Site allocation FA10001 should be removed from your plan. It isn't and will never be suitable for such development. See application history and appeal refusals. It all but contravenes your own policy DEV6 Strategic Green Gap (land south of Battery Hill) But it must be realised that a 35 house connection to the sewer running down Battery Hill then along the bottom of this field will cause a direct reverse flow back up the problematic smaller sewer servicing the top of Fairlight Cove running down Lower Waites Lane. Regardless of what PR and sticking plasters project Pathfinder provide, unless the main sewer from the combination of the two in Fairlight ging to the treatment plant and the treatment plant itself is increased there will always be flooding in Fairlight Cove.
The surface water issue. The suds required for 35 houses would be almost impossible on land that already floods.

I support the Inspector's findings of the July 2022 Appeal Hearing for Wakeham's Pond Field in Fairlight, particularly concerning flooding and sewage pollution and this site should be de-allocated from the 2020 to 2040 Local Plan.

I wish to state my case for the de-allocation of housing on Pond Field in Fairlight Cove, Site ID FA10001, Site Address Land east of Waites Lane, Fairlight Cove.

The Site is Isolated from the Village
• Pond Field is totally isolated from the existing village of Fairlight. Whilst, on a map, it may look to be central to Fairlight Cove, in reality there is no access to the village closer than Wakeham’s Farm Shop.
• Pedestrian access from existing village to Pond Field, and vice versa, is particularly bad with a number of road crossings and a long walk for a potential elderly population. A car will inevitably have to be used between the existing village and the new development, needlessly raising the carbon footprint of Fairlight, where there are already parking issues.
• Any ‘affordable housing’ may be ideal for elderly people wanting to move to a village like Fairlight but is inappropriate for the elderly on Pond Field because of the isolation. The excellent village facilities for a retirement population may be just too much out of reach.

Housing on Pond Field would Create Loss
• The Loss of a beautiful section of countryside. The High Weald AONB is one of the best surviving medieval landscapes in northern Europe, we should be conserving the landscape not losing it.
• The loss of wildlife habitat and biodiversity would be particularly sad. This land has been farmed for very many years and its position is almost unique in the area. This has resulted in a stable wildlife ecosystem that would be totally destroyed by any development.
• The loss of good agricultural land most suitable for farming compared to surrounding fields used solely for grazing.
• The loss of safe pedestrian, cyclist and horse riding access along Rosemary Lane and Peter James Lane as these very narrow lanes become more congested by residents trying to avoid the inevitable bottlenecks along the C92.

Housing on Pond Field cannot happen until Foul Water Issues have been Adequately Addressed
• The sewerage system is already in difficulty, all residents are aware of the current inadequacy of the foul water & surface water system during winter and periods of heavy rain. We share the treatment works with our neighbours in Pett Level, any additional load on this service will cause more flooding & sewage contamination of surrounding areas for both the residents of Fairlight and Pett Level. Infill developments in Fairlight have already pushed the Treatment Plant in Pett Level Road to capacity.
• Any development on Pond Field would need to: (a) upgrade to pipes from Fairlight Cove to the Waste Treatment Plant; (b) upgrade the Waste Treatment Plant itself to cope with extra capacity; (c) and finally upgrade the increased outflow from the treatment plant to avoid flooding in Pett Level.
• A flood report says that overflow raw sewerage will discharge into the watercourse, and that cannot be acceptable for any new development. Southern Water is already struggling in this area.

Flooding on Pond Field is a Serious Risk
• It is not called Pond Field for nothing.
• ESCC and ES Building Control Partnership have earlier raised concerns of a flood risk.
• Any housing development on Pond Field can only increase flooding probabilities.

The Proposed Access for Pond Field is a Potential Hazard
• The single access in and out of the proposed development is onto a narrow 40mph C Class road close by not one but two blind bends.
• Pedestrians will have to cross the road at least twice to get into the current Fairlight village from the planned development.
• The lack of visibility, 40mph traffic, pedestrians crossing the road – this would be an accident waiting to happen.

Additional Housing on Pond Field Creates Concern for Roads and Traffic
• The Road to the east of Ore in particular is a C Class road – C92 and has very narrow passing places all along it. A car and a bus or large lorry can just about pass each other but when a bus or large lorry meets another similar vehicle a holdup ensues whilst one of them manages to reverse into a suitable passing place. Stagecoach have recognised this and have arranged their bus schedule so that buses do not pass each other along the C92 between Ore and Pett Level. This is the current situation that would be greatly exacerbated by a new development on Pond Field.
• The junction of C92 with the A259 in Ore Village already struggles enough that Martineau Lane is regularly used as a bypass to reach The Ridge and the A259. Martineau Lane is not designed for heavy traffic but already heavy vehicles are using it. This can only get worse with any new development the size of Pond Field.

Further Development on the Scale of Pond Field is Inappropriate for Fairlight
• Fairlight is predominantly a retirement village. Our village has an excellent community spirit, quiet with excellent facilities for a retirement population, there are few facilities here that most modern young families would require.
• We no longer have a Post Office or village store, travel to Ore or Winchelsea Beach is necessary for both.
• There are no local employment opportunities and travel towards areas of employment will require a car along narrow roads.
• The doctors’ surgery in Guestling has closed, the nearest alternative in Harold Road is full to capacity and not taking on more patients. Hastings and Rother Health Services in Rock-a-Nore or St. Leonards are now the closest surgeries.
• Whilst the daytime only hourly bus service suits the existing village population, it is entirely unsuitable for young families requiring school and employment access.
• There are no primary school places for children moving into the area, all the local schools are already oversubscribed. Without another school there are going to be some children subject to long journeys and very disappointed parents.
• ‘Affordable Housing’ may not be so affordable once the need to travel every day to schools and employment is taken into account.

Our Neighbours Have Objections Too
• There would be strong objections from Ore Village and Martineau Lane regarding any potential for increased traffic.
• There would be strong objections from Pett Level about potential flooding and sewage overflow. Remember that any of these issues occurring in Fairlight will eventually land on the doorstep of our neighbours in Pett Level.
• There would be similar concerns from Rosemary Lane and Pett Village about increased traffic into Pett due to the bottleneck of the C92 in Ore Village and the proximity of Rosemary Lane to the access to Pond Field.

And Finally
Our local MP has said there is plenty of spare land elsewhere in the District that is more
suitable for a new housing estate than Wakeham’s Pond Field.

Ref :- GUE0010
Infringement of surrounding houses i.e. views and privacy - this is detrimental to the wellbeing of the people surrounding this site. These people moved here for the peace and tranquillity and enjoyment of their gardens.

The local infrastructure is archaic - sewerage, gas and electricity are out of date.

Water run off will present problems - a certain amount will go south into the Marsham Brook catchment area which is already overloaded from Fairlight and Guestling run offs. If the run off goes North then it is only a matter of time before the Pannel catchment area has problems and that will then travel down to the Royal Military Canal and the marsh.

Parking - 12 houses means 24 cars in the near future. Pett Road cannot take any more cars parked on the roadside.
Visibility and parking - already an issue along this stretch of road.

WES0040 P53/55 Land on east side of Cottage Lane, Westfield.

This site is currently being reviewed by the Forestry Commission, their full response to planning app. RR/2022/1118/P is listed on the portal 18.01.24. and copied below:

Our Regulations Team have carried out their review of this case. We can confirm that it appears to the Forestry Commission that an offence has occurred and that we are minded to serve a Restocking Notice, and we are in contact with the owners.

The council may wish to take this into consideration, as a Restocking Notice (under section 17A of the Act) would compel the person served to restock the land with trees and maintain those trees for 10 years. Additionally, we have the power to initial a criminal investigation and potential prosecution. Failing to comply with a Restocking Notice may result in the Commission serving a section an Enforcement Notice under section 24 of the Act. This provides further time for the person served to restock the land with trees.
Non-compliance with an Enforcement Notice is an offence. Prosecution may lead to the court imposing an unlimited fine set at its discretion. Additionally, in respect of any Enforcement Notice served after 1st January 2023, the court may, in addition or instead of imposing a fine, make a Restocking Order. A Restocking Order will again require the individual concerned to restock the land with trees. Non-compliance with the Order may be held to be in contempt of court. Non-compliance with any such Order may therefore result in a custodial sentence.
In addition to any penalty set out above, such convictions may result in an application under the Proceeds of Crime Act 2002 for the confiscation of all profits made as a result of the illegal activity. The Forestry Commission would reasonably expect this to include all profit made in connection to any development of the site that would otherwise not have been possible had the original Notice been complied with.
If the local planning authority is minded to grant planning permission on land where a conditional licence or Notice is in force, they may wish to consider removing the land subject to the licence or Notice from any planning permission granted for a wider area.
The presence of a Notice or conditional felling licence may be considered by the local planning authority to be a material consideration in decision making. Local planning authorities may also wish to consider land subject to a Notice or felled under licence to be woodland, or existing trees, as the presence of the Notice or licence ensures that the land will be restocked with trees and maintained for a period of 10 years from the date of the trees being planted. This is particularly pertinent in relation to ancient woodland sites and the application of the National
Planning Policy Framework in relation to those sites, as well as Biodiversity Net Gain. We would also add that Restocking and Enforcement Notices served from 1st January 2023 are local land charges. This means that once they have been served, they will appear on the local land charges register. This register is routinely checked by conveyancers as part of the buying and selling of land. As such, the land being listed on the register will alert any prospective purchaser to any liabilities that they may be taking on should they purchase the land.
Environmental Impact Assessments
Under the Environmental Impact Assessment (Forestry) (England and Wales) Regulations 1999, as amended, some proposals involving afforestation, deforestation, forest roads or forestry quarries may require ‘stage 2’ Consent from the Forestry Commission before they can be carried out. For these project types the applicant should determine if their proposal needs Consent (referring to guidance as necessary), or approach the Forestry Commission for
a ‘stage 1’ opinion as to whether or not Consent is required.
For instance, afforestation that is a condition to a planning permission where the area of afforestation has not been explicitly specified within the planning permission. For these proposals you should advise the applicant to consult gov.uk https://www.gov.uk/guidance/environmental-impact-assessments-for-woodland as to whether they need to approach the Forestry Commission for Consent.
We hope these comments are helpful to you. If you have any further queries, please do not
hesitate to contact me further.

Taking into account the seriousness of the situation highlighted above and the large number of comments submitted on the planning portal (residents, Parish Council & Sussex Ramblers) concerning the lack of safe road and/or pedestrian connectivity to the village, I feel it would be irresponsible of the council to include this site within the Westfield North development boundary.

Live Well Locally

The Live Well Locally concept will be particularly difficult for residents within Icklesham Parish as none of the four settlements have a doctors surgery, the closest ones being in Rye and Hastings. There is also two primary schools throughout the Parish that serve all four settlements. These schools (Winchelsea CEP and Icklesham CEP) are very small schools and would not be able to take an influx of extra children. Two of the wards have small village shops and one has a Co-Op. None of these shops would be suitable to do a weekly food shop. Icklesham does not have a shop at all.

There is a bus service in each of the four settlements however the service is infrequent and at times unreliable.

Policy GTC2

Icklesham Parish Council are concerned about what this policy would mean for historic and listed buildings. IPC note that the polilcy states that HER1 would apply but it would be interesting to note which policy would carry more weight when deciding on a planning application.

Policy HER1

Please refer to note above concerning GTC2.

Policy DEV3

IPC would like to know if Net Zero developments would be considered outside of development boundaries.

Policy LWL3

Both Rye Harbour and Icklesham have potential sites identified for development. Both Rye Harbour and Icklesham have a bus service although the service is only once an hour during the week and once every two hours on a Saturday. There is no bus service at all on a Sunday in Rye Harbour. If new development is to go ahead, could Rother consult with Stagecoach about increasing the number of bus journeys?

Rye Harbour has good cycle paths however cycling in and out of Icklesham means cycling on the road with fast traffic both in and out of the village.


Policy HOU6

Planning Enforcement Team very over stretched and relying on Parish Councils and residents to flag any issues. Issues with HMOs may not be obvious to Councillors or other residents. Will the Enforcement Team realistically have time to Enforce such planning conditions?

Policy HOU17

Would these sort of developments be considered in Winchelsea Beach? IPC are concerned about the potential extra kitches and bathrooms and the strain this would cause to an already overloaded sewer system and ongoing surface water flooding and sewerage issues.

Policy ECO6

The Parish Council would like to know if this would also be the case for caravan parks extending their opening times during winter months? There have been instances recently where extension to opening times have been allowed despite objections raised by residents and the Parish Couoncil and evidence of extreme surface water flooding on specific sites being provided to the Planning Team and Planning Committee.

Policy ENV1

The Parish Council would like to know if anything can be done to ensure that any contributions are actually spent on improving local infrastructure as we know that the sewer networks in both Icklesham and Winchelsea Beach are in desperate need of updating. The Parish Council feel that this is a necessary step before any further development takes place in either ward.


Potential Sites Identified in Icklesham

ICK0041 & ICK0017

As previously explained, Icklesham's sewer network is in need of an upgrade and the Parish Council feel that this should take place before any further development takes place. The Parish Clerk has an email from Southern Water which indicates that they are aware that the Water Treatment Works (WTW) in Icklesham gets overloaded which causes it to back up the line. The Clerk has asked Southern Water whether there are any plans to update the Water Treatment Works and they have advised there is no planned investment prior to April 2025 at Icklesham WTW. However, there is planned investment in AMP8 (April 2025 to 2030) to the monitoring of flows entering the WTW. Certainty of this investment is yet to be concluded by OFWAT in the PR24 determination for AMP8.


Potential Site identified in Rye Harbour

ICK0046

Parish Council have previously raised concerns about the local infrastructure not being able to cope with this level of development. Particularly the roads as Rye Harbour is effectively a cul de sac. Harbour Road already gets heavily congested, particularly in the summer months when visitors attend to visit the Discovery Centre and the Nature Reserve. ICK0046 has been identified as suitable for 40 dwellings which is a large development for Rye Harbour which is very small in comparison.

Live Well Locally

The Live Well Locally concept will be particularly difficult for residents within Icklesham Parish as none of the four settlements have a doctors surgery, the closest ones being in Rye and Hastings. There is also two primary schools throughout the Parish that serve all four settlements. These schools (Winchelsea CEP and Icklesham CEP) are very small schools and would not be able to take an influx of extra children. Two of the wards have small village shops and one has a Co-Op. None of these shops would be suitable to do a weekly food shop. Icklesham does not have a shop at all.

There is a bus service in each of the four settlements however the service is infrequent and at times unreliable.

Policy GTC2

Icklesham Parish Council are concerned about what this policy would mean for historic and listed buildings. IPC note that the polilcy states that HER1 would apply but it would be interesting to note which policy would carry more weight when deciding on a planning application.

Policy HER1

Please refer to note above concerning GTC2.

Policy DEV3

IPC would like to know if Net Zero developments would be considered outside of development boundaries.

Policy LWL3

Both Rye Harbour and Icklesham have potential sites identified for development. Both Rye Harbour and Icklesham have a bus service although the service is only once an hour during the week and once every two hours on a Saturday. There is no bus service at all on a Sunday in Rye Harbour. If new development is to go ahead, could Rother consult with Stagecoach about increasing the number of bus journeys?

Rye Harbour has good cycle paths however cycling in and out of Icklesham means cycling on the road with fast traffic both in and out of the village.


Policy HOU6

Planning Enforcement Team very over stretched and relying on Parish Councils and residents to flag any issues. Issues with HMOs may not be obvious to Councillors or other residents. Will the Enforcement Team realistically have time to Enforce such planning conditions?

Policy HOU17

Would these sort of developments be considered in Winchelsea Beach? IPC are concerned about the potential extra kitches and bathrooms and the strain this would cause to an already overloaded sewer system and ongoing surface water flooding and sewerage issues.

Policy ECO6

The Parish Council would like to know if this would also be the case for caravan parks extending their opening times during winter months? There have been instances recently where extension to opening times have been allowed despite objections raised by residents and the Parish Couoncil and evidence of extreme surface water flooding on specific sites being provided to the Planning Team and Planning Committee.

Policy ENV1

The Parish Council would like to know if anything can be done to ensure that any contributions are actually spent on improving local infrastructure as we know that the sewer networks in both Icklesham and Winchelsea Beach are in desperate need of updating. The Parish Council feel that this is a necessary step before any further development takes place in either ward.


Potential Sites Identified in Icklesham

ICK0041 & ICK0017

As previously explained, Icklesham's sewer network is in need of an upgrade and the Parish Council feel that this should take place before any further development takes place. The Parish Clerk has an email from Southern Water which indicates that they are aware that the Water Treatment Works (WTW) in Icklesham gets overloaded which causes it to back up the line. The Clerk has asked Southern Water whether there are any plans to update the Water Treatment Works and they have advised there is no planned investment prior to April 2025 at Icklesham WTW. However, there is planned investment in AMP8 (April 2025 to 2030) to the monitoring of flows entering the WTW. Certainty of this investment is yet to be concluded by OFWAT in the PR24 determination for AMP8.


Potential Site identified in Rye Harbour

ICK0046

Parish Council have previously raised concerns about the local infrastructure not being able to cope with this level of development. Particularly the roads as Rye Harbour is effectively a cul de sac. Harbour Road already gets heavily congested, particularly in the summer months when visitors attend to visit the Discovery Centre and the Nature Reserve. ICK0046 has been identified as suitable for 40 dwellings which is a large development for Rye Harbour which is very small in comparison.

My immediate concern was not in relation to funding construction but the apparent waste of funds allocated to the CLT who appear toe spending substantial sums on ‘investigating the site’s suitability’ for development when this has already been assessed as unsuitable in the HELA Assessment and it does not appear to require professional evaluation of the site in relation to existing and proposed Council policies and requirements as outlined in the Development plan to determine that it does not comply with many of them.

I would like to make it clear that I am strongly in favour of construction of sustainable social and low cost housing in the right locations. i.e. those with active travel routes to local infrastructure and served by good public transport links.

I feel that this could be achieved through rejecting applications for exclusive ‘high end’ housing developments unless a mix of low cost and social housing is ensured on every site.. The consequence of allowing a pseudo social-conscience fund (AKA Rother’s Commuted Sum Fund) is clearly resulting in exclusive homes for the wealthy on prime sites and funding development on low cost, unsuitable sites such as the one at Fairview for people on low incomes.

I question whether money allocated to the CLT for proposals at Fairview could be better spent on bringing empty homes back into use, and tightening controls on second homes and holiday lets which remain empty for long periods of time.

If new homes are constructed on the Fairview site, future residents on low incomes in that location are likely to be ‘marooned on site’ due to lack of safe active travel routes and extremely poor public transport to any local services including schools, shops, meeting places, play parks, sports facilities and entertainment.

Since any construction will have a life expectancy of decades, the suggestion that these homes will be carbon neutral will be entirely negated over time by private vehicle movements by any residents who are lucky enough to be able to afford their own vehicles.

I continue to believe that the perception of ‘cheap’ land at Fairview is clouding the judgement of the CLT. The HELA Assessment has already concluded that the site would result in car dependency for future residents (who can afford private transport) and, by implication detriment to those who cannot. For this reason alone, the project is also environmentally unsustainable.

It is also clear that the site does not comply with numerous policies and requirements set out in Development Pan proposals.

Any future development will clearly provide homes for generations to come so it is utter folly to build in the wrong place because the land is ‘cheap’.

I strongly believe that funds being wasted on investigating this unsuitable site could be spent elsewhere on provision of low cost and social housing on sites which do fulfil requirements of the local plan in terms of genuine environmental sustainability where further residents can gain safe access to local infrastructure through active travel and public transport.

Please see attached supporting document for full representation.

With reference to the proposed development of 14 houses at 'Wild Meadows', in Chapel Lane, Guestling.

I am totally against this development, Chapel Lane is a peaceful, rural, narrow, and historical country lane, with listed buildings where locals walk their dogs and ride their horses.
The building of 14 modern houses is totally out of character with the immediate area, not only will it put a burden on the local infrastructure but if planning permission is granted it will act as a precedent for every land owner in the area to assume they can apply to do the same.

I do not understand when planning permission for 4 houses at 'Wild Meadows' was recently rejected
that it is now deemed suitable for 14 houses.

Site ID: WES0003
This site can be available but its history includes 1 and 2 Moor View Cottages and associated large greenhouses and forms part of the curtilage of Moor Farmhouse. An access directly on to Stonestile Lane was approved by the Planning Inspectorate but it is proposed that access could and should be gained from the A28 by an extension to WES0021. See amended proposed development site submission for assessment.

Site ID: WES0021
The allocated orange area adjacent to Stonestile Lane forms part of Moor Farmhouse curtilage as determined by Justice Geoff. The available land for immediate future development will not include this curtilage.

It is proposed that the land area available for development would have an eastern edge approximately determined by the line of the mains sewer manholes as this would facilitate sewer maintenance if a road was built along this man-made boundary. There are 14 sewer manhole covers in this field making it unsuitable for agriculture. There are also Openreach access manholes adding to the unsuitability of this land for agriculture.

The visibility afforded along this stretch of the A28 provides the opportunity for safe access and egress for housing development on this new proposed site of 8.0 hectares. The extended site would not only offer an alternative road access (following line of sewer manholes) to WES0003 but with joined up thinking could be exploited for a more practical infrastructure to this end of the village. The natural topography of this area facilities drainage.

Frequent public transport from adjacent recognised bus stops affords good access to supermarkets, hospital and Hastings town centre.

See amended proposed development site submission for assessment.

Site ID: WES0031
A reduced area of this site, to straighten up the northern boundary of this field, will be used for the construction of two houses by the existing owners. The existing main sewer already passes through this site and other services are adjacent. The two properties would only need the access already available.

As with all things the future decisions made will determine if the policies, which appear community focused, are followed with "Green to the Core" and "Live Well Locally" at their heart.
For example, it would not seem credible to present policies stating that sustainability is vital for any potential development whilst Rother District Council's Housing Enabling Officer and Housing Development Manager are supporting Sussex Community Housing Hub and a CLT in progressing a potential Affordable Housing development on a site that is located in an area, categorised in the draft Local Plan, as being of poor sustainability.
This site was deemed unsuitable for inclusion in the 2013 SHLAA and was rejected in the new draft 2024 HELAA.
My hope is that the relevant bodies, within Rother District Council, judge the suitability of this site for development with the core objectives of the Local Plan very much in mind.

The term “Hastings fringes” gives a misleading impression of a coterminous homogeneous suburb. The numerous distinct settlements that are in this area could be more accurately referred to as “Southern Rother Villages”

Please see the attached submission on behalf of the landowner of WES0039 (and WES0035) regarding the suitability of WES0039 for development.

I am writing in response to the Draft Local pan 2020- 2040 ROTHER District Council and my
concerns regarding the proposed housing development in Chapel Lane Guestling.
Please see my concerns in point form:
1. This proposed site will feed off a lane not a road. by definition a country lane is A narrow
road in the countryside whereby vehicles travelling in opposite directions must slow or
stop to pass
2. At present this lane has restricted access at both junctions of the lane and most of
Chapel Lane is single track use already. By increasing the traffic flow on this lane, it will
severely compromise the residents and increase the likelihood of road/pedestrian
accidents down this lane. It is well known locally that lorries do not use this road for
access purposes because it is not suitable for large heavy vehicles.
3. The suggestion that Guestling is on the ‘fringes of Hastings’ is questionable. Ore village
is physically on the fringes not Guestling which is 3 miles away from central Hastings
town.
4. The proposed area comprises of areas of greenbelt and AONB, with ancient woodland
ancient adjacent to the proposed site. It needs to be considered and protected. Other
authorities Kent being an example have already demonstrated the ruination of rural sites
and built indiscriminatory on country land. We now have a conglomeration of housing
estates which have no delineations and have destroyed village communities and
identities. I do not want that to happen in Guestling.
5. This development will not enhance or protect the wildlife, habitats or ecosystems which
already coexist in the area. On the contrary this will have the opposite effect; any
disruption be it noise light or physical activity will alter their landscape forever. I am not
convinced any consideration has been given to this fact.
6. I have resident bats in my property and have recently had a bat survey that identified 6
species of bats occupying the local area. Bats survive in various habitats for different
periods and reasons; they will roost and socialise/mate in various habitats during the
calendar year. They will forage for food over several km every night. My house sits within
a prescribed area near the proposed housing estate therefore it is fair to assume that
any activity will seriously disrupt and interfere with the bat’s habitat and welfare. I am
not convinced any reference or consideration will be given to the bats and their rights for
the sake of building 14 houses.
7. There is no infrastructure to support new residents; the local schools and GP surgeries
are oversubscribed, and local public transport is limited.
8. I understand there is a shortage of housing stock nationally, but this building plan is
tokenistic and there other options to help the shortfall. Looking at unoccupied houses
and holiday lets/ Air BB will free up more appropriate local housing. There is always a
possibility that the proposed housing could also be purchased as holiday lets.
Reading the Draft local plan, I feel there has been very little reference or sensitivity has been
given to existing local communities and residents. I also cannot see where there is enough
emphasis and recognition that inevitably there will be a knock-on effect to the surrounding
countryside and wildlife.

Reference: GUE0012 Wild Meadows, Chapel Lane, Guestling Residential 14 Dwellings

The need for housing is understood, but must be in the right location. We and our neighbours in Chapel Lane, urge you to reconsider your inclusion of Wild Meadows as a potential development site for the following reasons: -

- Chapel Lane is part of an ancient rural landscape, dating back over 900 years, in an AONB. The proposed site overlooks the oldest Church in the area (Pett & Fairlight are much newer) It is ancient Guestling that should be conserved as a historic rural landscape, before the newer settlements. There are listed buildings on Chapel Lane and in the close locality.

-Chapel Lane is narrow, (one car width mostly) and already struggles to cope with the traffic using it. It is very rural with farms and low-density housing. There are many near misses when traffic is diverted from Pett Rd or the A259. Recently a pedestrian broke her leg and a man was knocked off his motorbike as part of a pile up caused by a goose wandering on the lane – not an uncommon sight here. To make the lane safe for further development, including the works traffic, significant widening of the lane will be needed, which will ruin the historical landscape and character of this AONB and picture postcard dwellings.

-As an ancient settlement mentioned in the doomsday book, Guestling should be preserved and not considered the “fringes” of Hastings. It is vital to conserve its character for future generations, and not allow it to be slowly urbanised. Green space between Hastings and Guestling should be preserved. It is very concerning that there is no mention in the local plan to maintain a green boundary between Guestling and Hastings.

-A proposal for building 4 houses on this site was rejected on appeal last year. To resolve the points of refusal, significant infrastructure will be needed, which cannot be justified against the negative impact on the AONB. There is no obvious need for housing here. Existing houses for sale stay on the market for considerable lengths of time. Families are not drawn to the locality, due to the lack of amenities and infrastructure. There are no shops, post office, play areas, or anything for children, other than the local school. This is often over-subscribed because it has to cater for all the local villages. A family who recently moved into the lane, couldn’t get their own children into the school because it was full. To create the infrastructure necessary to appeal to families, will significantly urbanise this rural village. Building houses on this site will likely result in most of them becoming second homes and AirB&B’s. It will do nothing to enhance your stated objectives to be “Green to the core” and allow residents to “Live well locally”.

-The rural ecosystems and ecology will be devastated by this proposal. A recent local bat survey identified 6 different species of bat here. Chapel Lane is also a crossing for hundreds of toads who breed in the lakes here. Many are already killed during their annual migration and the population will be devastated by the works traffic and subsequent increase in cars on the lane. The many owls and buzzards who live here require this area to remain rural and the few remaining glow-worms on the verges of the lane, (rarely seen now in the South East), will be wiped out by the works traffic.

- Housing was flooded on the lane near the proposed site last year and this development is likely to increase the risk.

- Next to the proposed site is an historic farm, which includes a small plot of ex-farmland which the council calls the depot. It was sold to the council by the local farmer as land to be used only for storing grit and sand for the winter. FERNS bought it from the council as it was mistakenly considered suitable for light industrial use. FERNS could not operate their lorries in the lane; it proved totally unsuitable due to being too narrow and the entrances to Chapel Lane at both ends being unsuitable for manoeuvring lorries. For this reason they no longer operate from the site. Having shown it to be unsuitable for industrial use, it would be better suited to a rewilding project, once the current small pet waste business that took over from FERNS ceases to use it.

- Brownfield sites and existing properties set within towns should be prioritised over historical, rural AONB areas, as they hold greater possibilities including inbuilt communities, services, amenities & opportunities for more jobs and economic growth.

Thank you for your consideration. As residents on this narrow rural lane, we strongly believe that the difficult balance you have to make between providing sufficient housing and conserving ancient rural settlements, weighs heavily in favour of preservation in this case.

Draft Rother Local Plan 2020-2040 – Public Consultation

Hastings Borough Council welcomes the opportunity to formally comment on the Rother District Council Regulation 18 draft Local Plan. Hastings Council is broadly supportive of the Rother Local Plan and its vision, aims and objectives. Specific comments are made here on those areas of the Draft Plan where there are strategic cross-boundary issues. We wish to continue to work with the Rother District Council on these and other matters in the Plan, as work on the Plan progresses as part of meeting Duty to Cooperate requirements.

- Joint Statement:

The Council is supportive of the joint statement and is committed to continuing to work closely together on strategic matters affecting both of our councils’ Plans.

- Housing requirement and Development Strategy:

The joint Housing and Economic Development Needs Assessment (HEDNA) identifies a need for 14,740 net new homes over Rother’s Plan period. The draft Plan outlines the potential to meet this need through the delivery of between 5,158 and 7,287 new homes. This equates to meeting approximately 50% of the district’s identified housing need, and places a potential pressure on Hastings Council, as a neighbouring authority within the same housing market area, to assist Rother in meeting their full housing need. Rother Council, has, after the start of their Regulation 18 consultation, now formally requested this council’s assistance in meeting their unmet housing need. As established through joint working with Rother planning officers, we will regrettably be unable to assist in meeting any of Rother’s potential unmet need owing to the challenges we face in meeting our own housing targets.

We note that at this draft Regulation 18 stage of the plan making process, (with an additional final public consultation to follow) this draft Plan does not provide any specific allocations but presents sites that have been assessed as part of the Housing Economic Land Availability Assessment (HELAA) process. The draft Plan’s preferred development strategy policy includes development around the Hastings Fringe (as referenced in option SD05 set out in the Development Strategy Background Paper) and identifies small-scale sensitive development around the fringe.

From the HELAA document it can be identified that there are only three sites identified in the Hastings Fringe that would be considered as potentially suitable sites that have not been rejected as part of the HELAA process. Hastings will be keen to discuss these potential sites on the Hastings Fringe and surrounding area as the Rother Plan progresses and further details of specific site allocations come forward. However, in principle, the Council is broadly supportive of the residential development within the Hastings Fringe, subject to the details of specific sites and their constraints.

Furthermore, the council is supportive of the assessment within the HELAA of land at the Breadsell (HAF0007), which indicates that the site is not currently suitable for allocation.

- Strategic Gap:

The Council is broadly supportive of the strategic gaps between Bexhill, Crowhurst and Battle in relation to Hastings, given the importance of the Combe Valley Countryside Park, environmental constraints and the lack of suitability in sustainability terms of these locations to accommodate significant levels of development. The supporting land supply evidence documents should clearly set out how these broad locations have been assessed and discounted for significant development.

- Employment Land:

The draft Plan indicates that it will be possible to meet overall employment needs in terms of having a sufficient supply of land suitable for employment-related development. However, there is an identified undersupply of land suitable for meeting storage and distribution needs. Given the undersupply of land suitable for storage & distribution within Hastings Borough, this could result in a significant under-delivery across the district and borough functional market area combined. The Council would therefore welcome more discussion on meeting employment needs across the two authorities’ areas.

- Flood Risk:

We recognise that flood risks may cross our respective district and borough boundaries. Some watercourses have interactions with, or originate from, watercourses beyond the Hastings borough. In some cases, surface water can enter these watercourses over quite a wide area (the Combe Haven is an example of this). The Council would welcome at this stage in the development of Rother’s Plan, the opportunity to explore whether the Rother Strategic Flood Risk Assessment (SFRA) is able to consider how surface water discharge may impact on flood risk in Hastings, either through runoff or interaction with watercourses.

- Whole Plan Viability:

As already stated, the Council is generally supportive of the policies that have been proposed in the Draft Local plan and their alignment with Draft Plan objectives. However, the Council notes that there is no whole plan viability assessment underpinning the policy proposals at this time. The Council is therefore keen to understand the viability of Regulation 18 policy proposals set out, as the plan progresses.

We also look forward to the continuing dialogue between the two councils as part of the duty to cooperate process.

The original reponse has been saved as an attachment, titled: 'Regulation 18 Representation - Hastings Borough Council'

With reference to the proposed development of agricultural land in Chapel lane, Guestling for 14 Houses. I feel that this is again without consideration of the impact this would have on the neighbourhood ,quality of life for all residents and destruction of more land and wildlife is without consideration of the environment .. There is loss of sight for the chaos and disruption this will bring. There are no services, the water supply fails , so this would again add more decreased pressure to existing houses. No recreational centres or parks , countryside walks for people to enjoy is far more important than building more houses without facilities for people to live a healthy balanced life.

I am against this greed again for the purposes of ticking the boxes and quota to provide housing without intelligent thought of the quality of life for every being, including the wildlife habitat.

See attached document for the representation.

Please see attached full representation on the draft Local Plan in relation to HELAA site ICK0017.

Representation by Stantec on behalf of Welbeck Strategic Land III Limited in support of Land East of Waites Lane, Fairlight Cove - HELAA site ID FAI0001.

Submission also responds to questions 59, 60, 61, 76, 27 and 191 in the Regulation 18 draft Local Plan.

Please see attached submission for full comments.

See the attached documents regarding HELAA sites HAF0013 (Land rear of 70 Westfield Lane, Westfield) and HAF0032 (Land at 56 Westfield Lane, Westfield) which comprises:
1) The Written Representation; and
2) Appendix 1 - Location Plan

See attached documents which comprise the submission for the Regulation 18 Local Plan and HELAA site ICK0002: Seven Acres, Watermill Lane, Icklesham.