Please see attached representation, existing and proposed sites plans.

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.

Please see attached the full submission regarding Land at Breadsell Farm covering background information to the site as well as detailed responses to questions 27, 28, 32, 51, 52, 54, 55, 60, 61, 77 and 90.

Please see attached submission.

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.

Full submission attached.

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

Please see attached full representation

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 accept this response to your consultation on the draft local plan for Rother 2020-2040 as your online consultation webpage is difficult to navigate and I became totally lost in the bureaucratic jargon and only managed to reach page 260 before burn-out.

The Draft itself is difficult to decipher what is actually being said, requires much cross referencing with other lengthy, confusing documents and I have had to deal with this draft in a ‘bite-size’ manageable way so may well miss important points, which I hope others will pick up on.

In short, the summary of many hours of reading:
Housing should be confined to brown/grey field sites, in urban surroundings that can cope with the demands of contemporary living, before greenfield sites (especially the HWNL) are even considered.
The Local Plan does not set any limits on anything so cannot possibly have any value as a plan for sustainable development. Development with no limits is unsustainable.
Please provide a map of the development boundary for Catsfield. (For example page 224, DaSA adopted 2019). Maps like this provide clarity for the lay-person rather than struggling through huge documents such as the Draft Local Plan, the HELAA reports, HEDNA etc. but unable to locate any meaningful maps.


RESPONSE TO QUESTIONS:

Q2. What are your views on proposed twin Overall Priorities to be ‘Green to the Core’ and ‘Live Well Locally’?

I have to disagree that RDCs vision is achievable. On the face of it the vision appears to indicate a respect for the environment and the rural communities within, but simply introducing the word ‘green’ does not equal sustainability and, likewise, the word ‘well’ is simply subjective. Therefore, rather than slogans which are open to interpretation or challenge by developers with their eye on today’s profit not tomorrow’s generations, perhaps something a little less open to subjective interpretation would be better. Ie. Today’s priority is tomorrow’s environment. It is clear that we need to protect our environment, both natural and built, because we won’t get a second chance tomorrow. The High Weald National Landscape must be protected as this will be our legacy to following generations – this is sustainability. A climate emergency and protecting our National Landscape is in absolute contrast to the aims of profit-driven developers and speculators, so the question is, how will RDC make developers/speculators adhere to these twin priorities and share their vision?
Regarding Catsfield where I live: The proposed number and design of dwellings on CAT0001 and CAT0016 sites in the HELAA report is really too large for the rural character of the village to subsume into the settlement and should be decreased. Large housing estates will urbanise the rural character - already seen in Ninfield in Wealden district. Therefore, such large housing estates are neither ‘green to the core’ nor beneficial to residents.
Why has Catsfield been singled out to provide 60 new dwellings when other villages have a nil target? How is this figure determined? Is the development boundary for Catsfield being altered without resident’s knowledge?
Q3. What are your views on the key issues (listed at paragraph 2.13) that have been identified and is there anything significant missing?

Simply carving up the country-side will not make houses affordable. Brown/grey field sites must be used before green spaces.
For instance, BEX008 is earmarked for industrial use. Why isn’t the site earmarked for residential buildings if there is a national housing crisis? The infrastructure is already in place.
The site MOU0012 is a vacant industrial site - why is the landowner not incentivised to free up this site? Is he holding out for residential planning?
I understand RDC has a partnership with Hastings. Have they audited empty brownfield sites and properties together, such as the old Post Office, that could be refurbished for residential dwellings?
What is significantly missing is a clear brown/greyfield register for the area if RDC is to conserve its special landscapes such a the HHWNL. Such a register should be in the public domain.

Q22. What are your views on the Council’s proposed policy for Biodiversity Net Gain?

Conserving special landscapes like the HW National Landscape will not be achieved by building more houses over it. By definition house building cannot leave the natural environment in a measurably better state than it was beforehand. BNG can only be achieved on brown/greyfield sites. Brownfield/grey sites should be used first and RDC should make this clear in the Local Plan. Please provide the brownfield maps to the public.

Q25. What are your views on the Council’s proposed policy for the High Weald National Landscape? Q26. Are there any alternatives or additional points the Council should be considering.

Hopefully, these policies will protect the HWNL. However, for the policy to be sustainable there must be clear limits and boundaries and there is not! Therefore, the policy has little value without limits.

Q27. What are your views on the Council’s proposed policy on compact development?

I am unsure what ‘compact development’ means in practice. I assume it means making the best use of infrastructure by building in those areas, predominantly urban, where infrastructure is already in place, which makes sense. In rural villages, like Catsfield, infrastructure is poor. Public transport is non-existent in Catsfield and residents rely on private vehicles to get to work, to shop etc. usually over poorly maintained roads and lanes. No mobile signal is available in the village and no fibre WiFi is available. Drains overflow, water pressure is low or nonexistent and the village regularly suffers from power cuts. This is all down to poor, unmaintained infrastructure but I made the choice not to live in an urban environment with its good infrastructure but enjoy our wonderful countryside of Sussex.
Again, housing should be confined to brown/grey field sites, in urban surroundings that can cope with the demands of contemporary living and if that is what ‘compact development’ means then I support that.

Q28. What are your views on the area types and densities proposed as a key driver to Live Well Locally?

Please advise where the current map of the development boundary around Catsfield can be found? 25-45 dwellings per hectare makes little sense to ordinary residents - please clarify before I can comment.

Q51. What are your views on the Council’s preferred spatial development options? Q52. Do you have any comments on the merits of the alternative Spatial Development Options, that do not form part of the preferred development options – as explained in the background paper? Q53. Are there any other development options that the Council should consider as part of its Local Plan?

These concepts are confusing to the ordinary resident and need to be explained in clear English. I cannot comment on something that is so confusing.

Q62. What are your views on the vision for Battle and surrounding settlements?

RDC’s target of 60 houses for the small village of Catsfield does not correspond with Rother’s vision quoted from Page 140 - 'Sensitive small-scale development will be delivered in villages surrounding Battle, at densities consistent with the surrounding area, where it is sustainable and does not negatively impact the setting of the High Weald NL.’
Needs a total rethink regarding the number of dwellings. However, Page 145 - para 5.60/61 introduces the idea that the target of 60 houses for Catsfield is purely hypothetical!

Q77. Do you agree with the principal identified by the Council of achieving a stepped housing delivery with greater levels of delivery planned for later in the plan period?
How will RDC incentivise developers to adhere to this principal? Without strict limits this principal is unachievable! Page 177 identifies a problem with land-banking by developers - 'there have been significant delays in the build out of sites.’ This practise needs to be penalised as it affects the price mechanism of houses thus pushing up prices. How is RDC tackling the issue of land-banking?

Q82. What are your views on the Council’s approach to development boundaries?
Page 186, para 5.119 - 'This Local Plan will review each settlement’s boundary, especially in relation to potential allocation sites.’ How can residents possibly comment on something they have not seen? Please produce the Development Boundary map for Catsfield so I can make an informed comment.

Q103. Do you feel that this policy is sufficient to protect open space?
No. The policies have no limits so developers will perpetually challenge them - mission creep.

Q104. What are your views on the Council's proposed policy on public rights of way?
PRoWs are a historic right and should remain. Not diverted nor ignored nor moved surreptitiously (which has been seen in Catsfield). New PRoW are always welcome!

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 representations document.

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