point 7- It is imperative that existing communities have the security of the appropriate infrastructure not being over stretched.

It should have been made crystal clear that, notwithstanding the omission of Chapter 13 at this stage, that the HELAA document IS part of the Reg. 18 Consultation and can be found in the Supporting Evidence Data where comments can be submitted.

Unfortunately the wording here ultimately suggests RDC was trying to throw residents off the scent and avoid comments being submitted on site allocations.

Chapter 13: excluding public from commenting on specific sites.

Is a regulation 18 consultation that doesn't permit public comment on the evidence base (supporting documents) going to be valid? I suggest that continuing to the published version and regulation 19 consultation while blocking public consultation at this stage is procedurally questionable.

I understand that public observations regarding the glaring contradictions between the evidence base and the plan might be embarrassing but I would've thought essential?

The Council's Local Plan emphasizes the importance of sustainable development, infrastructure, and environmental preservation. It outlines a vision prioritizing "Green to the Core" and "Live Well Locally" through policies addressing the climate emergency, biodiversity, compact development, and public transport. Additionally, it highlights the need for robust infrastructure to support growth, enhance health and wellbeing, provide affordable housing, and sustain economic development. Despite these objectives, recent planning decisions have disregarded these principles, relying on outdated plans and neglecting infrastructure and environmental impacts. Moreover, the removal of social housing undermines the original intent of these developments. I urge you to realign with the Local Plan's goals to ensure balanced, sustainable, and community-focused growth otherwise what is the point of this local plan when it is totally disregarded when planning decisions are being made.

See attached full representation

`My General comments on the plan are:
• Hard to read/follow plan: The document is not easy to use and is difficult to follow and at over 450 pages in length, is far too long and the important points can easily be overlooked.
• Does not conform to national government policy: Most of the land under RDC’s purview is green-belt, most of which, should have not be considered for either housing or traveller site development. The reasons being because of environmental reasons and the absence of the required adequate infrastructure and services provision
• Need for clear green-belt division between villages being ignored: In particular between the villages of Flimwell and Ticehurst.
I would like to also make the following Points/objections specifically relating to the unsuitability of the field referred to in the Local Plan specified as GYP0002 (on slide 10, “Identifying Sites for Gypsies, Travellers and Travelling Showpeople”) and TIC0039 (on p66, HELAA-Part 2- CHAPTER-5-NORTHERN-Compressed document), respectively.

• The field (TIC0039) has already been prevously been marked as unsuitable for a housing development , please see document; HELAA-PART 2-CHAPTER-5-NORTHERN-COMPRESSED and therefore should not now be considered suitable for a traveller’s site encampment (GYP0002) for the reasons given in that judgment by RDC but I would also like to raise the following additional points:
• The land, as well as the ancient woodland that surrounds it, is home to home to many speices of native wildlife and rare plants. The area is currently home to barn owls, kestrels, woodpeckers, falcons, buzzards and other wild birds and also some small animals such as shrews and hedgehogs.

• The field is prone to flooding and becomes very waterlogged and boggy at the bottom, every winter.

• The field is at a steep incline.
  The access points to the field would be dangerous, as it joins a 40mph road that is situated on a corner, on a hill, and would be dangerous not  only for those emerging from the site but also to existing road users.
• The private road that provides access to Ketley Wood Lodge is too narrow to sustain large traveller vehicles.

• There is a lack of basic amenities to support a travelling community in Flimwell. Apart from the artisan smokery shop and an ice parlor, there are no food shops within a mile radis. There is also no Doctor’s surgeries, dentists, chemists, post offices and garages for fuel in Flimwell. And with no footpaths, the only way to access these services safely is via car as also public transport services are at a minimal in the area. A primary school is also only assesable via road in the same manor.
•          It is in an area that is mimalising light pollution with litte or no street lighting
• Difficult/impossible to safeguard the protection of the ancient woodland from, pollution, fires and general damage and this would have a catastrophic effect upon resident wildlife.

I understand and empathise that accommodation has to be made for new housing and traveller sites in Rother, but please focus on the brown field areas first where the infrustraure is in place and only consider areas of green belt in case of urgent need.

Please see attachment

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!

The Kent County Council (KCC) Public Rights of Way and Access Service ('the Service') has been made aware of the Rother Draft Local Plan 2020 - 2040 ('the Plan') at its Regulation 18 consultation stage. As a neighbouring authority, the Service has reviewed the Plan and offers comments as below.
As a general statement, the Service is keen to ensure its interests are represented with respect to its statutory duty to protect and improve Public Rights of Way (PROW) in the county. The Service is committed to working in partnership with local and neighbouring authorities, councils, and others to achieve the aims contained within the KCC Rights of Way Improvement Plan (ROWIP) and the KCC 'Framing Kent's Future' strategy for 2022-2026. KCC intends for people to enjoy, amongst others, a high quality of life with opportunities for an active and healthy lifestyle, improved environments for people and wildlife, and the availability of sustainable transport choices.
Rother District lies in East Sussex and borders the Kent districts of Ashford, Folkestone and Hythe, and Tunbridge Wells. Although outside of Kent, it is felt appropriate to offer comments of a general and informative nature on this Plan given the high likelihood of cross-boundary interactions in the event sites in close proximity to Kent are in future proposed and developed, which could impact on and hopefully enhance access for both Rother District and Kent residents.
1.
The Service notes the Plan does not presently propose site allocations, preferring to first consult on the development strategy and draft Housing and Employment Land Availability Assessment. When sites come forward in due course, the Service will expect to be consulted where access need for future site residents or other occupants could impact existing access facilities in Kent.
2.
The Service notes the Plan's Vision (p19) gives a high profile to 'walking, cycling and public transport' to access facilities and services, and to the need for 'enhanced health and wellbeing'. These statements are welcomed as they provide considerable scope for the PROW networks of both East Sussex and Kent for positive partnership working to Rother District's future.
3.
Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) (p73). It is proposed future major residential proposals will need to ensure Active Travel Infrastructure either by infrastructure delivery or a financial contribution, the timing of which is significant and requires mention, as infrastructure should be provided prior to occupation.
4.
Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) (p73). Recognition of the King Charles III England Coast Path National Trail is welcomed, not least for the wellbeing benefits it delivers to residents and visitors.
5.
Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) (p73). In designing and delivering future new routes, or perhaps upgrading existing facilities, various design guidance is given. It is quite likely the ESCC PROW Service has its own guidance which, as it is the local highway authority, should be recognised; for example, the ESCC ROWIP.
6.
Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) (p73). The proposal to upgrade existing or provide new PROW could be a welcome benefit for both Rother District and Kent residents and visitors. For example, creating new bridleways around Ticehurst and Flimwell that link to the existing (Kent) bridleway network in Bedgebury Forest would not only offer local access benefits but also link to the Wealden Cycle Trail connecting Ashford and Tunbridge Wells. It is recommended any changes to the existing PROW network are undertaken in conjunction with the ESCC PROW Service and ourselves, given the legal processes involved and the need to ensure continuity of standards 'on the ground'.
7.
Vision for the Countryside (p164). The ambition for the countryside and coast to have improved access is supported. It is not specified how this is to be achieved; cross-reference to Proposed Policy LWL3: Walking, Wheeling, Cycling and Public Transport (Outside the Site) is suggested.
8.
Proposed Policy HWB1: Supporting Health and Wellbeing (p198). Recognition that access infrastructure can be a key factor in improving and maintaining communities' and individuals' health and wellbeing supports the Service's own view.
9.
Proposed Policy HWB5: Green and Blue Infrastructure (p211). PROW are generally considered an important part of Green Infrastructure, which should be given more clarity within this policy.
10.
Proposed Policy HWB6: Public Rights of Way (p215). The protection of individual PROW and the enhancement of local access networks impacted by proposed development is welcomed. Reference to 'Active Travel' could enhance understanding of this aim. One means to achieve the policy aim is to up-grade the status of Public Footpaths to Public Bridleways, so extending lawful use to cyclists, which can be achieved at comparatively small cost to road network enhancements. Rother District Council is recommended to consult with the ESCC PROW Service on this Policy.
11.
Proposed Policy INF1: Strategic Infrastructure Requirements (p223). As an adjunct to comment in point 3 above regarding the timely delivery of infrastructure so as to establish cultural change in access modes, this Policy and the requirement to deliver new infrastructure 'upfront or early in the development phasing' is welcomed. It is expected this will extend to infrastructure improvement in Kent where this is identified and agreed.
12.
Proposed Policy HOU18: Boundary Treatments and Means of Enclosure (p309). Bullet point 3 on p310 acknowledges 'public footpath or bridleway'; it would be clearer to replace with 'PROW' given a Restricted Byway or Byway Open to All Traffic could conceivably run adjacent to any site.
13.
Proposed Policy ECO10: Equestrian Developments (p351). The proposal to, ideally, site new development close to 'the bridleway system' would likely assist users' and local safety. The ESCC PROW Service should be consulted, and its comments carefully considered before finalising this Proposed Policy.
14.
Glossary (pp440-453). The Service supports the use of a comprehensive glossary, enabling readers who are not familiar with terms used within the Plan to more clearly understand the Plan's ambitions and means. For this reason the Service considers the Glossary should be revised as follows:
A.
'Active Travel': the definition offered within the Plan differs to that adopted by KCC - this can be found at https://www.kent.gov.uk/about-the-council/strategies-and-policies/service-specific-policies/roads-paths-and-transport-policies/active-travel-strategy; the definition should therefore be confirmed with ESCC.
B.
'Infrastructure': this acknowledges 'footpaths'; however, use of the broader term 'PROW' would enhance recognition of the need for improvement across wider access infrastructure;
C.
'PROW': a definition should be included for clarity and understanding. The Service recommends 'PROW is the generic term for Public Footpaths, Public Bridleways, Restricted Byways, and Byways Open to All Traffic. Each are public highways, similar to public roads, and are for public use at any and all times unless formally closed by the relevant local highway authority.'
In closing the Service adds that any future development proposals should reference NPPF Policy (as it then exists). Presently the Service would draw attention to:
•
NPPF (December 2023) para. 96: 'to achieve healthy, inclusive and safe places', which specifically encourage social interaction, minimise crime and disorder and the fear of such, and enable and support healthy lifestyles.
•
NPPF (December 2023) para. 97: to 'plan positively for the provision and use of shared spaces... support the delivery of local strategies to improve health, social and cultural well-being...guard against the unnecessary loss of valued facilities and services...and ensure an integrated approach to considering the location of housing, economic uses and community facilities and services'.
•
NPPF (December 2023) para. 102: to be 'based on robust and up-to-date assessments of the need for open space, sport and recreation facilities ... and opportunities for new provision.'
•
NPPF (December 2023) para. 104: 'Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.'
•
NPPF (December 2023) para. 108: 'Transport issues should be considered from the earliest stages of plan-making and development proposals, so that:
...
c) opportunities to promote walking, cycling and public transport use are identified and pursued
...'
•
NPPF (December 2023) para. 110: 'Planning policies should:
...
b) be prepared with the active involvement of local highways authorities, other transport infrastructure providers and operators and neighbouring councils, so that strategies and investments for supporting sustainable transport and development patterns are aligned;
c) identify and protect, where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen transport choice and realise opportunities for large scale development;
d) provide for attractive and well-designed walking and cycling networks with supporting facilities such as secure cycle parking (drawing on Local Cycling and Walking Infrastructure Plans);
...'
•
NPPF (December 2023) para. 116: '... applications for development should:
a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;
b) address the needs of people with disabilities and reduced mobility in relation to all modes of transport;
c) create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards;
This response is made on behalf of Kent County Council Public Rights of Way and Access Service. The views expressed should be considered only as the response of the County Council in respect of public rights of way and countryside access matters relating to the Plan.
Yours sincerely
Kate Beswick
Countryside Access Improvement Plan Officer
Public Rights of Way & Access Service