See attachment for response.

Catsfield site allocation CAT0001 (HELAA Identified) has recently had an outline planning application submitted and withdrawn before it was refused (Application RR/2019/257/P). Previous applications for much smaller developments on this site have also been rejected (Applications A/70/522 for one dwelling and A/70/526 for 3 dwellings). A FOI request made to RDC has revealed the planning officers final report recommending refusal for the most recent application of the proposed 35 dwellings (as identified and proposed by the HELAA) and other associated documentation, which showed some of the reasons for refusal. These should be reviewed and considered before finalising this future Local Plan and HELAA as they show that; - The site is actually not appropriate for development (it contravenes National and RDC's own policies). - Development of the site would cause a significant health, safety and wellbeing risks to local residents and the local community due to it being in a 'red zone' for flood risk, cause over population and cripple the already inadequate local infrastructure (highways, health provision, poor utility quality and provision, lack of education facilities in the village and surrounding area, etc). - 1.6 hectares is not adequate for a development of this size and does not meet planning guidance for density of development in a rural village location. - Development of the site would destroy the habitat of protected and endangered wildlife which currently resides there (as documented in the ecology report submitted to RDC planning dept). This site falls within the 'red zone' for Great Crested Newts and is home to a large number of protected and endangered species of wildlife, flora and fauna (inc bats, badgers, hazel dormice, etc). All of which are fully protected under the Wildlife and Countryside Act 1981 and The Conservation of Habitats and Species Regulations 2017, also making them European Protected Species. - The site falls within the High Weald AONB, which according to policy, can only be developed in 'exceptional circumstances'. This site and proposed number of dwellings does not fall within this caveat. The number of dwellings proposed for this site (35 dwellings) is classified in the planning documents as a 'Major development', which is not permitted within the HWAONB. - The site is subject to a blanket Tree Protection Order (TPO) and is adjacent to properties with listed status. These would all be severely impacted by any kind of development/construction on this site. - The northeastern boundary of the site falls within the Pevensey levels Hydrological Catchment and RAMSAR Area. - The Delegated Officer Report - Assessment of Case, should be referred to before finalising this draft Local Plan/HELAA and before any further consideration of the continued allocation of site CAT0001. The report's conclusion (and reasons for refusal of outline planning) states; - The proposal would cause significant harm to the local landscape character of the AONB and the rural settings of the nearby listed buildings. - The submitted information concerning the impact of the proposal on ecology and biodiversity and the proposed biodiversity mitigation and enhancement measures are considered to be inadequate. - The proposed development of 35 dwellings by reason of its layout and scale and disregard to landscape features such as trees and road hedgerows would be out of character with the site and surrounding pattern of development and would materially harm the intrinsic character and appearance of the locality and scenic beauty of the High Weald National Landscape (Area of Outstanding Natural Beauty). As such, the proposal is contrary to policies OSS4, EN1 and EN3 of the Rother Local Plan Core Strategy (2014), policies DIM2, DEN1 and DEN2 of the Rother Development and Site Allocations Local Plan (2019), paragraphs 135, 136 and 182 of the National Planning Policy Framework and, Objectives S2, S3 and FH2 of the High Weald Management Plan. - It has not been demonstrated that the proposal complies with policy EN5 of the Rother Local Plan Core Strategy (2014), policy DEN4 of the Rother Development and Site Allocations Local Plan (2019) and, paragraphs 180 and 186 of the National Planning Policy Framework. - The proposed development (of 35 dwellings) due to inadequate drainage strategy and lack of flood risk management strategy for high groundwater could increase risk of flooding within site and elsewhere, contrary to policies EN6 and EN7 of the Rother Local Plan Core Strategy (2014) and paragraphs 173 and 175 of the National Planning Policy Framework. The final paragraph states; - NATIONAL PLANNING POLICY FRAMEWORK: In accordance with paragraph 38 of the National Planning Policy Framework the Council works in a positive and pro-active way with Applicants and looks for solutions to enable the grant of planning permission. However, in this case the proposal is not sustainable development for the reasons set out and the Council was unable to identify a way of securing a development that improves the economic, social and environmental conditions of the area. Planning applications for other sites in Catsfield with the same features as this site (e.g. The Brooks) have been refused and the site deemed as unsuitable in the HELAA. This site should be assessed in the same way, deemed unsuitable for development for the same reasons and subsequently removed from the HELAA as an allocated site for development, as should site CAT0016 for the same reasons.

Please see:

- Mr John Lovering - Rother Draft Local Plan 2020 (comments of draft Local Plan)
- Land off Uckham Lane - Location Plan
- Landscape Feasability Study
- Transport Report
- Access Plan

Live Well Locally

The Live Well Locally concept will be particularly difficult for residents within Icklesham Parish as none of the four settlements have a doctors surgery, the closest ones being in Rye and Hastings. There is also two primary schools throughout the Parish that serve all four settlements. These schools (Winchelsea CEP and Icklesham CEP) are very small schools and would not be able to take an influx of extra children. Two of the wards have small village shops and one has a Co-Op. None of these shops would be suitable to do a weekly food shop. Icklesham does not have a shop at all.

There is a bus service in each of the four settlements however the service is infrequent and at times unreliable.

Policy GTC2

Icklesham Parish Council are concerned about what this policy would mean for historic and listed buildings. IPC note that the polilcy states that HER1 would apply but it would be interesting to note which policy would carry more weight when deciding on a planning application.

Policy HER1

Please refer to note above concerning GTC2.

Policy DEV3

IPC would like to know if Net Zero developments would be considered outside of development boundaries.

Policy LWL3

Both Rye Harbour and Icklesham have potential sites identified for development. Both Rye Harbour and Icklesham have a bus service although the service is only once an hour during the week and once every two hours on a Saturday. There is no bus service at all on a Sunday in Rye Harbour. If new development is to go ahead, could Rother consult with Stagecoach about increasing the number of bus journeys?

Rye Harbour has good cycle paths however cycling in and out of Icklesham means cycling on the road with fast traffic both in and out of the village.


Policy HOU6

Planning Enforcement Team very over stretched and relying on Parish Councils and residents to flag any issues. Issues with HMOs may not be obvious to Councillors or other residents. Will the Enforcement Team realistically have time to Enforce such planning conditions?

Policy HOU17

Would these sort of developments be considered in Winchelsea Beach? IPC are concerned about the potential extra kitches and bathrooms and the strain this would cause to an already overloaded sewer system and ongoing surface water flooding and sewerage issues.

Policy ECO6

The Parish Council would like to know if this would also be the case for caravan parks extending their opening times during winter months? There have been instances recently where extension to opening times have been allowed despite objections raised by residents and the Parish Couoncil and evidence of extreme surface water flooding on specific sites being provided to the Planning Team and Planning Committee.

Policy ENV1

The Parish Council would like to know if anything can be done to ensure that any contributions are actually spent on improving local infrastructure as we know that the sewer networks in both Icklesham and Winchelsea Beach are in desperate need of updating. The Parish Council feel that this is a necessary step before any further development takes place in either ward.


Potential Sites Identified in Icklesham

ICK0041 & ICK0017

As previously explained, Icklesham's sewer network is in need of an upgrade and the Parish Council feel that this should take place before any further development takes place. The Parish Clerk has an email from Southern Water which indicates that they are aware that the Water Treatment Works (WTW) in Icklesham gets overloaded which causes it to back up the line. The Clerk has asked Southern Water whether there are any plans to update the Water Treatment Works and they have advised there is no planned investment prior to April 2025 at Icklesham WTW. However, there is planned investment in AMP8 (April 2025 to 2030) to the monitoring of flows entering the WTW. Certainty of this investment is yet to be concluded by OFWAT in the PR24 determination for AMP8.


Potential Site identified in Rye Harbour

ICK0046

Parish Council have previously raised concerns about the local infrastructure not being able to cope with this level of development. Particularly the roads as Rye Harbour is effectively a cul de sac. Harbour Road already gets heavily congested, particularly in the summer months when visitors attend to visit the Discovery Centre and the Nature Reserve. ICK0046 has been identified as suitable for 40 dwellings which is a large development for Rye Harbour which is very small in comparison.

This would be supported, if the current development boundaries for villages and towns were known so that residents would know definitely what they were. The concern is that these boundaries will be manipulated and changed to fit the needs of development. This happened with the Robertsbridge Neighbourhood plan where a boundary was increased to include a whole site. A map showing the boundaries should be included as part of this document.

See attached.