the ‘less than substantial harm’ category and constitute substantial harm to the heritage asset. Clearly, this damage to the curtilage of the building very much reduces the significance of the asset. Therefore, the council should reject the land under reference IDE0011 from the site allocation on the basis of harm to the curtilage (and setting) of Conkers.

Aside from the damage to the curtilage of Conkers, the presence of a road and the development of agricultural land into residential use would result in a change of character of the surroundings of several listed buildings. Under the definition in the NPPF, the land under reference IDE0011 is part of the setting of the listed Rose Cottage, Conkers, Eastview and Deacons. The site doesn’t immediately abut Partridge, as this property is located on the opposite side of the road, but this property’s setting is also impacted.

The existing context and setting of Conkers, Eastview and Deacons would be harmfully diluted by any residential scheme at IDE0011. The buildings would no longer make sense or read correctly in their new context, which instead of being the grand buildings in the ribbon development, would instead punctuate the T-junction to access the new housing estate. The prominence of these heritage assets when seen from the main road and public viewpoints would be lost, and the new-build dwellings would be visible and ever-present from these viewpoints. Upon approaching the village from the south, a residential scheme would become the dominant form in the landscape rather than the historic buildings and would, with some ease, draw the eye away from them. The cumulative damage to the setting of the four listed buildings reduces the significance of all four assets. Under the NPPF, this would meet the “less than substantial harm” threshold at the medium end of that spectrum to the heritage significance of these listed buildings.

Access – Access to the land under reference IDE0011 would require running a straight onto Main Street, and so spoiling and interrupting the historic layout of the village. Access off Main Street is difficult and compromised, and a far from ideal place for a junction to be located. Due to the listed Eastview being built adjacent to Main Street, there would appear to be issues of visibility with inserting a junction immediately adjacent to it. Any vehicle travelling from the south would not be able to see a car emerging from the junction and vice versa. We question whether visibility splays would be a sufficient resolution here. The access issues here would also be exacerbated by the fact that traffic moves a lot faster down Main Street than it does on, for instance, subsidiary roads like Elmsmead.

Any junction inserted into Main Street would also make for a far greater degree of disturbance to those residents living near to the junction. Rather than vehicles occasionally passing their properties, residents would have to deal with stationary traffic turning into a new housing estate. A new housing estate would provide for many car journeys, and glare from turning headlights would be disruptive to residents.

Summary

This submission demonstrates that the original allocation, under reference IDE0001, was flawed as there is no feasible and available access to this land. This allocation was made because access could be achieved from the north of this site, on the basis of an ‘in principle’ agreement. This agreement never materialised.
The only feasible access to IDE0001 is from land being brought forward in the HELAA under reference IDE0011. This land has previously been rejected by the council due to the impact on surrounding listed buildings. As demonstrated above, this impact goes beyond merely impacting the setting of the listed Conkers and other listed buildings but requires that the access road to the two pieces of land be constructed in the immediate curtilage of the listed Conkers.

Therefore, local residents are surprised that the HELAA appears to be looking at site reference IDE0011 as a means of making site reference IDE0001 workable. If site reference IDE0001 is unworkable then it should no longer be designated as an allocated site. In our client’s view the site can only be accessed by Elmsmead, and if the Council will not facilitate that through the use of compulsory purchase powers then the site should no longer be allocated.

Question 67 in the main

Beckley Parish Council is in broad support of the policies put forward, in the Local Plan, in particular those that reduce our carbon footprint and protect our environment.

With regard to potential residential development for Beckley, as identified in the HELAA, the council is in favour of sympathetic development throughout the village. The village is one where the natural gaps, with views to the countryside, between continuous development distinguish the two main areas: Four Oaks (Whitebread Lane, Hobbs Lane, Peasmarsh Road and Main Street to Budden Green) and Beckley (the Church to the Village Hall).

Currently there are two approved sites: Buddens Green allocated 6/8 dwellings as affordable homes and Hobbs Lane Former Manroy site allocated 14 dwellings. These are reasonable locations where the number of dwellings should not be allowed to augment as a higher density
would not sit well.

The council believes there should be no further development in the Four Oaks area as this would lead to a disproportion between Four Oaks and Beckley changing the overall appearance of the village. Four Oaks would become over developed and cramped whilst Beckley towards the Church would become sparser. This would alter the current natural fall in density from Four Oaks to All Saints.

To preserve the current balance, the council believes that the proposed further 10/12 dwellings should be in small groups of 2 to 4 dwellings. These should include low level bungalows as well as self-build schemes and should be 2/3-bedroom accommodation.

To maintain the character of Beckley as a disbursed settlement these should be distributed along Main Street and the adjoining lanes. There are sites on Kings Bank, Horseshoe Lane, Church Lane, Rectory Lane and Stoddards Lane, which whilst currently outside the development boundaries, would allow for small pockets of houses to be built in order to meet the targets placed on the village, whilst minimising traffic impacts on the relevant lanes and reflecting the way in which the village has evolved historically.

We would welcome the opportunity to work with the District Council, local residents and landowners
to identify appropriate sites.

Please see attached submission letter.

The vital strategic gap between Rye and Rye Harbour is not fully protected, as a large open area of land exists between HELAA site RYE0025 and Rye sewage works. Also, site ICK0028 lies in the strategic gap and should not be listed as a potential site for development. This site allocation, along with what appears to be rampant and speculative industrial development along Rye Harbour Road, is inconsistent with RDC's 'Green to the Core' goal and with maintaining Rye's unique historic character. Three huge new warehouses have lately appeared on Rye Harbour Road, risking Rye looking like the annex to a vast industrial estate. The strategic green gap between Rye and historic Playden — as well as recent Planning Inspectorate rulings — are also ignored by potential site PLA008. Potential sites chosen by HELAA often appear arbitrary and many of them state "there is no evidence the site is available".

These comments relate specifically to the area marked as IDE0010 on the supplied map ie Street Field, Iden.

While it is apparent that there is a pressing need for affordable housing in the villages, it is difficult to imagine that even modest houses in this location are likely to be ‘affordable’ to ordinary first time buyers with limited resources. More likely the ‘new build’ housing will - like countless other properties here - be purchased as second/ weekend homes, by those who are not in a position to contribute to the life or economy of the village. Mentioned in the planning document is the fact that new houses would adjoin the existing row of grade 2 listed terraced cottages, disingenuously referred to as ‘existing Ribbon Development’. It is difficult to imagine how new houses could be designed to blend comfortably with these.

Over the last 3-4 years traffic along the B2082 has become noticeably heavier. Car parking on the main road has also notably increased. The combination of these two factors is hazardous. Coming from the north at present, the occasional parked car by the existing terrace of cottages cannot be seen until almost too late. Crossing the road on foot at this location, or emerging in a vehicle from the Playden Lane junction, is already difficult. A row of new houses, with accompanying vehicles, would only contribute to the problem.

Iden is one of very few nucleated settlements still existing in East Sussex. Part of its attraction is that gaps between buildings allow extensive views to the countryside beyond. At present, Street Field represents one of these gaps. Over the last half century the field has been used as an orchard, grazed by sheep, and from time to time left as un-grazed grassland which was cut for hay. In the absence of sheep, wild flowers begin to emerge including, (to my own knowledge), Orchids and an abundance of Birds Foot Trefoil, both of which have an environmental value. Buildings, gardens and planted hedges from which non-native plants inevitably escape, would certainly detract from this. The ancient hedgerow mentioned in the planning document has already been degraded, several years ago, by the cutting down (without permission), of the mature trees within it. Further housing development here would put paid to any chance that they could be allowed to regenerate.

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

As a resident of Houghton Green Lane, Playden, I have to say I was very concerned to learn that you were considering building new housing estates in the vicinity.

With specific reference to 'potential sites’ PLA0012 and PLA0013

My first concern is traffic; this lane is very narrow & twisty and can be quite dangerous at the best of times, let alone during times of increased traffic, such as school runs, or when there are diversions from military road, for example.

There are no pavements & very little in the way of verges. There is really only room for single traffic, with few passing places. Dips and potholes are also an issue, as are overhanging branches, etc.

I do not believe there is anywhere in the lane that could safely accommodate vehicular access to a housing estate, let alone the heavy plant required to build it.

I also do not believe there is the necessary infrastructure in place to support multiple additional homes in Playden, let alone in Houghton Green Lane. There are no shops in Playden. The primary school, I believe, is already full, and the medical centre is already stretched to capacity.

And we are talking about beautiful green fields that form part of the rural landscape. None of the proposed sites could possibly be described as grey belt, which I understood is supposed to be the current target for development.

With the above in mind, I implore you to reconsider the proposed plans.

As a resident of Houghton Green Lane, Playden, I have to say I was very concerned to learn that you were considering building new housing estates in the vicinity.

With specific reference to 'potential sites’ PLA0012 and PLA0013

My first concern is traffic; this lane is very narrow & twisty and can be quite dangerous at the best of times, let alone during times of increased traffic, such as school runs, or when there are diversions from military road, for example.

There are no pavements & very little in the way of verges. There is really only room for single traffic, with few passing places. Dips and potholes are also an issue, as are overhanging branches, etc.

I do not believe there is anywhere in the lane that could safely accommodate vehicular access to a housing estate, let alone the heavy plant required to build it.

I also do not believe there is the necessary infrastructure in place to support multiple additional homes in Playden, let alone in Houghton Green Lane. There are no shops in Playden. The primary school, I believe, is already full, and the medical centre is already stretched to capacity.

And we are talking about beautiful green fields that form part of the rural landscape. None of the proposed sites could possibly be described as grey belt, which I understood is supposed to be the current target for development.

With the above in mind, I implore you to reconsider the proposed plans.

Please see attached comments from Burwash Parish Council.

I should like to make a comment about the proposed developments in Iden- 25 in all, SOUTH OF ELMSMEAD, the ‘Conkers’ plot, (IDE0001). Also the possible development of the field on the RIGHT of the main Road on entering Iden from the South, (IDE0010).
Whilst appreciating the need for more housing in the Southeast, I feel that attention should be directed to the desperate need for Either ‘affordable housing’ (if there is such a thing, given the price of land in the SE), or Council housing or both ideally. There are already sufficient ‘executive’ properties in Iden. which these 3 sites will be aimed at
But, more importantly, the village of Iden simply does NOT have the infrastructure to sustain that many new houses.
• The local school is not large enough presently to accommodate a potential influx of over 100 new pupils.
• The local Surgery is already at bursting point and, together with the development of up to 300 new houses in nearby Peasmarsh, which is also in their catchment area, it will need twice as many Doctors than it presently employs, plus larger premises.
• Local Dentists presently are almost non-existent.
• In addition, local employment prospects are extremely limited.
• On closer inspection of the large amount of different species growing in some of the hedges which would be affected/destroyed by the developments in Iden, they appear to be quite ancient and should be preserved as an important part of the surrounding landscape.
Iden is in danger of becoming a ‘ribbon village’ and, over time, could join up with Playden and in a worst case scenario, become part of Rye. This surely will impact detrimentally on the landscape of the High Weald, with its villages dotted on hilltops or nestled in valleys. In my view it is very important to keep these rural Domesday Villages intact and separate, each with their own special character, acquired over centuries if not millennia, not characterless, amorphous dormitories for, in this case, Hastings, Ashford or Tunbridge Wells, swelling the already exceedingly crowded country roads with cars and endangering the local wildlife, horse riders and walkers.

I should like to make a comment about the proposed developments in Iden- 25 in all, SOUTH OF ELMSMEAD, the ‘Conkers’ plot, (IDE0001). Also the possible development of the field on the RIGHT of the main Road on entering Iden from the South, (IDE0010).
Whilst appreciating the need for more housing in the Southeast, I feel that attention should be directed to the desperate need for Either ‘affordable housing’ (if there is such a thing, given the price of land in the SE), or Council housing or both ideally. There are already sufficient ‘executive’ properties in Iden. which these 3 sites will be aimed at
But, more importantly, the village of Iden simply does NOT have the infrastructure to sustain that many new houses.
• The local school is not large enough presently to accommodate a potential influx of over 100 new pupils.
• The local Surgery is already at bursting point and, together with the development of up to 300 new houses in nearby Peasmarsh, which is also in their catchment area, it will need twice as many Doctors than it presently employs, plus larger premises.
• Local Dentists presently are almost non-existent.
• In addition, local employment prospects are extremely limited.
• On closer inspection of the large amount of different species growing in some of the hedges which would be affected/destroyed by the developments in Iden, they appear to be quite ancient and should be preserved as an important part of the surrounding landscape.
Iden is in danger of becoming a ‘ribbon village’ and, over time, could join up with Playden and in a worst case scenario, become part of Rye. This surely will impact detrimentally on the landscape of the High Weald, with its villages dotted on hilltops or nestled in valleys. In my view it is very important to keep these rural Domesday Villages intact and separate, each with their own special character, acquired over centuries if not millennia, not characterless, amorphous dormitories for, in this case, Hastings, Ashford or Tunbridge Wells, swelling the already exceedingly crowded country roads with cars and endangering the local wildlife, horse riders and walkers.

See attached.

We refer to ROTHER DISTRICT COUNCIL DRAFT HOUSING AND ECONOMIC LAND AVAILABILITY ASSESSMENT (HELAA)
Part 2: Site Assessments
Chapter 4 - Rye and the Eastern Settlements Cluster


There are 2 general points we should like to make on the draft vision for Rye and the eastern network settlements.

Rye is a popular tourist destination despite an infrequent hourly train service from Ashford and from Eastbourne. Access by road is similarly awkward with no major highways

We believe that Rother's approach to the regional housing problem is cumbersome and limited in that the council seems to be attracted to potential sites merely because the land owner has approached the council to sell parcels of land without giving a lot of thought to the impact on existing residents and the country side. The net result is housing being built for tourism which of course enriches the few but not the many less wealthy people and others who just love their environment as it is.

Our views of the draft about Iden (pages 46 to 52) are that Rother has completely overturned the current plan based upon years of cooperation with the outlying settlements which is reflected in "Rother District Council Development and Site Allocations Local Plan dated 16 December 2019". We believe that this occurred as a consequence of the local elections in 2023. It would seem that something similar will occur after the 2024 general election.

Nonetheless we support the need for modest (affordable housing) but we cannot change the basic fact as stated in the current plan: "There is very limited scope for development in and around the village." and ..."development to the south would inappropriately extend growth along Main Street, encroaching into an area of rural character.

The 312 bus service is 2 hourly, the pub is closed indefinitely although there is a strong will within the community to take it over. Horse riding is abundant as is cycling with serious walkers and runners going on.

The current proposed development behind Conkers (IDE 0001 and IDE 0011) is beset with problems of access and proximity to listed buildings of which there are relatively many nearby. Main Street is increasingly dangerous with passing traffic having to navigate a curving narrow rural road, sadly made worse by frequent speeding well above the 30 mph limit

On the other hand, there is a brownfield site (IDE0014) which is home to a very few small businesses using old apple packing sheds This site has decent access to Wittersham Road would be more appropriate than IDE0010 which the draft suggests:
"The site could be suitable for a short terrace of small
houses fronting Main Street, which would continue the adjoining
ribbon development northwards" To describe a charming set of mid-19th century built affordable homes in such a way is incongruous if not dishonest.

It is quite odd that IDE 0021 is assessed in the draft as follows: "development into the remainder of the field would not be appropriate as this would be out of keeping with and harmful to the settlement pattern and the rural setting of the village within the countryside of the National Landscape, and could harm the setting of the adjacent listed buildings."

IDE0010 is an important part of the rural setting of Iden. It is what impacts visitors and residents alike. I believe a development here would be a serious error and should be refused.

PLAYDEN PARISH COUNCIL
COMMENTS ON ROTHER DISTRICT COUNCIL DRAFT LOCAL PLAN AND HELAA.

- General Comments for sites in Playden Parish:

The council has previously carried out a housing needs assessment where all residents were invited to gives their views. This showed a limited additional need for residents downsizing or for small family houses. This could potentially be met by ‘windfall’ sites (understood from RDC's presentation being 1 to 2 units ) which is outside the scope of the HELAA document.

The Parish Council's view is that the area of Playden outside the High Weald National Landscape (formally the Area of Outstanding National Beauty) shares the same landscape characteristics as adjoining protected areas of Playden, Rye Foreign and Iden and should be considered in the same way as the protected area when deciding planning applications. In addition, the bold wooded cliff and rural upland beyond is very visible from Romney Marsh to the east and requires protection from prominent development intruding into this view. This fact was acknowledged by Rother District Council in initial refusal of a garage block at The Mount (RR/2012/225/P) and refusal of an additional house at Rother Cliff, Point Hill (in relation to a well known architect’s development) (RR/2015/475).

The Parish Council therefore asks for recognition of the landscape character of this part of Playden Parish as a constraint within your Local Plan.

In addition the Rye Neighborhood Plan (section 4.76) states that ‘to further protect the profile of Rye, it is important to retain green areas as gaps between adjacent parishes particularly ……. Playden and Rye Foreign.

- Sites over five houses as listed in the HELAA document:

The Parish Council notes constraints have been listed at all the sites identified by Rother District Council. Our comments on the sites listed are as follows:

1. Poppyfield PLA0012

Background:
This site or a version of it was the subject of an invited public meeting in 2015 at which time the location outside a Development Framework was the overriding objection.

Current:
The Lane approach is narrow and is also affected by car parking, there being a number of houses without vehicular access in the immediate area and parking provision for these residents would need to be taken into account. At the entrance to the Lane the width of the road is constricted by buildings both sides and cannot be widened and we believe access will not meet Highways standards.
The Parish Council is pleased to note that the WI hall car park is shown as excluded from the development area.

2. Saltcote / The Steps PLA0008

Background:
This field was proposed for development in the 1980s. At that time it was in common ownership with Saltcote and the proposal was to widen New England Lane by taking the front strip of the garden at Saltcote. As the two sites are now in separate ownership, this improvement is not likely to be readily available.

Current:
The Council objects to this being a development site both on the general comments detailed above and the unsuitability of the Lane for larger scale development.
The site is also within the setting of the Grade I Listed St Michael's Church and development would have an adverse impact on the perception of the church as well as the landscape character of the area.

The site is opposite the Shellfield site that lost on appeal twice and the reasons for this refusal by both RDC and the Inspectorate should be fully considered by Rother Planning Department.

Please note that both this site and the Shellfield site have very strong opposition from Playden parishioners.

3. Corner House PLA0013

Background:
It was proposed as the site of a new village hall many years ago and not pursued due to local opposition and the WI hall was refurbished instead.

Current:
The Parish council is opposed to this site. This site shares the same constraint as at the Poppyfield site, as due to access difficulties, the site is not considered suitable for entry onto the A268 due to proximity to the bus stop, layby and visibility.

4. Shellfield PLA0001 (rejected)

This site was the subject of considerable local opposition and opposed by the Parish Council and two appeals were dismissed. It is noted that it has been omitted from the current allocation due to the owner not making the site available within the Local Plan period. If the land becomes available RDC should fully consider the reasons for dismissal in this refusal by both RDC and the Inspectorate for the appeals.

Query.
Can you confirm to the Parish Council if land becomes available by landowners during the process of developing the Local Plan would these sites be included in the HELAA/Local Plan under a revised status. If so is there another consultation stage where the Parish Council can comment on any site that has changed its status?

Original submitted document containing the above comments has been attached.

PLAYDEN PARISH COUNCIL
COMMENTS ON ROTHER DISTRICT COUNCIL DRAFT LOCAL PLAN AND HELAA.

- General Comments for sites in Playden Parish:

The council has previously carried out a housing needs assessment where all residents were invited to gives their views. This showed a limited additional need for residents downsizing or for small family houses. This could potentially be met by ‘windfall’ sites (understood from RDC's presentation being 1 to 2 units ) which is outside the scope of the HELAA document.

The Parish Council's view is that the area of Playden outside the High Weald National Landscape (formally the Area of Outstanding National Beauty) shares the same landscape characteristics as adjoining protected areas of Playden, Rye Foreign and Iden and should be considered in the same way as the protected area when deciding planning applications. In addition, the bold wooded cliff and rural upland beyond is very visible from Romney Marsh to the east and requires protection from prominent development intruding into this view. This fact was acknowledged by Rother District Council in initial refusal of a garage block at The Mount (RR/2012/225/P) and refusal of an additional house at Rother Cliff, Point Hill (in relation to a well known architect’s development) (RR/2015/475).

The Parish Council therefore asks for recognition of the landscape character of this part of Playden Parish as a constraint within your Local Plan.

In addition the Rye Neighborhood Plan (section 4.76) states that ‘to further protect the profile of Rye, it is important to retain green areas as gaps between adjacent parishes particularly ……. Playden and Rye Foreign.

- Sites over five houses as listed in the HELAA document:

The Parish Council notes constraints have been listed at all the sites identified by Rother District Council. Our comments on the sites listed are as follows:

1. Poppyfield PLA0012

Background:
This site or a version of it was the subject of an invited public meeting in 2015 at which time the location outside a Development Framework was the overriding objection.

Current:
The Lane approach is narrow and is also affected by car parking, there being a number of houses without vehicular access in the immediate area and parking provision for these residents would need to be taken into account. At the entrance to the Lane the width of the road is constricted by buildings both sides and cannot be widened and we believe access will not meet Highways standards.
The Parish Council is pleased to note that the WI hall car park is shown as excluded from the development area.

2. Saltcote / The Steps PLA0008

Background:
This field was proposed for development in the 1980s. At that time it was in common ownership with Saltcote and the proposal was to widen New England Lane by taking the front strip of the garden at Saltcote. As the two sites are now in separate ownership, this improvement is not likely to be readily available.

Current:
The Council objects to this being a development site both on the general comments detailed above and the unsuitability of the Lane for larger scale development.
The site is also within the setting of the Grade I Listed St Michael's Church and development would have an adverse impact on the perception of the church as well as the landscape character of the area.

The site is opposite the Shellfield site that lost on appeal twice and the reasons for this refusal by both RDC and the Inspectorate should be fully considered by Rother Planning Department.

Please note that both this site and the Shellfield site have very strong opposition from Playden parishioners.

3. Corner House PLA0013

Background:
It was proposed as the site of a new village hall many years ago and not pursued due to local opposition and the WI hall was refurbished instead.

Current:
The Parish council is opposed to this site. This site shares the same constraint as at the Poppyfield site, as due to access difficulties, the site is not considered suitable for entry onto the A268 due to proximity to the bus stop, layby and visibility.

4. Shellfield PLA0001 (rejected)

This site was the subject of considerable local opposition and opposed by the Parish Council and two appeals were dismissed. It is noted that it has been omitted from the current allocation due to the owner not making the site available within the Local Plan period. If the land becomes available RDC should fully consider the reasons for dismissal in this refusal by both RDC and the Inspectorate for the appeals.

Query.
Can you confirm to the Parish Council if land becomes available by landowners during the process of developing the Local Plan would these sites be included in the HELAA/Local Plan under a revised status. If so is there another consultation stage where the Parish Council can comment on any site that has changed its status?

Original submitted document containing the above comments has been attached.

PLAYDEN PARISH COUNCIL
COMMENTS ON ROTHER DISTRICT COUNCIL DRAFT LOCAL PLAN AND HELAA.

- General Comments for sites in Playden Parish:

The council has previously carried out a housing needs assessment where all residents were invited to gives their views. This showed a limited additional need for residents downsizing or for small family houses. This could potentially be met by ‘windfall’ sites (understood from RDC's presentation being 1 to 2 units ) which is outside the scope of the HELAA document.

The Parish Council's view is that the area of Playden outside the High Weald National Landscape (formally the Area of Outstanding National Beauty) shares the same landscape characteristics as adjoining protected areas of Playden, Rye Foreign and Iden and should be considered in the same way as the protected area when deciding planning applications. In addition, the bold wooded cliff and rural upland beyond is very visible from Romney Marsh to the east and requires protection from prominent development intruding into this view. This fact was acknowledged by Rother District Council in initial refusal of a garage block at The Mount (RR/2012/225/P) and refusal of an additional house at Rother Cliff, Point Hill (in relation to a well known architect’s development) (RR/2015/475).

The Parish Council therefore asks for recognition of the landscape character of this part of Playden Parish as a constraint within your Local Plan.

In addition the Rye Neighborhood Plan (section 4.76) states that ‘to further protect the profile of Rye, it is important to retain green areas as gaps between adjacent parishes particularly ……. Playden and Rye Foreign.

- Sites over five houses as listed in the HELAA document:

The Parish Council notes constraints have been listed at all the sites identified by Rother District Council. Our comments on the sites listed are as follows:

1. Poppyfield PLA0012

Background:
This site or a version of it was the subject of an invited public meeting in 2015 at which time the location outside a Development Framework was the overriding objection.

Current:
The Lane approach is narrow and is also affected by car parking, there being a number of houses without vehicular access in the immediate area and parking provision for these residents would need to be taken into account. At the entrance to the Lane the width of the road is constricted by buildings both sides and cannot be widened and we believe access will not meet Highways standards.
The Parish Council is pleased to note that the WI hall car park is shown as excluded from the development area.

2. Saltcote / The Steps PLA0008

Background:
This field was proposed for development in the 1980s. At that time it was in common ownership with Saltcote and the proposal was to widen New England Lane by taking the front strip of the garden at Saltcote. As the two sites are now in separate ownership, this improvement is not likely to be readily available.

Current:
The Council objects to this being a development site both on the general comments detailed above and the unsuitability of the Lane for larger scale development.
The site is also within the setting of the Grade I Listed St Michael's Church and development would have an adverse impact on the perception of the church as well as the landscape character of the area.

The site is opposite the Shellfield site that lost on appeal twice and the reasons for this refusal by both RDC and the Inspectorate should be fully considered by Rother Planning Department.

Please note that both this site and the Shellfield site have very strong opposition from Playden parishioners.

3. Corner House PLA0013

Background:
It was proposed as the site of a new village hall many years ago and not pursued due to local opposition and the WI hall was refurbished instead.

Current:
The Parish council is opposed to this site. This site shares the same constraint as at the Poppyfield site, as due to access difficulties, the site is not considered suitable for entry onto the A268 due to proximity to the bus stop, layby and visibility.

4. Shellfield PLA0001 (rejected)

This site was the subject of considerable local opposition and opposed by the Parish Council and two appeals were dismissed. It is noted that it has been omitted from the current allocation due to the owner not making the site available within the Local Plan period. If the land becomes available RDC should fully consider the reasons for dismissal in this refusal by both RDC and the Inspectorate for the appeals.

Query.
Can you confirm to the Parish Council if land becomes available by landowners during the process of developing the Local Plan would these sites be included in the HELAA/Local Plan under a revised status. If so is there another consultation stage where the Parish Council can comment on any site that has changed its status?

Original submitted document containing the above comments has been attached.

PLAYDEN PARISH COUNCIL
COMMENTS ON ROTHER DISTRICT COUNCIL DRAFT LOCAL PLAN AND HELAA.

- General Comments for sites in Playden Parish:

The council has previously carried out a housing needs assessment where all residents were invited to gives their views. This showed a limited additional need for residents downsizing or for small family houses. This could potentially be met by ‘windfall’ sites (understood from RDC's presentation being 1 to 2 units ) which is outside the scope of the HELAA document.

The Parish Council's view is that the area of Playden outside the High Weald National Landscape (formally the Area of Outstanding National Beauty) shares the same landscape characteristics as adjoining protected areas of Playden, Rye Foreign and Iden and should be considered in the same way as the protected area when deciding planning applications. In addition, the bold wooded cliff and rural upland beyond is very visible from Romney Marsh to the east and requires protection from prominent development intruding into this view. This fact was acknowledged by Rother District Council in initial refusal of a garage block at The Mount (RR/2012/225/P) and refusal of an additional house at Rother Cliff, Point Hill (in relation to a well known architect’s development) (RR/2015/475).

The Parish Council therefore asks for recognition of the landscape character of this part of Playden Parish as a constraint within your Local Plan.

In addition the Rye Neighborhood Plan (section 4.76) states that ‘to further protect the profile of Rye, it is important to retain green areas as gaps between adjacent parishes particularly ……. Playden and Rye Foreign.

- Sites over five houses as listed in the HELAA document:

The Parish Council notes constraints have been listed at all the sites identified by Rother District Council. Our comments on the sites listed are as follows:

1. Poppyfield PLA0012

Background:
This site or a version of it was the subject of an invited public meeting in 2015 at which time the location outside a Development Framework was the overriding objection.

Current:
The Lane approach is narrow and is also affected by car parking, there being a number of houses without vehicular access in the immediate area and parking provision for these residents would need to be taken into account. At the entrance to the Lane the width of the road is constricted by buildings both sides and cannot be widened and we believe access will not meet Highways standards.
The Parish Council is pleased to note that the WI hall car park is shown as excluded from the development area.

2. Saltcote / The Steps PLA0008

Background:
This field was proposed for development in the 1980s. At that time it was in common ownership with Saltcote and the proposal was to widen New England Lane by taking the front strip of the garden at Saltcote. As the two sites are now in separate ownership, this improvement is not likely to be readily available.

Current:
The Council objects to this being a development site both on the general comments detailed above and the unsuitability of the Lane for larger scale development.
The site is also within the setting of the Grade I Listed St Michael's Church and development would have an adverse impact on the perception of the church as well as the landscape character of the area.

The site is opposite the Shellfield site that lost on appeal twice and the reasons for this refusal by both RDC and the Inspectorate should be fully considered by Rother Planning Department.

Please note that both this site and the Shellfield site have very strong opposition from Playden parishioners.

3. Corner House PLA0013

Background:
It was proposed as the site of a new village hall many years ago and not pursued due to local opposition and the WI hall was refurbished instead.

Current:
The Parish council is opposed to this site. This site shares the same constraint as at the Poppyfield site, as due to access difficulties, the site is not considered suitable for entry onto the A268 due to proximity to the bus stop, layby and visibility.

4. Shellfield PLA0001 (rejected)

This site was the subject of considerable local opposition and opposed by the Parish Council and two appeals were dismissed. It is noted that it has been omitted from the current allocation due to the owner not making the site available within the Local Plan period. If the land becomes available RDC should fully consider the reasons for dismissal in this refusal by both RDC and the Inspectorate for the appeals.

Query.
Can you confirm to the Parish Council if land becomes available by landowners during the process of developing the Local Plan would these sites be included in the HELAA/Local Plan under a revised status. If so is there another consultation stage where the Parish Council can comment on any site that has changed its status?

Original submitted document containing the above comments has been attached.

1. The site is located within the High Weald Area of Outstanding National Beauty (AONB), which is a sensitive area as defined by the EIA Regulations, and as its located within a sensitive area any development would bring significant impact in terms of noise, waste, contamination, ecology, flooding, traffic or complex construction. Given the nature, scale and location of the proposal there would be significant impact on the surrounding area as a result of a development.

2. Great Crested Newts: The site is located within a Red impact zone for great crested newts which means there is highly suitable habitat and is the most important areas for great crested newts. Several ponds are observed within the vicinity. it is therefore highly likely that the proposal would cause an impact on great crested newts and or their habitats.

3. There has already been a site identified IDE006 a former packing house and warehouse which would be better considered for development.

4. Ironically earlier in 2024 a planning application RR/2024/237/P was submitted for a change of use from agricultural land to a garden, the land backing onto IDE0010. Intially it was rejected, subsequently it received approval on the understanding the area in question would only partly be used as a garden and there would be clear delineation between the garden and agricultural land to ‘ensure the appropriate landscape setting and to preserve the visual amenities of the area in accordance with Policy OSS4(iii) and EN3 of the Rother local plan’. I would have thought any building work on agricultural land would go against this policy.

SUBMISSION TO HELAA 23RD July 2024 regarding ROTHER DISTRICT COUNCIL DRAFT HOUSING AND ECONOMIC LAND AVAILABILITY ASSESSMENT (HELAA) PART 2: SITE ASSESSMENTS CHAPTER 4: RYE AND THE EASTERN SETTLEMENTS CLUSTER DOCUMENT
Site id: IDEOO1O
Street Field is a single piece of agricultural land abutting Main Street Iden of approximately 0.69 hectares identified as IDE0021. It is deeply disappointing that the ROTHER DISTRICT COUNCIL DRAFT HOUSING AND ECONOMIC LAND AVAILABILITY ASSESSMENT (HELAA) PART 2: SITE ASSESSMENTS CHAPTER 4: RYE AND THE EASTERN SETTLEMENTS CLUSTER DOCUMENT of April 2024, has identified part of Street Field - the portion of land IDE0010 [hereinafter identified by us as Street Field West]- as ‘potentially available’ for the development of 10 dwellings along Main Street Iden, by the year 2028. In this submission, we wish to register a number of objections to the proposal set out in IDE0010.
2. We begin our submission by stating our full support for the government’s desire to accelerate the building of new houses across the country, in particular of ‘affordable houses’. This is an admirable policy. As will become clear in our submission however, we have serious concerns where new housing development is proposed without any, or any sufficient provision of the necessary infrastructure (local job opportunities, medical and education facilities, public transport, energy provision ad so on) essential to make sense of and therefore to justify any particular new housing development.
3. For many years, Iden Parish Council has submitted local plans to Rother District Council which specifically rule out any development of the agricultural land East of Main Street, because there has been a strong desire for Iden to remain one of those increasingly rare villages that retains its rural heritage. Although we accept that development policy can (and sometimes must) change to reflect new housing priorities, the Iden Parish Council position has been strongly supported in the past by Rother District Council, for example in the RDC Development and Site Allocation Local Plan dated 16 December 2019 (DaSa). In this document it is stated as follows:
There is very limited scope for development in and around the village [Iden]. There is little opportunity for infill within the development boundary. Development east of the village, where extensive views may be gained across the countryside, would encroach negatively into the wider AONB landscape. ….. (Similarly) development to the south would inappropriately extend growth along Main Street, encroaching into an area of rural character [11.133].
4. IDEOO21 states as follows.
This is a gently sloping, open field at the southern end of the village, forming part of a wider fieldscape which extends into open countryside to the east. It is bordered by short terraces of cottages, including several grade II listed buildings on its south-eastern and south-western boundaries. It has a substantial roadside hedge on its boundary with Main Street and a field access. The western part of the field [Street Field West] is assessed separately as IDE0010. While this separate section could potentially be suitable for a short terrace of small houses fronting Main Street, development into the remainder of the field would not be appropriate as this would be out of keeping with and harmful to the settlement pattern and the rural setting of the village within the countryside of the National Landscape, and could harm the setting of the adjacent listed buildings.
5. Having explained with solid reasoning why Street Field is generally unsuitable for development, the document reaches the opposite conclusion regarding the western portion of the field. Street Field West. This approach reads as disingenuous and inherently contradictory.
IDEOO10: The site forms the western section of a gently sloping open field at the southern end of the village, forming part of a wider fieldscape which extends into open countryside to the east. It is bordered by a short terrace of cottages, including grade II listed buildings, on its southern boundary. It has a substantial roadside hedge on its boundary with Main Street and a field access. The site could be suitable for a short terrace of small houses fronting Main Street, which would continue the adjoining ribbon development northwards. This is subject to the retention of as much of the roadside hedge as possible, allowing for an access and footway. Any development would need to be of an appropriate high quality design in order to respect the setting of adjacent listed buildings and the rural setting of the village within the High Weald National Landscape. Initial Highway Authority comments suggest that sightlines would need to be increased by the cutting back of vegetation, and a footway provided outside the site.


6. Observations:
• Iden is a small village of c. 450 residents, situated in an area of outstanding natural beauty adjoining/near Romney Marsh. It has many Grade II listed properties clustered around the proposed development site, of which several date back to the 16th century. Listed building property owners are legally bound to maintain the status of these buildings, which form part of the character of the area. Owners are prevented from altering or extending any part of these listed buildings unless fully compliant with stringent planning requirements, which have been designed to maintain the vernacular appearance and historic character of the area in which they are situated. It would be perverse and counter intuitive for the Rother District Council to support this proposed ‘ribbon housing extension’ in the centre of this cluster of listed buildings, a development that would most likely alter the character of the village for ever. Visitors regularly comment on the wonderful experience of arriving at Iden from the more urbanised settlements at Playden, Rye Foreign and Peasmarsh. They feel they have entered a rural gem where one can stop at the gate entrance to Street Field to admire the scene of grazing sheep with lambs etc. Rother District Council reflects this observation at 11.129 to 11.131 of the DaSa [see supra para. 3].

• IDEOO10 suggests that this potential site ‘could be suitable for a short terrace of 10 small houses fronting Main Street, which would continue the adjoining ribbon development northward’. This so-called ‘ribbon development’ i, in fact a cluster of four charming 1850s cottages, quite unsuitable to be annexed to any modern ‘ribbon development’. Suggesting the roadside hedge ‘should be retained as much as possible’ is a fantasy. This ancient hedge would disappear under a footway which itself would abut a busy and relatively narrow highway.

• Iden is part of the HELAA Eastern Developments Cluster of 12 communities, all of which rely heavily on Rye for schools and medical support. At present, although the Medical Centre provides excellent care, such is existing demand that routine GP appointments are offered one month ahead, which many people feel is unacceptable. The proposed new site will only increase this problem and offers no collateral solution.

• Iden has no mains gas. The existing houses rely either on oil, wood burning stoves or expensive electric alternatives. There are no sustainable inexpensive alternatives yet available to the public in Britain, other than air source heat pumps. The HELAA proposal does not address this issue in any coherent way. The increased pressure on fragile water supplies and sewage disposal systems that the proposed development would inevitably generate, is also not accounted for in the proposal.

• There is already a considerable amount of through traffic frequently flouting the speed limits in Main St, Iden. The proposed new development abutting Main St would inevitably lead to a significant increase in motor traffic with concomitant danger to life, and further environmental destruction occasioned by the arrival of c. 20 more residential motor vehicles, increased pressure generally on limited parking options, an increase in local delivery vehicles and so on.

• Iden has a strong public commitment to maintaining its status as a Dark Sky Area which helps enhance its special rural qualities. The amount of lighting associated with any such development on Street Field West would completely undermine and effectively bring to an end this commitment.
We wish to register our objection to this proposal.
Jeremy Cooper and Clare Picking

I am supportive of the principles of Green to the Core and Live Well Locally.

I also see the value in ranking areas of Rother according to their sustainability as a framework for decision making.

However, neither the principles or the sustainability ranking are appropriately applied in the HELAA and thus the plan fails to deliver on its vision.

Specifically, Iden is rated as a low sustainability area and yet the HELAA proposes two additional sites for development creating a total of 25 properties in the village. It is incongruous to suggest that an area that is designated low sustainability could support this level of development. If an area is low sustainability then it is not fit for development unless and until the metrics for sustainability improve.

To suggest that additional land at the rear of Conkers IDE0011 be brought forward despite previously being ruled out because of the position of listed building is ridiculous. Nothing has changed regarding the situation of the listed properties so why is land previously rejected now being considered as an option. The only reason surely is pressure from developers.

A further major shortcoming with this plan is that it does not put forward a strategy / plan for sites to be brought forward for BNG and it is therefore not clear how Rother will meet its commitment to 20% BNG. The target for 20% is good however it should be accompanied by a plan to meet that commitment within the boundary of Rother. Given the fact that much of Rother sits is in an AONB, it should be possible for Rother to make significant process in meeting its own target of 20%.

It is also the case that with no plan for sites for BNG, there are no incentives for land owners to bring forward sites and thus potentially excellent sites for BNG will be lost to development. Rother simply risks undermining its own commitments.

In summary, the vision for the plan is good from a theoretical perspective but it will fail in practical application.

Please see three separate attachments for the full representations

Please see full the Environment Agency's representations, please see attached submission document.

Please see full the Environment Agency's representations, please see attached submission document.