Comment

Representation ID: 25521

Received: 17/07/2024

Respondent: Wild About Burwash

Please see attached comments.

Comment

Representation ID: 25799

Received: 22/07/2024

Respondent: Mrs Jacqueline Himves

Objection to any planning permission being granted on land adjacent to Coneyburrow Lane/Barnhorn Road.
An area grossly over developed with current construction taking place next to Ashridge N/H,2 properties in Sandhurst Lane, Beech Farm and stage 2/3 of Rosewood Park.
The site is unsuitable as there is a 20% gradient of the field.
One must consider sewage and overflow disposal to be an enormous concern should an estate be built.
Barnhorn Road does not have the infrastructure to cope with further development.
This is an ancient meadow and is on the boundary of an SSSI/RAMSAR site of National historic and interest.
The land was rejected by RDC in 2022 as being unsuitable as building land.
Further more there are many protected species of flora and fauna that will be affected and disturbed should this land be used as building land.

Comment

Representation ID: 25810

Received: 22/07/2024

Respondent: Mr Barry Hinves

I object to further development in west Bexhill and particularly to further development on the land bordered by Coneyborough Lane and Barnhorn Road. My objection to a previous planning request is logged in Rother District Council files which can be available to you.
Building is occurring next to Ashridge Court Nursing home, and to the immediate North of my property and a building request to the east received in the last 2 years.
The sword of Damocles hangs over the Northeye site!
The inadequacy of the sewage disposal on Barnhorn Road and the A259 vehicle pollution, together with the lack of new local facilities make further building impracticable. The value of the Pevensey Levels Ramsar and SSSI sites which border Coneyborough Lane have been ignored as identified by SPINDAG
We who purchased property in West Bexhill have been heavily compromised by new developments and would wish this to stop please.

Comment

Representation ID: 26497

Received: 22/07/2024

Respondent: Mr Julian Kenny

There doesn’t seem to be any rationale for the choices of potential sites in the HELAA. If Rother is truly green to the core it should give clear justifications for the choice of each site. The classification of a major development is not transparent, obviously a major development in Bexhill or Battle (10 houses or more?) would be remarkably different to a major development in a village, which should be dependent on the size of the village and a single house in a remote greenfield area could be considered as a major development.

I would also like to know what the situation is with the housing along the Bexhill link road, It was my understanding that applications for a large number of houses were granted along the Bexhill link road. It would make much more sense to ensure that these were built rather than creating another new road (around Flimwell and Hurst Green) where the same situation is likely to arise. Please either let me know or include details in the future HELAA.

Comment

Representation ID: 26664

Received: 29/07/2024

Respondent: Stephen Nicholls

With particular focus on Q64 my main concern lies with the fact that the HELAA has not considered all
development, but sets a bar at 5 houses or above in it's assessment of suitability. This is too high a
level and damage will be done at much lower levels of development. I have concerns that a more
distributed approach utilising these already deemed unsuitable locations will be suggested for smaller
scale development that sits below the HELAA level. This would be disastrous, as many of the sites are
within the HWNL and the disruption caused and destruction of natural habitats, would, to my mind
result in greater environmental impact and damage than development at a single larger site in the
centre of the village that sits outside of the HWNL.

Comment

Representation ID: 26705

Received: 23/07/2024

Respondent: Bexhill Old Town Preservation Society

We did not readily find a reference to Conservation Areas as part of any considerations applied in planning or decision making although these are mentioned in the Supporting Evidence Base Documents (HELAA Part 2).

Comment

Representation ID: 26817

Received: 31/07/2024

Respondent: Northern Parishes Group

HELAA assessment
43) Like allocation generally, the group appreciates that the structure of HELAA has been laid down by others and the framework cannot at this stage be disturbed. However, the impact of it will feed through to bad planning grants in the decades to follow. One problem that the group cannot deal with is that Rother District Council does not have the resources to carefully analyse every site put forward. It is noted that the neighbourhood plans that make housing allocation are mentioned, but the Burwash neighbourhood plan, which with an inspector's approval, made no housing allocation. This decision was not only approved by Rother District Council, but it was also approved by the planning court after a three-day hearing.
44) The group was very unhappy about the prominence that was given to potential sites. Many of those listed as a potential sites are in fact on examination wholly unsuitable. However, listing them as potential sites gives the developer the impression that if he or she waits long enough it will become a suitable place for development. This introduces planning blight which is wholly contrary to most of the principles that Rother District Council stands for.

45) Para 1.7 in the HELAA tries to minimise the impact on planning decisions of this document. Unfortunately, whatever the authors of this document say, developers will use this document to promote their individual sites because the site is a potential site. One way of dealing with this problem is to amalgamate this section and the rejected section.

Comment

Representation ID: 27337

Received: 22/07/2024

Respondent: Ewhurst Parish Council

EPC will consider any applications for development on the potential development sites
(residential and business) identified in the HELAA within the Parish of Ewhurst on their merits
at the time of submission. However, it is strongly of the opinion that, in respect of proposed
residential development:
1 Adequate and accessible infrastructure should exist – or be put in place before, or shortly
after, developments are completed.
2 Size, type, location, affordability and tenure mix should reflect local (at parish level) need.
3 (Where applicable) Size, type, location and design should cause no harm to the High Weald
National Landscape.

Comment

Representation ID: 27372

Received: 22/07/2024

Respondent: High Weald AONB Unit

HELAA
We will respond separately to the draft Housing and Economic Land Availability Assessment (HELAA)
in the near future, in particular those sites within, or affecting the setting of the High Waeld AONB, to
help inform the consideration of potential sites in advance of the Local Plan Reg 19 version.
In general in this regard, we would highlight that we firmly consider that site specific allocation
policies (including site specific requirements, including maps/plans assessing the sites and setting
guiding principles, and references for the need for the layout and design approach to be based on the
HW Housing Design Guide) should be provided within the Local Plan Reg 19 version for any sites
within or affecting the setting of the High Weald National Landscape. This should help to ensure that
such development is managed and coordinated within each location, and to ensure that clear and
realistic expectations for each site are set, with regard to the local plan general polices, the High
Weald AONB Management Plan, and the Council’s duty under section 85 of the CRoW Act.
We would highlight at this stage that any site allocations proposed for grassland sites should also be
subject to grassland surveys, and if found to be unimproved grassland/species rich grassland, these
should not continue to be allocated for development in the Reg 19 version, since this is an important
habitat type within the High Weald AONB, and an important part of its landscape character and
natural beauty.
The High Weald Joint Advisory Committee is a partnership between: East Sussex, West Sussex, Kent and Surrey County Councils; Horsham, Mid Sussex,
Tandridge, Sevenoaks, Wealden and Rother District Councils; Tunbridge Wells, Hastings, Ashford, Crawley and Tonbridge & Malling Borough Councils;
Defra; and organisations representing farming, forestry, community, business and recreation interests.
In addition to the above comments, we would also draw to your attention that Section 245 of the
Levelling-Up and Regeneration Act 2023, which came into effect on 26th December 2023, has
introduced important changes to legislation around protected landscapes. In particular, with regard
to Areas of Outstanding Natural Beauty, Section 245 (5) to (10) of the Act amends the Countryside
and Rights of Way CRoW) Act in a number of ways.
Most significantly, 245 (6)(a) amends section 85 of the CRoW Act regarding the general duties of
public bodies etc by inserting the following text:
“In exercising or performing any functions in relation to, or so as to affect, land in an area of
outstanding natural beauty in England, a relevant authority other than a devolved Welsh
authority must seek to further the purpose of conserving and enhancing the natural beauty of
the area of outstanding natural beauty.” [my underlining]
This is considered to represent a strengthening of the previous section 85 duty, which set out that “a
relevant authority shall have regard to the purpose….” [my underlining]
It is therefore important that this new duty is reflected in the content of the Local Plan, including in
the evaluation of proposed site allocations.

Comment

Representation ID: 27461

Received: 22/07/2024

Respondent: Home Builders Federation

Site assessments:
45. The Council will need to ensure that its assessment as to the constraints on sites excluded from the plan are consistent with national policy. In particular the council must not consider the strategic gap between Bexhill and Hastings to be a constraint on development on a par with the AONB or any other footnote 7 constraints. As the Council will be aware the NPPF does not mention strategic gaps and provides no guidance on their use. Whilst such local designations have been included in many local plans it is important to ensure that when preparing a new plan and considering new sites, strategic gaps are not used as a justification for not allocating a site or for the restriction of development as a whole within Rother.

46. It will also be vital that the council seeks to maximise development on each site it does allocate give the significant shortfall between housing needs and supply. The Council should look to ensure that all land within submitted sites that are considered suitable for development are allocated for development.

Comment

Representation ID: 27669

Received: 21/07/2024

Respondent: Mr Michael Plowman

Comment:
The HELAA is for the Rother District Local Plan (RDLP) 2020 - 2040, yet the Draft Version HELAA is only now out for consultation April - July 2024.

Q1 - The HELAA informs the Rother District Local Plan (RDLP), why isn't consultation with the public undertaken prior to the RDLP?

Q2 - Will the RDLP be published as 2025 - 2040 to incorporate the outcome of the HELAA?

Q3 - During the period of 2020 - 2025 there may have been sites approved that were not included in the previous Development and Site Allocations Local Plan (DaSALP) adopted in 2019, which had been subject to public consultation and accepted by a Planning Inspector. There has been a DaSALP since 2019 why was it not being used to steer developers to the sites identified by Rother District Council as suitable for development.

Comment

Representation ID: 27789

Received: 23/07/2024

Respondent: Salehurst & Robertsbridge Parish Council

Why is the HELAA being consulted on at the same time as the local plan? We would like explanations as to how the HELAA sites have been identified and the implications for our own Local Neighbourhood Development Plan (Salehurst & Robertsbridge Neighbourhood Development Plan, in force from July 2018). Please note comments submitted separately by Stephen Hardy who led our Neighbourhood Plan Group. Most importantly, could additional sites not in our neighbourhood plan be added to the Local Plan when we have been advised by Rother Planning Department not to review our neighbourhood plan until the local plan is agreed?

Comment

Representation ID: 28138

Received: 22/07/2024

Respondent: East Sussex County Council

HELAA Part 1 report, Figure 3: Approach to assessing constraints, p28-30; Archaeological Notification Areas (ANAs) are regarded as non-designated heritage assets it would be appropriate to also include provision for consultation with the Council’s Archaeological Advisor here.

Comment

Representation ID: 28266

Received: 23/07/2024

Respondent: Environment Agency

Development sites:

We note that numerous development sites have been included within the Local Plan for further future development and that the DRAFT Housing and Economic Land Availability Assessment (HELAA) is to be consulted on and included at a later date.

We would wish to be included in this consultation to identify sites that may require further attention in the future.

It is important that a sequential test, based on the SFRA and assessing all forms of flooding is undertaken and that the functional floodplain is identified to avoid allocating sites in areas where development should not be permitted.

Please see attached submission document for full representation text on Development Sites.