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

The snappy punchline of 'Green to the core' and 'Live well locally' is a bold attempt to show a commitment to protecting rural communities and local ecology but your HELAA land allocation of CAT0001 and potential site CAT0016 in Catsfield fly in the face of these claims/promises. The proposal of 60 new houses (some proposing to be built on protected AONB land) in this small rural village (doubling the size of the main village), is absolutely shocking and I object strongly to these sites being included for allocation in this plan. These proposals would not only destroy ancient woodland, biodiversity and protected wildlife habitats, they would also severely impact the lives of local residents with increased pollution and a serious decline in the already insufficient utilities and local infrastructure. This site is also within a high flood risk area. See further comments on HELAA Part 2 Chapter 3.

Please see attached representation, existing and proposed sites plans.

Please see attached submission

Q25.

Local housing needs necessitate that some development will be required within the High Weald National Landscape area and it is appropriate that any such development within this area is well-related to existing built-up areas and services. References to 'major development' within the policy are not well defined and lack the additional context provided within footnote 64 of the NPPF and could therefore mislead decision-makers into thinking this should apply to any 'major applications'. The policy as worded is therefore contrary to paragraph 16 of the NPPF which requires that policies are "clearly written and unambiguous, so it is evident how a decision maker should react to development proposals".

Reference to the High Weald Design Guide is supported and the proposed development concept at the Wild Meadows site has been considered in line with this Design Guide.

The proposed development reflects the positive characteristics of the built environment throughout the High Weald and makes effective and efficient use of the development site. The key principles that have determined the overall design and layout include:

• Prioritising walking and cycling routes within the site and ensuring permeability for those walking past, through and around the site, including improved access to both local facilities in Guestling Green (and those within the proposed development) and the surrounding countryside;
• Incorporating a central green public space that is addressed by the buildings around it;
• Meaningful public realm throughout the rest of the site with soft edges to streets, new tree planting and a rural character that reflects the character of the wider area;
• Residential layout that defines the streets within the site and provides strong street frontages offering both discernible building lines and architectural variety;
• An appropriate unit mix that reflects the local housing need for smaller dwellings and affordable housing;
• Parking integrated into the design and layout, with a mix of parking solutions to ensure that parking is discretely located where possible and not overly dominant at street level

Q51, 53

The Council's authority monitoring reports show that the Council have delivered between 98- 283 homes a year since 2011/12. Although completions have been rising over time, the scale of delivery falls significantly short of identified local housing needs (733 homes a year), as well as the agreed housing trajectory within the adopted Core Strategy (335 homes a year) and the proposed spatial development strategy for the Rother Local Plan 2020 - 2050 (258 to 364 homes a year).

The Council's existing housing policies and allocations are therefore significantly under-delivering on the agreed minimum housing requirements for the District and local need has grown since the adoption of the previous Core Strategy. Housing delivery will only improve consistently through the adoption of a new Local Plan with additional housing allocations and a revised policy framework that provides a more aspirational framework for housing delivery.
Without deliberate policy interventions to improve delivery, local supply and affordability issues will continue to worsen.

We therefore welcome the Council's intention to allocate additional sites for development and adopted a new Local Plan. It is essential that the new Plan does not impose constraints to development that suppress housing delivery unnecessarily. It is therefore essential that the local planning authority scrutinise its own evidence on supply and capacity to determine whether these figures are robust and whether there are further sources of supply that could
be relied upon or identified sites are capable of delivery additional housing.

It is noted that the housing requirement identified in the draft Plan currently is a supply-led figure that would not come close to meeting the identified local housing needs of the area and therefore all efforts must be made to find additional sources of supply.

The Wild Meadows site is one such location where the identified capacity of the site is being unnecessarily suppress within the Regulation 18 Plan. The site has been assessed as capable of delivering 14 new dwellings, but the Council's own minimum density target (25 dwellings per hectare (dph) in village locations) suggests that any allocation of this site should be seeking to
achieve a minimum of 28 new homes.

We have previously submitted a development concept that shows 29 new homes within the site alongside new community infrastructure including public greenspace and equipped playspace, and have provided a copy of this concept plan as part of this consultation response.

As mandatory housing targets have been re-established by central Government and national policy is likely to shift in favour of housing delivery (particularly on sites that can be delivered within the first five years of the Plan), there is a clear policy shift towards additional housing delivery. The delivery of at least 28 new homes on the Wild Meadows site would not only
deliver additional housing overall in the short term, but would also double the number of affordable homes that would be delivered on this site compared to the 14 unit estimate currently shown.

Q 59, 60, 61

We support the strategy for sustainable villages within this area and the concept plans for the proposed residential development at Wild Meadows already seek to enhance the public realm and provide new community facilities in Guestling Green, in accordance with this vision.

Guestling Green is an appropriate location for new housing growth and the allocation of the Wild Meadows site would deliver an appropriate scale of development that is commensurate to the size of the settlement. We believe that additional homes could be delivered on the Wild Meadows site in accordance with the Council's own minimum density target.

Q76

We welcome the recognition of Guestling as an appropriate location for growth.

Guestling Green provides an important local Primary School that serves the wider rural area, and the village also provides opportunities for development that can deliver new family housing, affordable homes and community infrastructure that will ultimately improve the overall sustainability of the settlement.

As set out in our response to other questions, the Wild Meadows site has the capacity to deliver new community infrastructure, including public amenity greenspace and equipped playspace that would provide a benefit to the entire settlement. The Wild Meadows site can also deliver 29 new homes at the Council's minimum density target (25 dwellings per hectare), which would
deliver a wide range of market and affordable homes and new family housing within walking distance of the Primary School.

The development can therefore improve the sustainability and viability of the settlement through appropriate growth and a gentle residential density. The settlement has been identified as a potential growth location in the past but the tightly drawn development boundary has prevented new development from coming forward and therefore the new Local Plan needs to be proactive in allocating the Wild Meadows site to ensure that the appropriate scale of growth and delivery of new community infrastructure can be achieved.

The scale of development proposed at Wild Meadows is commensurate to the size of the settlement and provides an excellent opportunity to sustain the settlement and address local
housing needs over the Plan period.

Q77.

We have serious concerns that the Council's intention to build a stepped housing trajectory into their strategy reflects a lack of aspiration to urgently address the under-delivery occurring within the District.

If delivery rates do not improve in the short term then the scale of unmet need will only worsen and the challenge to improve delivery at a later date will be potentially unachievable.

We are concerned that the Council is over-optimistic about its ability to achieve higher rates of delivery without immediate interventions and a step-change in the approach to housing delivery within this Local Plan.

One way to ensure that housing delivery if maximised throughout the Plan period is to review the potential capacity of sites identified as suitable for development and to ensure that the recommended minimum density targets are achieved on all these future allocations.

Please see attached:

- Draft Local Plan Representations
- Site Location Plan
- Existing Site Layout Plan
- Call for Sites Illustrative Layout Plan

Please see attached representations

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.

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Rurban Estates Limited.

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Catesby Strategic Land Ltd and Rurban Estates Limited.

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

See attachments for the submission to the Local Plan (Regulation 18) consultation from DHA Planning on behalf of Rurban Estates Limited.

See attachments for full submission comprising:
- Homes England - Draft Reps R18 plan and Hodson's Mill Robertsbridge (which also contains Appendices A and B);
- Appendix C - Landscape Statement; and
- Appendix D - Site Boundary

The submission contains general comments on the Local Plan and HELAA sites SAL0003 and SAL0024, as well as answers to specific questions as set out in the Local Plan.

Please see the attached full submission from the Home Builders Federation.

See attached document for the representation.

See attachment for the full representation.

The full submission comprises of:
- DHA Response to RDC Reg 18 Draft Local Plan; and
- Site Location Plan

Please see attachment

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

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

Q9: Agreed a good Policy

Q11: Agreed a good Policy

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

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

Q25: Agreed a good Policy

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

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

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

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

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

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

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

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

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

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

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

Q84: Agreed a good Policy.

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

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

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

Q109: Agreed a good Policy.

Q112: Agreed a good Policy.

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

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

Q125: Agreed a good Policy.

Q131: I welcome further work on this need.

Q133: Agreed a good Policy.

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

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

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

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

Q178: Agreed a good Policy.

Q180: Agreed a good Policy.

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

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

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

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

Please see attached letter with representations on the Regulation 18 consultation. The representation includes general comments in addition to responses to a number of questions raised within the Emerging Local Plan.

Please see attached full representation on the draft Local Plan in relation to HELAA site ICK0017.

Representation by Stantec on behalf of Welbeck Strategic Land III Limited in support of Land East of Waites Lane, Fairlight Cove - HELAA site ID FAI0001.

Submission also responds to questions 59, 60, 61, 76, 27 and 191 in the Regulation 18 draft Local Plan.

Please see attached submission for full comments.

See attached documents which comprise the submission for the Regulation 18 Local Plan and HELAA site ICK0002: Seven Acres, Watermill Lane, Icklesham.

Please see attached representations document.

Please also see StoryMap detailing Gladman's portfolio of using the following address: https://storymaps.arcgis.com/collections/315747d6c3ef40069b1b886958aaedaf