Reference to development for RR/2022/1765/P

I am writing to strongly object to the proposed development of land at Almonry Farm, North Trade Road. Site ID BAT0014, I have examined the plans and I know the location well. I wish to object strongly to the development of houses in this location for the following reasons:

1.The area proposed for development lies within the High Weald AONB and any planned housing would cause significant damage to the immense biodiversity of the area which comprises of ancient woodland, ancient and veteran trees, meadows, ancient hedgerows/boundaries and habitats for endangered plants, fungi, birds, bats, reptiles and mammals. The infrastructure required to build 1000 houses (sewers, piping systems, cables, foundations etc) would decimate the ecology of the site and endanger wildlife thus not fulfilling the National Policy of affording AONB sites ‘highest status of protection.’

2. 3.63 The NPPF specifically states that the scale and extent of development within an AONB should be limited and advises that planning applications for major development should be refused other than in exceptional circumstances. (p.60) Rother draft local plan 2020-40. There are no ‘exceptional circumstances’ of housing need in Battle. Several houses at Lillybank (most recent development) are unsold and now reduced in price. There are many family-sized homes currently for sale in Battle that have been advertised for 6 months + Added to this is the current development of the Blackfriars site which is for 200 houses. The town is not built to uphold the footfall with support from surrounding educational premises such as schools, nurseries, even doctors, dentist and car parking.

3. Urban Sprawl. A poor decision on a planning application on this site could set a precedent for a pattern of development that could lead to massive expansion and exploitation of the site as it is over 18 hectares leading to urban sprawl.

4. Battle is a hugely important market town, home to one of the UK’s most important historical sites and brings thousands of visitors every year. Building over historic land would change the look and feel of Battle from a small town to a conurbation and a less attractive place to visit. This would have a direct impact on local businesses and the economy.

5. The site comprises of Grade A, viable farmland. It is currently used for livestock, haylage and hay. Building over this site would rob the opportunity of this area ever being farmed again thus demeaning food security.

6. Historic site decimated. The fields of Almonry farm were formerly part of Battle Abbey and are of historical importance. The fields, ancient woodland and hedgerows provide a green buffer between the town and Battle Abbey

7. Road. Battle High Street and North Trade Road are heavily congested and at times Battle High Street is gridlocked. North Trade Road and Battle Highstreet are ancient thoroughfares with many listed and Historically significant buildings. The traffic generated by extra houses will put enormous pressure on the already strained road network and old buildings - unless the high street had a full resurfacing and removal of high street car parking to the neighbouring car park for multi storey to make it a clear way for traffic.
8. Infrastructure. As mentioned above - What are the plans for extra school places GP surgeries and dentists?
9. Access via Tollgates residential area is unworkable. The planned access road would put immense pressure on the small, residential road into Tollgates (an area which has just recovered from expansion). There is no junction capacity.

10. The proposed access road will bisect 2 buildings of historical importance via a residential garden. Almonry Farmhouse (a Grade 2 listed building) and Almonry Oast House. A substantial amount of mature trees and shrubs would have to be removed in order to build an access road.

11. There is significant surface water flooding across several areas of the proposed site, underground springs and streams. Any removal of woodland/shrubs will have a negative impact on the water table and clay soil with the potential to upheave homes.

12. The planned road would bisect a public footpath which is currently heavily utilised by the public and most especially the pupils of Claverham School and Battle Langton School as a safe route to school. A road bisecting the footpath would compromise the safety and independence of children travelling to and from school.

13. After the reneged promises of the developers at the current Blackfriars site and the inability of RDC to compel the developers to make good their promise of affordable housing and social housing it is clear there is absolutely NO appetite for any further large-scale housing developments in Battle.

https://www.rother.gov.uk/housing/housing-development/rother-dc-housing-company-makes-significant-progress-to-deliver-its-first-housing-scheme

14. The people of Battle are a concerned populace that believes their heritage and green future are at stake. The main tenet of the RDC draft development plan is ‘Green to the core.’
‘Green to the Core emphasises the need to consider the impact of our planning decisions on the climate emergency, biodiversity crisis and the High Weald National Landscape.’ Rother District Council’s draft Local Plan (2020 – 40)

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