Please see attached representations on the draft Local Plan titled:

- Green to the Core submission Christopher Smart

HELAA site FAI0001

- Landscape Character Submission Christopher Smart

draft Local Plan questions: Q180, Q181, Q182

The darkness of the High Weald is deeply worth protecting; better, it should be enhanced. From a human point of view , there are few places left in the UK where you can see the universe (also known as 'stars'), experience its beauty, and feel the profundity of space. Humans aside, darkness is the world's largest habitat, and light pollution from human activity has a negative, in some cases devastating, effect on biodiversity. Insects in particular suffer, and as the bedrock of the ecosystems that provide our food, that is something that urgently needs addressing. I welcome the initiative to see areas of Rother become designated Dark Skies Communities, and hope the council will support their efforts.

Maintenance of Dark Skies is essential, and conformity should be assessed on every planning application, irrespective of scale and type

Totally Agree. For wildlife, nature, heritage and astonomy dark skies must be protected.

It is very heartening to note Dark Skies are now a recognised as an integral part of the RLP. Including this important aspect is applauded.

Completely agree. Dark skies, where they still exist, must be protected. Once they are gone it is virtually impossible to restore them.

Happy with this policy

Rother seems to have made Dark Skies a consideration in the planning process which is welcomed.
Recommending that lighting design should take place at the pre-app stage where possible should go a long way to ensuring that affordable and practical ways to light buildings in line with preserving dark skies are at the forefront of the minds of architects and developers.

Pett Level has remarkable areas of dark skies, however, recent new developments have particularly invasive lighting. A policy restricting this would significantly protect and enhance the area.

I am strongly supportive of the Dark Sky policy

I will start off by commenting that it is a very detailed ambitious plan covering many aspects of life in Rother. I am not sure whether many parts of it will come to fruition due to the cost and I understand that Rother is putting aside a huge sum of money to repair our dreadful roads. The roads suffer from the amount of lorries and industrial vehicles which thunder through our towns and villages.

Due to the incompetence of the Council the Plan which should have been out on 2024 is now due in 2026.

Our local plan which was worked on for 3 years and is very detailed was supposed to take us to 2039. That has now been changed without consultation to 2028. Why?

My comments of course mainly relate to Peasmarsh where I live but I have made comments on other parts of the Plan

In section 1.9 Peasmarsh has been missed out as one of the Villages which have a Local Adopted Plan so it should state 8 Villages – not 7.

In Fig. 35 on Page 173 it does state that Peasmarsh has a Local Adopted Plan.

Our Village, Peasmarsh suffers from flooding, sewerage problems and electricity failures.

The warden assisted development in the Maltings was closed – people were relocated away and a large new development built on the site ( the only 3 storey development in Peasmarsh). The grassed area was built on and now properties in Farm Gardens below this development have flooding problems as no measure was put in place to cope with the problems caused by concreting this entire area. Also the roads were left in a poor state from all the heavy equipment and vehicles used to erect this development.

I agree with high standards for building (though no mention was made of fire safety).

The very old listed Church, at the highest point of the Village, suffered from flooding last year and this year so half of the Graves and the path were under water. Not much hope for the Village which is lower down!

No mention is made of the specific needs of children and the facilities required to enable them to do well in this area.

Farmland should be protected which will help food security and fits well with your Green to the Core and Live Well Locally emphasis in the Plan

Our farmers need all the help they can get and their produce and livestock means we can buy locally (less food and transport miles)

8.94 I agree that it is not appropriate to make provision for higher levels of care beds.

Mention was made in the Plan of Roads and Streets but none about Lanes – which you find in most Villages.

Public Rights of Way should be upheld though a proviso should be added regarding dogs being kept on leads on fields containing livestock. Again a sheep owned by our local farmer was savaged by a dog allowed to run loose.

I agree that Ancient Woodlands, SSSI’s should be protected and Dungeness which is a unique site in itself.

I agree that Habitats and Dark Skies should be protected. I hope we never have street lighting in Peasmarsh.

Brownfield sites and disused buildings should be identified and used for any new development NOT Greenfield sites

In principle I agree with ENVI – Coastal Water and Flood Risk Management and EC07.

Please see attached comments from Burwash Parish Council.

Please refer to attachment

Full representation attached

See attached

Please see attached document for the full submission from Westfield Parish Council.

See attached full representation

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?