Whilst the National Trust supports the general principles outlined within proposed Policy HER1: Heritage Management, this policy should be strengthened to ensure the appropriate consideration to the setting of heritage assets. In line with paragraph 200 of the NPPF, planning decisions need to be based on a proportionate assessment of the significance of an affected heritage asset, including how the relevant settings contribute to that significance, or allow the significance to be appreciated. Suggest policy word change to ‘Development affecting the historic built environment, including designated and non-designated assets including their setting, must…’

The Conservation Areas are extremely important and their character must be preserved with unsuitable developments being refused.

Please see attached comments from Burwash Parish Council.

Full representation attached

Please see attached comments by Historic England on the Rother draft Local Plan 2020-2040 (Regulation 18), including representations on:

Policy GTC1
Policy GTC2
Policy GTC6
Policy LWL1
Policy HER1
Policy HER2

Requirement for Development Management policies

Draft Local Plan evidence base documents

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

See attached full representation

Please see attachment

Please see full the Environment Agency's representations, please see attached submission document.

We welcome most of the draft Local Plan, although there are points of particular concern for us which we describe below.

For clarity, as there are two different versions of the Local Plan draft in circulation, the text and page numbers mentioned below relate to the ‘Cabinet version” of the Local Plan found at:

https://rother.moderngov.co.uk/documents/s9244/Appendix%20A%20-%20Rother%20Local%20Plan%202020-2040%20-%20Draft%20Regulation%2018%20Version.pdf

- Housing allocation for Hurst Green (p.148)

Unless and until the village is bypassed from the A21, we feel we should not be the subject of any more major housing developments (i.e. of more than five houses) because of the exceptionally heavy traffic we experience. For substantial parts of the day there are lorries and cars passing continuously through Hurst Green, one approximately every two seconds. That means high levels of pollution and noise; it means anyone turning into London Road often has a long wait and dangerous exit; or if they are turning from London Road into their driveway they cause significant traffic to build up behind them. All this is set to worsen when the 26 new houses at London Road West (RR/2021/2798/P) are ready. Ditto the 20 houses being built at Foundry Close (RR/2019/2194/P) and if the 28 houses proposed at London Road East (RR/2022/1526/P) are built.

New village housing should above all take account of the nature of the village. Quotas and allocations should not be made on a population basis. They should be made where the landscape, the roads and townscape make development sensible, convenient and sustainable. New village housing is only appropriate where there is walkable access to a GP or chemist (we have neither), where children living in the new houses can be walked to school on adequate pavements (ours are narrow and unsuitable for families), where the roads are relatively safe and where lorries are not always thundering past, where the village has an obvious and thriving central core and hub, where good quality shops and restaurants can be walked to, where if you’re in a car to shop or dine out on the main street you can park. There are lots of villages in East Sussex that fit this bill. Until it is bypassed Hurst Green cannot be one of them.

- Construction waste being dumped on farmland for profit (pp.39-40).

Building-waste dumping is a significant problem around the villages in the north of Rother because it is lucrative for the farmers and landowners who allow builders to do it. If Rother’s planning permission rules were changed so that new buildings could not be occupied until planners were content that waste had been disposed of correctly it would discourage landowners from allowing these waste dumping trucks onto their land. We think there is scope under the 2012 (no. 767) Town and Country Planning (Local Planning) (England) Regulations for Rother to add such planning conditions to its ‘development management policy’ under section 5, para 1 (a) (iv) of the Regulations.

- Solar panels on roofs

The Local Plan says (p.47) ‘Proposals for roof-mounted solar energy supply infrastructure will be supported and encouraged wherever possible, subject to other policies and Policy HER1 (Heritage Management)”. Policy HER1 is an admirable policy designed to protect heritage assets but it is vague and subjective. We think that the Local Plan should oppose solar panels being added to a visible roof on any listed building in the High Weald National Landscape, because they tend to compromise the character and appearance of historic buildings. We think the same should be true of any Victorian or Edwardian building within a conservation area within the HWNL (such as in central Robertsbridge or Burwash). We also think there is a case for requiring planning permission for mounting solar roof panels on a non-listed building if it is adjacent to a listed building.

- Design of new buildings

Page 80 of the Local Plan says that new development should be visually attractive, understand and respond positively to local landscape and townscape character and should “conserve, enhance, and draw inspiration from this context and character in either a traditional or contemporary style”. We do not feel this is clear or strong enough guidance for developers. We would like to see the Plan say proposed developments in the High Weald National Landscape will be refused planning permission unless they can demonstrate they have followed the High Weald Housing Design Guide. Developers should be required to identify local design features that characterise the village or landscape they are building in and show how they will adopt these features. We would also like to see the Local Plan say that in the HWNL ‘contemporary style’ buildings would only be permitted where of truly exceptional quality and where a traditional style would be manifestly unsuitable.

- Wind farms

On page 45 the Local Plan’s policy wording says that wind farms will be supported if ‘they will not result in significant adverse impacts on landscape character that cannot be satisfactorily mitigated, including the High Weald National Landscape; trees, woodland and hedgerows; agricultural land use and local heritage.” The explanatory text on p.46 says “The opportunity for the development of wind turbines within the district, is extremely limited and is not appropriate in, or within the setting of, the High Weald National Landscape.”

We would like to see this language toughened and made clearer. There can be no satisfactory mitigation of a 300ft high wind turbine in our exceptional landscape. We would like to see the policy wording rewritten as “Wind farms will not be permitted in, or adjacent to, the High Weald National Landscape because they undermine its outstanding natural beauty and historic character.”

- Solar Farms

Pages 45 and 46 of the Local Plan say that “Stand-alone ground mounted solar installations will be supported, subject to other policies, on previously developed land or where evidence of community support can be demonstrated….. Stand-alone ground mounted solar installation opportunities are limited within the district, however a policy that supports suitable schemes in appropriate sustainable locations, with community support is necessary.”

We do not share the view that there are any opportunities for solar farms in the High Weald National Landscape that would not cause visual damage to the landscape and surrounding heritage assets so we would like them ruled out altogether in the HWNL.