My name is Jacqueline Boyce. I have lived in Flimwell for 28 years. I am a 60 year old disabled widow and was horrified to discover that land North of Broom Hill is being considered for a Traveller Site (GYP0002).

I strongly object to this. This land runs alongside my private road and would result in a great deal of noise and disruption. This is an Area of Outstanding Natural Beauty and would therefore impact badly the beauty and rural aspect of this quiet location. Bewl Water is close by. This a much loved destination for visitors and locals alike, offering an abundance of footpaths, bridalways and cycle paths for fun and healthy leisure time.

The site itself has a footpath within it's boundaries which is widely used by walkers and dogs.

Living close by the site often appears extremely wet and boggy.

Hopefully these plans will be unsuccessful and we can all breathe a sigh of relief.

Re: proposed traveller site GYP0003 at The Hollies, Flimwell in Ticehurst Parish.

We wish to object to the proposed gypsy site on the draft local plan at The Hollies, The Mount, Flimwell in Ticehurst Parish.

As we are sure you know, the site know as The Hollies, has recently had an appeal for 4 houses dismissed under the title of ‘Land adjacent to Seacox Cockers, The Mount, Flimwell, Ticehurst, TN5 7QP’,
APP/U1430/W/23/3321909, and an enforcement notice ( also being appealed) for the removal of a static mobile home and caravan and other paraphernalia.

In light of the Governments Planning Policy for Traveller Sites, updated 19 December 2023, the document states the following points (in quotation marks) to which we have added comments in relation to this proposal:

1. Introduction
Section 4
g. "for local planning authorities to ensure that their Local Plan includes fair, realistic and inclusive policies"

As settled community housing has been refused at appeal for this site, surely permitting a traveller site would be unfair and not inclusive to the settled community
h. to increase the number of traveller sites in appropriate locations with planning permission, to address under provision and maintain an appropriate level of supply
This site is in an inappropriate location for all the heritage and landscape reasons stated in the Inspectors decision (APP/U1430/W/23/3321909) against housing on the site. In particular the impact on the grade 2 listed house next door to the site, the woodland TPO and its location in the High Weald NL. The site is adjacent to ancient woodland and a local Wildlife site. It is not possible to build an access that is acceptable with regards to Highway safety and the site is outside the defined development boundary for Flimwell. To reiterate, the static mobile home and caravan on site are there without planning permission.
i. to reduce tensions between settled and traveller communities in plan-making and planning decisions
The management of the site ( and other sites in the locality in the past) has created tensions within the local population and it is difficult to see how these tensions would be lessened, and most probably increased, if a traveller site was permitted on this site.

j. "to enable provision of suitable accommodation from which travellers can access education, health, welfare and employment infrastructure"

Flimwell does not have a school, health facilities or employment infrastructure and the nearest facilities are in Ticehurst or Hawkhurst

k. "for local planning authorities to have due regard to the protection of local amenity and local environment"

The Inspector, in dismissing the appeal for housing at this site, was very clear that extensive development in the form of dwellings and parking, and further removal of trees from this site ‘would lead to a substantial and unduly harmful change to the character of the site’. He also said that development on this site would prevent the rejuvenation of woodland trees which provide the distinctive treed character and appearance of the area. Importantly, development on this site would not ‘conserve or enhance the landscape and scenic beauty of this section of the High Weald NL, a matter that the Framework requires to be given great weight.’ In fact development would harm it. So it is very hard to see how a traveller site here would be any less harmful.

4. Decision making
25. "Local planning authorities should very strictly limit new traveller site development in open countryside that is away from existing settlements or outside areas allocated in the development plan. Local planning authorities should ensure that sites in rural areas respect the scale of, and do not dominate, the nearest settled community, and avoid placing an undue pressure on the local infrastructure."

A traveller site at this rural location would dominate the surrounding houses ( increasing dwellings by 15%) and degrade and harm the local amenity of residents by virtue of the damage it would cause to the High Weald NL and the loss of high value broad leaf trees protected by the woodland TPO. The site is also outside the development area for Flimwell as stated in the Local Neighbourhood Plan.

In 2012 we made comments to the Council in response to a proposed gypsy site at Cherry Tree Nursery, Flimwell, asking why the Council are not ensuring that permanent gypsy sites are incorporated into large scale housing developments which are supposed to have mixed housing allocations and are sited in highly sustainable areas, such as the large housing projects built near Bexhill and Rye in recent years and the many sites being considered in the current Draft plan. This would surely be a much fairer and inclusive way of ensuring sufficient and well planned gypsy pitches in appropriate areas. So, rather than the Council calling for sites which are inevitably put forward by land owners wishing to cash in their otherwise valueless land in inappropriate areas, and to the frustration of the settled community, wouldn’t this be a better and more sustainable way forward?

CONTESTING THE PLANNING APPLICATION FOR THE FOLLOWING-

GYP0003/GYP0002
TIC0043/TIC0044/TIC0008/TIC0027

After reading the proposed housing development and traveler sites of the above reference numbers I would like to object to all of the proposed plans for the following reasons.

• Reasons to object applications

- The areas are in the National landscape. This area needs to be protected in its Area of outstanding natural beauty. This is the reason people originally brought their properties in this area because they respect the environment around and would like to maintain it.

- This plan will have a detrimental effect on the wildlife, biodiversity and habitats of so many plants and animals. This will then mean that there would be a rapid decline in the wildlife and landscape that needs protecting so greatly. Also from a medical view point the destroying of the land and natural habitats and building up the area will potentially cause more pollution and problems for our ecosystem and the health of the residence.

- There would also be a huge impact on the listed buildings and protected lands in the area. There has been other housing development applications dismissed for this very reason. Please refer to the Seacox Cockers site (now being called the Hollies) as this has already been inspected and dismissed.

- A hugely important factor in not allowing these applications is also how it will unsettle the local community. The infrastructure is not here to support such developments. The doctors surgeries, dentists and schools in the area are already at full capacity and struggling hugely with the people that are already here. At the moment the waiting time for a Doctor’s appointment is weeks and surgeries cannot add more people to this already failing system. Therefore, adding more pressure to the community will only further strain resources and make the lives of locals that much harder than it is already.

The roads are also not adequately prepared for even more congestion. The traffic lights at Flimwell are already under pressure from sheer volume of vehicles and the smaller roads become completely congested most of the time already. The impact of the CO2 and emissions on the surrounding area would have an impact on residence and the land/wildlife potentially causing health concerns and damage. Unless the council is planning to rectify all these issues first then there is not the sustainability or the infrastructure to make this work without causing huge disruption and problems for the local community already. I would advise that the traffic situation is looked at especially at peak times and the already long wait times to get around the local area and this will only become so much worse with more vehicles added to the roads and land.

The area has oak trees of nearly 500 years old and many animal habitats will be affected by all of these sites, especially a traveler sites which would potentially cause irreversible damage. Who is going to clear the traveler site once people have moved on? What would happen to the rubbish and waste and the safety concerns around the area and the impact this would have. This could cause contamination of so many natural habitats. There is no exceptional circumstances why these sites need to be there so therefore it is unjustified.

These applications are causing nothing but distress to an already settled community and the council has an obligation to the residence to ensure that they are doing what is best for the settled community. If these applications go ahead then that will not be for the best interest of anyone already living in the local area.

There are not adequate facilities or public transport to accommodate more buildings in the area or traveller sites. There is a bus that runs through once an hour which is certain times is already full (I use this myself) and the school times are incredibly busy. Unless the council is planning to expand the public transport in the area then it will not be able to keep up with the potential pressures that more people will cause. This in turn will then mean more people will drive and this will cause a higher level of pollution in the community and have the knock on effect of causing harm to the residence and the wildlife/natural habitats.

There is documented proof that there are rare birds (some on the red list) residing in these areas and also there are rare bats nesting in the woodlands and across the pastures due for the sites and developments which need to be protected. A full survey will show that these sites cannot be touched for those reasons alone as it will be endangering the natural habitats of many species of animals/birds/plants. This cannot be justified by the council.

The biodiversity is very important in this area of outstanding natural beauty and the community has worked hard to support all wildlife and natural regeneration. These proposed sites would have a detrimental effect on the progress that has been made.

In conclusion the area of Flimwell under the proposed site references above is just not appropriate and I firmly oppose the applications. The local, schools, doctors, roads and other infrastructure is no there to support more buildings and sites. Also, the natural habitats of so many animals, plants and trees will be destroyed. These applications are a great source of uncertainty, anxiety and trepidation of a local community that is supportive of our surroundings and live here for the purpose of keeping it the way it is and to preserve the Area of Natural Beauty that we are lucky enough to live in. There is a huge safety concern also for us. Because of all the extra traffic, vehicles and people that will be in an area that cannot sustain it. The land all around Flimwell is used daily for so many people for walking, conservation of the environment and so much more that if this was taken away it would devalue the area greatly.

CONTESTING THE PLANNING APPLICATION FOR THE FOLLOWING-

GYP0003/GYP0002
TIC0043/TIC0044/TIC0008/TIC0027

After reading the proposed housing development and traveler sites of the above reference numbers I would like to object to all of the proposed plans for the following reasons.

• Reasons to object applications

- The areas are in the National landscape. This area needs to be protected in its Area of outstanding natural beauty. This is the reason people originally brought their properties in this area because they respect the environment around and would like to maintain it.

- This plan will have a detrimental effect on the wildlife, biodiversity and habitats of so many plants and animals. This will then mean that there would be a rapid decline in the wildlife and landscape that needs protecting so greatly. Also from a medical view point the destroying of the land and natural habitats and building up the area will potentially cause more pollution and problems for our ecosystem and the health of the residence.

- There would also be a huge impact on the listed buildings and protected lands in the area. There has been other housing development applications dismissed for this very reason. Please refer to the Seacox Cockers site (now being called the Hollies) as this has already been inspected and dismissed.

- A hugely important factor in not allowing these applications is also how it will unsettle the local community. The infrastructure is not here to support such developments. The doctors surgeries, dentists and schools in the area are already at full capacity and struggling hugely with the people that are already here. At the moment the waiting time for a Doctor’s appointment is weeks and surgeries cannot add more people to this already failing system. Therefore, adding more pressure to the community will only further strain resources and make the lives of locals that much harder than it is already.

The roads are also not adequately prepared for even more congestion. The traffic lights at Flimwell are already under pressure from sheer volume of vehicles and the smaller roads become completely congested most of the time already. The impact of the CO2 and emissions on the surrounding area would have an impact on residence and the land/wildlife potentially causing health concerns and damage. Unless the council is planning to rectify all these issues first then there is not the sustainability or the infrastructure to make this work without causing huge disruption and problems for the local community already. I would advise that the traffic situation is looked at especially at peak times and the already long wait times to get around the local area and this will only become so much worse with more vehicles added to the roads and land.

The area has oak trees of nearly 500 years old and many animal habitats will be affected by all of these sites, especially a traveler sites which would potentially cause irreversible damage. Who is going to clear the traveler site once people have moved on? What would happen to the rubbish and waste and the safety concerns around the area and the impact this would have. This could cause contamination of so many natural habitats. There is no exceptional circumstances why these sites need to be there so therefore it is unjustified.

These applications are causing nothing but distress to an already settled community and the council has an obligation to the residence to ensure that they are doing what is best for the settled community. If these applications go ahead then that will not be for the best interest of anyone already living in the local area.

There are not adequate facilities or public transport to accommodate more buildings in the area or traveller sites. There is a bus that runs through once an hour which is certain times is already full (I use this myself) and the school times are incredibly busy. Unless the council is planning to expand the public transport in the area then it will not be able to keep up with the potential pressures that more people will cause. This in turn will then mean more people will drive and this will cause a higher level of pollution in the community and have the knock on effect of causing harm to the residence and the wildlife/natural habitats.

There is documented proof that there are rare birds (some on the red list) residing in these areas and also there are rare bats nesting in the woodlands and across the pastures due for the sites and developments which need to be protected. A full survey will show that these sites cannot be touched for those reasons alone as it will be endangering the natural habitats of many species of animals/birds/plants. This cannot be justified by the council.

The biodiversity is very important in this area of outstanding natural beauty and the community has worked hard to support all wildlife and natural regeneration. These proposed sites would have a detrimental effect on the progress that has been made.

In conclusion the area of Flimwell under the proposed site references above is just not appropriate and I firmly oppose the applications. The local, schools, doctors, roads and other infrastructure is no there to support more buildings and sites. Also, the natural habitats of so many animals, plants and trees will be destroyed. These applications are a great source of uncertainty, anxiety and trepidation of a local community that is supportive of our surroundings and live here for the purpose of keeping it the way it is and to preserve the Area of Natural Beauty that we are lucky enough to live in. There is a huge safety concern also for us. Because of all the extra traffic, vehicles and people that will be in an area that cannot sustain it. The land all around Flimwell is used daily for so many people for walking, conservation of the environment and so much more that if this was taken away it would devalue the area greatly.

We object to the proposed development site because of the following.

1. The open field in question is the only green site left between Flimwell and Ticehurst.

2. At the bottom of the field is a wood with a public footpath through it for walking to Bewl Water. This footpath is regularly used by us elderly folk who live in Downash Court and also dog walkers. It is the only safe walk around here because Rosemary Lane is used as a rat run by people wanting to avoid the traffic lights on the A21.

3. Legislation has been recently been passed that on any new building sites the developer must maintain the biodiversity and also increase the biodiversity by 10%. How will this be achieved?

4. There is no footpath between the proposed site and the local school which is approximately 1.5 miles away. Safety for any children is a concern.

5. Traffic volume along the B2087 is high. A vehicle access way to the proposed site could cause a serious problem.

Strongly objecting to the proposal.

Gypsies and travellers wishing to create permanent locations should not be permitted to apply and develop outside of planning control

Please see attached comments from Burwash Parish Council.

Q2. Council feels that both are key to our Community with equal priority.

Q24. Clarification of "all qualifying development" is sought.
Council would like to prevent pre-emptive works at sites prior to submission of planning applications.

Q28. Agree the principle but very hard to visualise dwellings per hectare. Particularly when looking at rural areas.
Examples in our location would be helpful ie number of properties in Coronation Gardens per hectare, for example.


Q30. Whilst we feel this is a positive ambition, this may be impracticle for a town such as Battle.

Q33. In agreement with proposals, but clear access must be available. Blackfriars access to Battle Railway Station is a point in case of outside site access.

Q34. Council should make developers responsible for access outside site compulsory.

Q35. Applaud this objective but would once again highlight the Blackfriars development not having easy access to the Railway Station which would make walking outside of this 400m proposal.

Q39. This is an important policy and Council would like this enforced. However, it is disappointing that the Blackfriars development has not been approved in accordance with existing Battle Civil Parish Neighbourhood Plan policies.

Q46. Council feels that consideration should be to all disabilities, not only dementia sufferers; such as less ambulant people and those with hearing difficulties etc.
In relation to play areas, these should be sited in an appropriate safe, central location.

Q64. The topography of the central area of Battle town does not lend itself to significant further dwellings to be developed within the development boundary.
There may be very small opportunties for developments outside the development boundary but within the 800m constraint.
Broadly speaking, the number of dwellings suggested seems to be most unachievable.
During the development of the Battle Civil Parish Neighbourhood Plan, despite calls for employment opportunity developments, there was only one response.

Q74. These policies should be strictly adherred to, to protect the environment.

Q75. Subsequent to this Reg 18 document, Council would like to emphasise that the "Fir Tree Cottage" site at Netherfield only has temporary permission for three years and must be returned to agricultural use.

Q76. We do not agree that Battle is placed in the "Greater opportunities for growth" column in figure 35. In main part due to the topography of the Civil Parish and, at best, should be placed in the "Medium growth opportunities".
We are pleased to see that Mountfield and Whatlington in our SDO have been recognised in the column "Limited growth opportunities".

Q104. We welcome this policy.

Q116. For planning applications where affordable housing is approved, following applications to change the conditions will be greatly deplicated.

Q119. Council does not agree with this policy. There should be a mix of housing - 'pepperpotting'.

Q121. We do not wish to see this, as above.

Q183. LAN3 paragrpah 3 should have roof lights added as an example of discouraged glazing.
Planning applicants should be encouraged to use electrochromic glass.

Gypsy, Traveller and Travelling Showpeople Accommodation Needs:

We note that the joint East Sussex Gypsy, Traveller and Travelling Showpeople
Accommodation Needs Assessment (2022) identifies that Rother district will need to provide
an additional 22 pitches for gypsies and travellers to meet their accommodation needs over
the emerging Local Plan period. Similar to WDC, the ongoing ‘Call for Sites’ exercise RDC
is undertaking will provide an opportunity for the relevant stakeholders to put forward sites
to be considered for allocation for gypsy and traveller pitches or travelling showpeople plots
through the emerging Local Plan. WDC recognises that this will require further technical
work and that this is ongoing.

See attached document

I live in Flimwell not far from Site GYP0002 . I am surprised that the site is under consideration bearing in mind the summary of environmental constraints as you note at page 6 in Appendix 1 of your paper .

I believe the above site is totally unsuitable for consideration on the following grounds:

1. It is in an area of outstanding natural beauty and within the Weald National Landscape . I am not aware of any exception that would override the fundamental characteristics of an AONB namely tranquillity , the protection of wildlife and vegetation and light protection.
2. Any development must Conserve and enhance the area , that cannot be the result in this case and both issues must be covered . Six pitches are referred to which can have 2 caravans on each pitch , plus other vehicles and business equipment and no doubt animals such as dogs which would be a danger to wildlife and stock . I would suggest the likelihood would be material damage within an AONB.
3. As noted the area is adjacent to ancient woodland , there is a risk of flooding from surface water , there are historic field boundaries and there is an adjacent public footpath.
4. There have been unsuccessful applications for planning in the past in this area where many of the above points have been relevant . There have also been other applications in the Ticehurst area affecting an AONB and although not relating to a traveller’s site many of the issues dealt with in one such application and Appeal are relevant . The Appeal decision related to the Old Vineyard, Pashley Road Ticehurst and the defence to the Appeal by Rother District Council was successful and I believe a number of the detailed points in the Inspector’s decision are relevant and should be considered . The decision is dated the 24th April 2024 and the appeal reference is APP/U1430/W/23/3330956.
5. Consideration of the site would be contrary to the Ticehurst Neighbourhood Plan which I would suggest should be respected and supported.
6. Finally it appears an anomaly in the system that individual property speculation can result from any individual or organisation who might benefit commercially putting forward a suggested site which might have the result of converting an uneconomical site of an AONB into to a development with a commercial value . It may not be the case on the sites in the Interim report but the risk is clearly apparent.

Re: Rother Local Plan - Identification of potential land for Traveller Sites on land at Berners Hill, Flimwell (GYP0002)

I wish to present comments on a number of points in relation to the identification of GYP0002 in Berners Hill, Flimwell as a potential site for Traveller caravan plots:

1. Impact on Natural Beauty and Landscape Quality: The proposal is located within an AONB, a designation intended to conserve and enhance the natural beauty of the area. The introduction of up to 6 pitches of 2 caravans and associated infrastructure would result in a significant adverse impact on the visual and landscape quality of the area. This development does not align with the principles of protecting and enhancing the natural environment as stipulated in the National Planning Policy Framework (NPPF) and local planning policies.

2. Incompatibility with Local Plan Policies: The proposal fails to comply with specific policies within the Ticehurst Neighbourhood Plan that aim to restrict development within AONBs unless there are exceptional circumstances. The application does not demonstrate any such exceptional circumstances or an overriding need for the development in this sensitive location.

3. Environmental Impact: The proposed site development would likely result in environmental degradation, including potential harm to local wildlife habitats and ecosystems. The application lacks sufficient mitigation measures to address these concerns, making the proposal environmentally unsustainable. The site is also adjacent to ancient woodland and a popular public footpath.

4. Infrastructure and Services: The proposed development does not adequately address the provision of necessary infrastructure and services, including water, sanitation, and waste management. The lack of appropriate facilities could lead to negative impacts on the local community and environment.

5. Precedent for Future Development: Approving this application could set an undesirable precedent for future developments within the AONB, undermining the integrity of the protected status and leading to incremental harm to the area's natural beauty. Similar developments in the local area have been rejected in the past for the above points making them relevant to rejecting this proposal. It is also concerning the way that seemingly uneconomical land within an AONB can be proposed by an individual who may benefit commercially from the proposal.

Given these reasons, I believe the site to be wholly unsuitable for the proposal and would like these points and comments considered by those dealing with the interim report.

As a resident of Rother District, I would like to share some thoughts and observations regarding the Interim Report on identifying sites for Gypsies and Travellers within the district.
I reside in Flimwell, in close proximity to Site GYP0002. I am surprised that this site is being considered, especially given the summary of environmental constraints noted on page 6 of Appendix 1 in your report.
I believe Site GYP0002 is unsuitable for the following reasons:
1. Area of Outstanding Natural Beauty (AONB): The site is within the Weald National Landscape, characterized by tranquillity, protected wildlife and vegetation, and light protection. There are no known exceptions that justify overriding these fundamental characteristics.
2. Conservation and Enhancement: Development in an AONB must conserve and enhance the area. With six pitches, potentially accommodating up to two caravans each, plus additional vehicles, business equipment, and animals, there is a significant risk of material damage to the AONB, which contradicts conservation goals.
3. Environmental Constraints: The site is adjacent to ancient woodland, has a risk of surface water flooding, features historic field boundaries, and is near a public footpath. These factors further undermine its suitability.
4. Planning History: There have been previous unsuccessful planning applications in this area, highlighting similar concerns. Relevant points from the Appeal decision dated April 24, 2024 (Reference: APP/U1430/W/23/3330956) for the Old Vineyard, Pashley Road, Ticehurst, should also be considered. Rother District Council successfully defended this appeal, and many detailed points in the Inspector's decision are pertinent.
5. Ticehurst Neighbourhood Plan: The site consideration contradicts the Ticehurst Neighbourhood Plan, which should be respected and supported.
6. Commercial Speculation Risk: Allowing individual property speculation could convert uneconomical AONB sites into developments with commercial value. This poses a clear risk, even if not explicitly the case in the current Interim Report.
I urge those reviewing the Interim Report to carefully consider these points.

Please find our comments below on the proposed draft local plan:

Points specific to the unsuitability of the field referred to in the Local Plan which is specified as GYP0002 (on slide 10, “Identifying Sites for Gypsies, Travellers and Travelling Showpeople”) and TIC0039 (on p66, HELAA-Part 2- CHAPTER-5-NORTHERN-Compressed document), respectively.

The field (TIC0039) has already been deemed as unsuitable for a housing development in the document known as HELAA-PART 2-CHAPTER-5-NORTHERN-COMPRESSED and should not be considered for traveller’s site encampment (GYP0002) for the reasons given in that judgment by RDC, but there are additional ones.

Firstly, if the County Ecologist for East Sussex was allowed to examine the field, evidence would probably be found that it is a live habitat for natural wildlife and rare plants and deemed it unsuitable for development in the context of environmental and ecological reasons. Anecdotally, I can tell you that in and around the ancient woodland and gardens, which surround the field, there are barn owls, kestrels, woodpeckers, falcons, buzzards and several smaller wild birds, as well as shrews and hedgehogs, resident. The YouGov guidance on “Protected species and development: advice for local planning authorities” is very clear on the need to protect such lands for wildlife.

The choice of field as a proposed site by RDC also does not take sufficient account of the recommendations laid down in the “Planning Policy for Traveller’s Sites” in my view, which would also probably emerge as a point of concern to the travelling communities being considered for the site themselves. There is a lack of safe road access to the field (GYP0002). The B2087 has no continuous footpath to Ticehurst and in places, is hazardous to pedestrians, mainly because of its bends in both directions, as illustrated by the traffic accidents that have occurred over the past several years. The private road that provides access to Ketley Wood Lodge is too narrow to sustain large traveller vehicles. It is not safe for children to walk to the primary school in Ticehurst, the bus services are only hourly and train access is some miles away in Stonegate and Etchingham.

Furthermore, there is a lack of basic amenities to support a travelling community in Flimwell. Apart from the smokery, there are no food shops; the nearest grocery outlets are in Ticehurst (about one mile away) and Hawkhurst (four miles distant). Doctor’s surgeries, dentists, chemists, post offices and garages for fuel and repairs simply do not exist in Flimwell.

Finally, the field is not viable as a site, because it is on an incline and prone to flooding at the bottom. Provision of a basic hard-standing in order to accommodate caravans, cars and HGV’s, as well as gas, electric lighting and water would be expensive. Moreover, if suitable provision is not made for rubbish collection, sewage and noise/light pollution, as well as safeguards against grassland fires, the detrimental effect upon resident wildlife could be catastrophic.

In conclusion, while I empathise with the RDC Planning Department that accommodation must be made for the travelling communities and new housing developments within its district boundaries, an obligation is there to protect obvious green-belt land and to locate such developments where adequate amenities and infrastructure exists.

As its predecessor, the new national Labour Government is still keen to prioritise brown-field sites for new traveller's compounds and housing developments and, even its refined definition of so-called “grey-belt” land at the extreme only focuses on areas previously used mainly for industrial use or redundant car parking in rural areas, which is much lower quality green-belt land.

Much of RDC’s proposed developments in its 2020-2040 Local Plan is on prime green-belt land, which includes ancient woodland and area of natural wildlife and this needs to be reconsidered in its revised plans and consultations.

If adequate land according to new national government guidelines is not available for development, RDC should not consider prime green-belt fields for such purposes.

If accommodation has to be made for new housing and traveller sites in Rother, please focus on the brown field areas first and only the grey ones in case of urgent need.

Please find our comments below on the proposed draft local plan:

Points specific to the unsuitability of the field referred to in the Local Plan which is specified as GYP0002 (on slide 10, “Identifying Sites for Gypsies, Travellers and Travelling Showpeople”) and TIC0039 (on p66, HELAA-Part 2- CHAPTER-5-NORTHERN-Compressed document), respectively.

The field (TIC0039) has already been deemed as unsuitable for a housing development in the document known as HELAA-PART 2-CHAPTER-5-NORTHERN-COMPRESSED and should not be considered for traveller’s site encampment (GYP0002) for the reasons given in that judgment by RDC, but there are additional ones.

Firstly, if the County Ecologist for East Sussex was allowed to examine the field, evidence would probably be found that it is a live habitat for natural wildlife and rare plants and deemed it unsuitable for development in the context of environmental and ecological reasons. Anecdotally, I can tell you that in and around the ancient woodland and gardens, which surround the field, there are barn owls, kestrels, woodpeckers, falcons, buzzards and several smaller wild birds, as well as shrews and hedgehogs, resident. The YouGov guidance on “Protected species and development: advice for local planning authorities” is very clear on the need to protect such lands for wildlife.

The choice of field as a proposed site by RDC also does not take sufficient account of the recommendations laid down in the “Planning Policy for Traveller’s Sites” in my view, which would also probably emerge as a point of concern to the travelling communities being considered for the site themselves. There is a lack of safe road access to the field (GYP0002). The B2087 has no continuous footpath to Ticehurst and in places, is hazardous to pedestrians, mainly because of its bends in both directions, as illustrated by the traffic accidents that have occurred over the past several years. The private road that provides access to Ketley Wood Lodge is too narrow to sustain large traveller vehicles. It is not safe for children to walk to the primary school in Ticehurst, the bus services are only hourly and train access is some miles away in Stonegate and Etchingham.

Furthermore, there is a lack of basic amenities to support a travelling community in Flimwell. Apart from the smokery, there are no food shops; the nearest grocery outlets are in Ticehurst (about one mile away) and Hawkhurst (four miles distant). Doctor’s surgeries, dentists, chemists, post offices and garages for fuel and repairs simply do not exist in Flimwell.

Finally, the field is not viable as a site, because it is on an incline and prone to flooding at the bottom. Provision of a basic hard-standing in order to accommodate caravans, cars and HGV’s, as well as gas, electric lighting and water would be expensive. Moreover, if suitable provision is not made for rubbish collection, sewage and noise/light pollution, as well as safeguards against grassland fires, the detrimental effect upon resident wildlife could be catastrophic.

In conclusion, while I empathise with the RDC Planning Department that accommodation must be made for the travelling communities and new housing developments within its district boundaries, an obligation is there to protect obvious green-belt land and to locate such developments where adequate amenities and infrastructure exists.

As its predecessor, the new national Labour Government is still keen to prioritise brown-field sites for new traveller's compounds and housing developments and, even its refined definition of so-called “grey-belt” land at the extreme only focuses on areas previously used mainly for industrial use or redundant car parking in rural areas, which is much lower quality green-belt land.

Much of RDC’s proposed developments in its 2020-2040 Local Plan is on prime green-belt land, which includes ancient woodland and area of natural wildlife and this needs to be reconsidered in its revised plans and consultations.

If adequate land according to new national government guidelines is not available for development, RDC should not consider prime green-belt fields for such purposes.

If accommodation has to be made for new housing and traveller sites in Rother, please focus on the brown field areas first and only the grey ones in case of urgent need.

Please see attached submission document, which includes representations on:

Objections to HELAA sites
- TIC0008: Flimwell East Broad Location, Hawkhurst Road, Flimwell
- TIC0027: Land rear of Fruitfields, High Street, Flimwell

Objections to
- GYP0002: Land north of Broom Hill, Flimwell, Ticehurst Parish
- GYP0003: The Hollies, The Mount, Flimwell, Ticehurst parish

Comment on
- GYP0005: Land at North Bexhill, Watermill Lane, Bexhill

Comment on
- The consultation process

Please see attached submission document, which includes representations on:

Objections to HELAA sites
- TIC0008: Flimwell East Broad Location, Hawkhurst Road, Flimwell
- TIC0027: Land rear of Fruitfields, High Street, Flimwell

Objections to
- GYP0002: Land north of Broom Hill, Flimwell, Ticehurst Parish
- GYP0003: The Hollies, The Mount, Flimwell, Ticehurst parish

Comment on
- GYP0005: Land at North Bexhill, Watermill Lane, Bexhill

Comment on
- The consultation process

Please see attached submission document, which includes representations on:

Objections to HELAA sites
- TIC0008: Flimwell East Broad Location, Hawkhurst Road, Flimwell
- TIC0027: Land rear of Fruitfields, High Street, Flimwell

Objections to
- GYP0002: Land north of Broom Hill, Flimwell, Ticehurst Parish
- GYP0003: The Hollies, The Mount, Flimwell, Ticehurst parish

Comment on
- GYP0005: Land at North Bexhill, Watermill Lane, Bexhill

Comment on
- The consultation process

DRAFT LOCAL PLAN 2020-2040 ... regarding GY 0038, GYP 0039, TIC 0027, TIC 0008

1/Proposed HOUSING DEVELOPMENTS in FLIMWELL:

Policy LWL 1/2 states Compact Developments in village areas show 25-45 density per hectare.
this includes backfill which as always has been resisted especially with the proximity to
Bedgebury Forest. there will be no "Demand Responsive Transport" in this area as it is on a bus
route and goes into Kent the east and the north.

Facilities and services says rural areas may be more than 800m, with safe good walking distance
to local amenities ie primary schools, doctors, parks and green spaces, shops, post offices and
banks.

None of these are within safe, usable walking routes. Nothing is within 20 minutes walk, its
impossible to use a bicycle safely and its too dangerous with the state of our local roads, and will
then necessitate use of cars and vans.

We have no good quality walking routes between Flimwell and Ticehurst for TIC0027 and the
same goes for the routes from Flimwell to Hawkhurst for TIC008.

We had a recent walkers death earlier this year in the area where the bulk of the new proposed
houses are mentioned in TIC008, behind The Weald Smokery and Sunnybank Cottages, and we
certainly need to be aware of the heavily congested A21 Crossroads which has certainly been an
Accident Blackspot for many years.

The proposed TIC0027 development has already had 9 houses put forward in The Neighbourhood
Plan. The remaining area of field is seen as a "future development opportunity". This area meets
the southern boundary of Warsdown Woodlands where there are trees up to 500 years old!!! i am
told that Section 15 of the NPPF affords the highest level of protection to ancient woodlands and
they should not be touched unless there are exceptional circumstances but of which there are
none in this case.

More recently a directive dated 01/05/2024 requires all developments to achieve a biodiversity net
gain. pollutants from the construction of 9 houses alone will cause irreparable damage to the
habitat and eco systems, with possible run-off of surface water and will pollute the stream leading
to the River Bewl !!!

Flimwell in general has limited job opportunities which will necessitate the use of the already over
stretched use of the A21.

It also has poor mobile and internet coverage, poor roads and pavements and cannot sustain
large housing developments as proposed within the LOCAL DRAFT PLAN 2020-40.


2/ GYP 0038 "The Hollies" on the Mount Flimwell:

Land now called The Hollies is covered by a Woodland tree preservation order and joins ancient
woodland to the South. The owner is already in breach of a tree preservation order and in breach
of a dwelling on the site without permission. He is also in breach of forming an access onto the
highway without permission from East Sussex County Council!!!!

In the HEELA assessment, it is a rejected site, unsuitable for dwellings.
Infrastructure needs to be in place in all areas as any new dwellings, should it be caravan,
wooden lodge or house, need energy and water efficient services.

The only amenities that are in this area are an expensive restaurant and also a high class Smokery
with a Deli / high class shop. I have now been told that the smokery business might have been
planned for demolishment in the HEELA maps !!


3/ GYP 0039 - Wardsdown

This is against POLICY R2 in Ticehurst Neighbourhood Plan, to maintain green gaps between
settlements.

in HEELA it is a rejected site as it does not meet Rother District Councils objectives and has
historical field boundaries and substantial ancient woodland to the north.


4/GENERAL. ..

In general, gypsy sites should be healthy and sustainable and inclusive, which support access to
jobs, general services, facilities where people can meet most of their daily needs within a
reasonable distance, to access shops, schools, doctors etc. Flimwell only has one bus an hour
and then only until early evening.

These 2 sites will increase dependancy on cars, increasing carbon emissions which is against the
"Green to the core" policies of the DRAFT LOCAL PLAN.

Both proposed sites are in an area of Outstanding Natural Beauty and this has the highest level of
protection.

Rother District Council have 80% of its land in the Natural Landscape.

I am made aware that Planning Policy for Travellers Sites states;
Section 3 {policy E} requires liaison with adjoining authorities that don't have such high levels of
restrictions and this must be done. It also states that there should be no development in a Green
Belt except in very special circumstances and I'm very sure there are none here!!!

The most recent NPPF guidance note, dated 01/05/2024 requires that all the provisions to protect
AONB from any developments except under "exceptional circumstances"

DRAFT LOCAL PLAN 2020-2040 ... regarding GY 0038, GYP 0039, TIC 0027, TIC 0008

1/Proposed HOUSING DEVELOPMENTS in FLIMWELL:

Policy LWL 1/2 states Compact Developments in village areas show 25-45 density per hectare.
this includes backfill which as always has been resisted especially with the proximity to
Bedgebury Forest. there will be no "Demand Responsive Transport" in this area as it is on a bus
route and goes into Kent the east and the north.

Facilities and services says rural areas may be more than 800m, with safe good walking distance
to local amenities ie primary schools, doctors, parks and green spaces, shops, post offices and
banks.

None of these are within safe, usable walking routes. Nothing is within 20 minutes walk, its
impossible to use a bicycle safely and its too dangerous with the state of our local roads, and will
then necessitate use of cars and vans.

We have no good quality walking routes between Flimwell and Ticehurst for TIC0027 and the
same goes for the routes from Flimwell to Hawkhurst for TIC008.

We had a recent walkers death earlier this year in the area where the bulk of the new proposed
houses are mentioned in TIC008, behind The Weald Smokery and Sunnybank Cottages, and we
certainly need to be aware of the heavily congested A21 Crossroads which has certainly been an
Accident Blackspot for many years.

The proposed TIC0027 development has already had 9 houses put forward in The Neighbourhood
Plan. The remaining area of field is seen as a "future development opportunity". This area meets
the southern boundary of Warsdown Woodlands where there are trees up to 500 years old!!! i am
told that Section 15 of the NPPF affords the highest level of protection to ancient woodlands and
they should not be touched unless there are exceptional circumstances but of which there are
none in this case.

More recently a directive dated 01/05/2024 requires all developments to achieve a biodiversity net
gain. pollutants from the construction of 9 houses alone will cause irreparable damage to the
habitat and eco systems, with possible run-off of surface water and will pollute the stream leading
to the River Bewl !!!

Flimwell in general has limited job opportunities which will necessitate the use of the already over
stretched use of the A21.

It also has poor mobile and internet coverage, poor roads and pavements and cannot sustain
large housing developments as proposed within the LOCAL DRAFT PLAN 2020-40.


2/ GYP 0038 "The Hollies" on the Mount Flimwell:

Land now called The Hollies is covered by a Woodland tree preservation order and joins ancient
woodland to the South. The owner is already in breach of a tree preservation order and in breach
of a dwelling on the site without permission. He is also in breach of forming an access onto the
highway without permission from East Sussex County Council!!!!

In the HEELA assessment, it is a rejected site, unsuitable for dwellings.
Infrastructure needs to be in place in all areas as any new dwellings, should it be caravan,
wooden lodge or house, need energy and water efficient services.

The only amenities that are in this area are an expensive restaurant and also a high class Smokery
with a Deli / high class shop. I have now been told that the smokery business might have been
planned for demolishment in the HEELA maps !!


3/ GYP 0039 - Wardsdown

This is against POLICY R2 in Ticehurst Neighbourhood Plan, to maintain green gaps between
settlements.

in HEELA it is a rejected site as it does not meet Rother District Councils objectives and has
historical field boundaries and substantial ancient woodland to the north.


4/GENERAL. ..

In general, gypsy sites should be healthy and sustainable and inclusive, which support access to
jobs, general services, facilities where people can meet most of their daily needs within a
reasonable distance, to access shops, schools, doctors etc. Flimwell only has one bus an hour
and then only until early evening.

These 2 sites will increase dependancy on cars, increasing carbon emissions which is against the
"Green to the core" policies of the DRAFT LOCAL PLAN.

Both proposed sites are in an area of Outstanding Natural Beauty and this has the highest level of
protection.

Rother District Council have 80% of its land in the Natural Landscape.

I am made aware that Planning Policy for Travellers Sites states;
Section 3 {policy E} requires liaison with adjoining authorities that don't have such high levels of
restrictions and this must be done. It also states that there should be no development in a Green
Belt except in very special circumstances and I'm very sure there are none here!!!

The most recent NPPF guidance note, dated 01/05/2024 requires that all the provisions to protect
AONB from any developments except under "exceptional circumstances"

DRAFT LOCAL PLAN 2020-2040 ... regarding GY 0038, GYP 0039, TIC 0027, TIC 0008

1/Proposed HOUSING DEVELOPMENTS in FLIMWELL:

Policy LWL 1/2 states Compact Developments in village areas show 25-45 density per hectare.
this includes backfill which as always has been resisted especially with the proximity to
Bedgebury Forest. there will be no "Demand Responsive Transport" in this area as it is on a bus
route and goes into Kent the east and the north.

Facilities and services says rural areas may be more than 800m, with safe good walking distance
to local amenities ie primary schools, doctors, parks and green spaces, shops, post offices and
banks.

None of these are within safe, usable walking routes. Nothing is within 20 minutes walk, its
impossible to use a bicycle safely and its too dangerous with the state of our local roads, and will
then necessitate use of cars and vans.

We have no good quality walking routes between Flimwell and Ticehurst for TIC0027 and the
same goes for the routes from Flimwell to Hawkhurst for TIC008.

We had a recent walkers death earlier this year in the area where the bulk of the new proposed
houses are mentioned in TIC008, behind The Weald Smokery and Sunnybank Cottages, and we
certainly need to be aware of the heavily congested A21 Crossroads which has certainly been an
Accident Blackspot for many years.

The proposed TIC0027 development has already had 9 houses put forward in The Neighbourhood
Plan. The remaining area of field is seen as a "future development opportunity". This area meets
the southern boundary of Warsdown Woodlands where there are trees up to 500 years old!!! i am
told that Section 15 of the NPPF affords the highest level of protection to ancient woodlands and
they should not be touched unless there are exceptional circumstances but of which there are
none in this case.

More recently a directive dated 01/05/2024 requires all developments to achieve a biodiversity net
gain. pollutants from the construction of 9 houses alone will cause irreparable damage to the
habitat and eco systems, with possible run-off of surface water and will pollute the stream leading
to the River Bewl !!!

Flimwell in general has limited job opportunities which will necessitate the use of the already over
stretched use of the A21.

It also has poor mobile and internet coverage, poor roads and pavements and cannot sustain
large housing developments as proposed within the LOCAL DRAFT PLAN 2020-40.


2/ GYP 0038 "The Hollies" on the Mount Flimwell:

Land now called The Hollies is covered by a Woodland tree preservation order and joins ancient
woodland to the South. The owner is already in breach of a tree preservation order and in breach
of a dwelling on the site without permission. He is also in breach of forming an access onto the
highway without permission from East Sussex County Council!!!!

In the HEELA assessment, it is a rejected site, unsuitable for dwellings.
Infrastructure needs to be in place in all areas as any new dwellings, should it be caravan,
wooden lodge or house, need energy and water efficient services.

The only amenities that are in this area are an expensive restaurant and also a high class Smokery
with a Deli / high class shop. I have now been told that the smokery business might have been
planned for demolishment in the HEELA maps !!


3/ GYP 0039 - Wardsdown

This is against POLICY R2 in Ticehurst Neighbourhood Plan, to maintain green gaps between
settlements.

in HEELA it is a rejected site as it does not meet Rother District Councils objectives and has
historical field boundaries and substantial ancient woodland to the north.


4/GENERAL. ..

In general, gypsy sites should be healthy and sustainable and inclusive, which support access to
jobs, general services, facilities where people can meet most of their daily needs within a
reasonable distance, to access shops, schools, doctors etc. Flimwell only has one bus an hour
and then only until early evening.

These 2 sites will increase dependancy on cars, increasing carbon emissions which is against the
"Green to the core" policies of the DRAFT LOCAL PLAN.

Both proposed sites are in an area of Outstanding Natural Beauty and this has the highest level of
protection.

Rother District Council have 80% of its land in the Natural Landscape.

I am made aware that Planning Policy for Travellers Sites states;
Section 3 {policy E} requires liaison with adjoining authorities that don't have such high levels of
restrictions and this must be done. It also states that there should be no development in a Green
Belt except in very special circumstances and I'm very sure there are none here!!!

The most recent NPPF guidance note, dated 01/05/2024 requires that all the provisions to protect
AONB from any developments except under "exceptional circumstances"

TIC0027

The land in question is in the High Weald National Landscape, adjacent to Ancient Woodland and a Priority Habitat.

This is a complete contradiction to NPPF section 13 paragraph 143(c) and section 15 paragraphs 180-188.

This site would destroy large areas of wildlife friendly land.

This land is in the National Landscape and borders ancient woodland which is afforded the highest level of protection under NPPF Section 15.

See also GTC8. LWL2 annd LWL3 are also relevant due to absence of facilities and services.

I would also refer to NPPF para 172 which emphasises the conservation and enhancement of AONB.

TIC005

The land in question is in the High Weald National Landscape, adjacent to Ancient Woodland and a Priority Habitat.

This is a complete contradiction to NPPF section 13 paragraph 143(c) and section 15 paragraphs 180-188.

This site would destroy large areas of wildlife friendly land see NPPF Guidance May 2024.

This land is in the National Landscape and borders ancient woodland which is afforded the highest level of protection under NPPF Section 15.

See also GTC8. LWL2 is also relevant due to absence of facilities and services.

I would also refer to NPPF para 172 which emphasises the conservation and enhancement of AONB.

TIC0039 - site GYP002

This is unsustainable as gypsy site.

I refer to NPP section 15 para 180 re protection and enhancement of valued landscape.

This development will not deliver net gain, see GTC8.

It also contravenes policy R2 re maintenance of a gap between Ticehurst and Flimwell.

I understand the land is boggy and is not suitable for caravans etc, in breach of policy LHN6.

Referring to planning policy for traveller sites section 1D and 3E, there should be no development in green belt areas except in exceptional circumstances. I do not believe any apply here.

It is against Core Strategy EN1 given impact in AONB location.

It is also contrary to GTC7 and see Policies LWL2 and LWL3 as to availability of local services and impact.