Sedlescombe potential site SED0020. This site was rejected in the previous Dasa . The site was assessed in the previous East Sussex Landscape assessment done for RDC. The document was :

Rother District Council
Local Development Framework
Core Strategy: Market Towns and Villages Landscape
Assessment
August 2009
Volume 1

Its comment on this site is attached and clearly shows it is not recommended for development

Assurances at the time that the 63 new houses in Tollgates would not be a Trojan horse for further development were clearly false. If 100 new houses were built on adjacent land that would then provide argument for further development on what is one of the most beautiful parts of this AONB and consists of ancient woodland, prime farming land and includes the historic Malfosse Way through Manser's Shaw. UP to 200 additional cars passing within a few yards of the grade 2 listed building referred to, which I and my wife own, would compromise its integrity - it has no foundations. These vehicles would then pass through a narrow road between bungalows and debouch onto the already grossly overcrowded North Trade Rd very close to the Claverham Community College. While I have sympathy with the need for more housing, I'm afraid this is not the place for it.

Catsfield site allocation CAT0001 (HELAA Identified) has recently had an outline planning application submitted and withdrawn before it was refused (Application RR/2019/257/P).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 attached representation.

In support of BAT0001 - Darvel Down Site A, Netherfield

Please see attached:

- Main representation
- Appendices 1-4
- Appendix 5 and Landscape and Visual Technical Note

I would like to submit my response to Q.64 of The Draft Rother Local Plan 2020-40 P.145
I am writing to STRONGLY OBJECT to the proposed development of land at Almonry farm, North Trade. Site ID BAT0014 and request that is REMOVED forthwith.
I have examined the HELAA and have the following strong objections to the development of houses on this site:
this is an area of ancient land within the High Weald AONB with immense bio-diversity and should be preserved for nature as part of Rother's goals.
Building on this land would destroy food security as it is Grade A farmland.
This site was originally part of Battle Abbey and is of significant historical importance and should be preserved for these reasons.
This does not seem in keeping with RDC emphasis on being "green to the core".
Please consider as part of Call for Nature which is more appropriate.

BAT0026: AONB, Priority Habitat and a High Weald Wildflower Meadow. A development of this scale would inevitably cause significant harm to these valuable ecological features. With the inclusion of the Glengorse Estate, a recognized heritage asset, the proposed development would undermine the protections afforded to this important piece of local heritage

BAT0014: The suggested 100 houses is clearly a misprint or diversion as it massively breaches the density policy in the plan (representing a DPH of 0.18 as opposed to the plan's minimum for the area of 60+). Furthermore the damage to the area that the proposal would cause is hard to overstate:

Loss of Character: The proposed development would significantly alter the open character and natural beauty of the High Weald AONB and National Landscape, replacing historic fields with a large-scale housing estate. This would irrevocably damage the scenic value of this protected area, which is cherished for its rural charm and tranquility.

Harm to Landscape Setting: The development would encroach upon and disrupt the existing landscape setting, particularly the delicate balance between the built environment of Battle and the surrounding countryside. The introduction of a large number of dwellings would visually overwhelm the site and erode its natural appeal. The development would undoubtedly impact views from surrounding hills and trails, diminishing the overall aesthetic quality of the High Weald.

Ancient Woodland Destruction: The proposed development would directly abut an area of ancient woodland, a rare and irreplaceable habitat that supports a wide range of flora and fauna. Construction and associated activities would inevitably cause disturbance, fragmentation, and potential loss of this critical ecosystem.

Habitat Loss and Degradation: The network of historic fields, mature trees, hedges, and pond within the site provide valuable habitats for various wildlife species including bats, deer and various birds. Development would lead to the destruction or degradation of these habitats, resulting in the displacement or loss of local biodiversity. The proposed access points both have a multitude of mature trees that will be felled or suffer severely damaged roots as a result of the proposed roads.

Proximity to Battle Conservation Area and Registered Battlefield: The site's proximity to these nationally important heritage assets raises concerns about the potential visual impact of the development. The large-scale nature of the proposal could detract from the historic significance and setting of these areas, compromising their cultural and historical value.

Impact on Grade II Listed Building: The construction of a vehicular access via Tollgates, as suggested in the plan, would directly affect the setting and visual integrity of the adjoining Grade II listed building (Lower Almonry Farmhouse) and the corresponding oasthouse. This could significantly diminish the historic value of the building and compromise its architectural integrity. Furthermore, the proximity of the proposed roads to the listed building, as well as the highly likely flooding from the removal of trees on the lane, may well cause irreversible structural damage to Lower Almonry Farmhouse.

Surface Water Flooding: The site is already identified as being at risk of surface water flooding. Developing on this land would exacerbate this risk, leading to flooding of the development itself and causing problems for existing neighbouring properties. A large ancient oak at the top of the track (one of the proposed access routes) was removed a few weeks ago in readiness for this plan and more will need to be felled, creating further risks of flooding and heave to the local properties.

Strain on Infrastructure: A development of this size would place significant additional strain on local infrastructure, including the congested North Trade Road and High St.

Visual Dominance: The scale of the development would overwhelm the surrounding landscape, creating an imposing and incongruous feature that would detract from the rural character of the area.

Loss of amenity: the path way adjoining the plot along with Manser Shaw on the Western boundary and Saxonwood to the South are all regularly used by locals and tourists alike for rambling, dog walking and accessing the Abbey / High St. The proposed development will affect the enjoyment and amenity of the open space and will be detrimental to the physical and mental health of the residents.

Any significant proposed developments in Battle would be terrible for the town,
None of the infrastructure in battle could cope, at present the traffic is unbearable at peak times the schools are at capacity the doctors are at capacity as is the dentist.
Any proposed development on open countryside (as has been carried out at Blackfriars and Lillybank) will destroy the wildlife habitats and this is just unnaceptable!
There are much more suitable sites very close to battle for housing.
For example the east side of the Queensway this was largely cleared for commercial use and the construction of the Sussex exchange so the road work has already been carried out however Sussex exchange has gone into liquidation and the rest of the land has sat for sale for years it seems evident no one wants this for commercial use so why not use it for housing. There is already housing adjacent there are also major supermarkets etc very close by and good transport links.
There are lots of opportunities for jobs on the opposite industrial estate.

Extremely disappointing to see potential sites that may be allocated, but others that have been discounted and yet you still haven't identified enough potentially developable housing sites...

These larger scale developments are ruining villages, but as usual it's the big developers that benefit, but smaller land owners who would actually design and develop properties in a way that would take into consideration land characteristics have been overlooked yet again.

The site assessments are contradictory... how can you potentially consider one site that is within the AONB, has a Grade II Listed building nearby and historic field boundaries and yet discount another site that has the same or similar environmental constraints (ref CAT0016 & CAT0012 as below)?

I would welcome comments on the following sites:

• CAT0016 – Considered a Potential Site:
Summary of Environmental constraints - This site is within the High Weald National Landscape. It is adjacent to the Pevensey Levels Hydrological Catchment and a small area of surface water flooding affects the western section of the site. There is a Grade II Listed building nearby. The site is bounded and intersected by historic field boundaries. A public right of way runs adjacent to the site.

• CAT0012 – Rejected Site:
Summary of Environmental constraints - This site is within the High Weald National Landscape. There is a historic field boundary to the north. Listed building opposite to the south-west.

How can you consider one site for a larger number of houses and reject the other for a smaller number of houses, with both having the same environmental constraints? If anything CAT0016 has more site constraints and has single access to the site.

CAT0012 would have been developed in a way that took account of the AONB and wouldn’t have affected any field boundaries and certainly would not have impacted on the listed building opposite in Church Lane. The 1st paddock is within the centre of the village, has good connections to the local amenities. The site is relatively well screened from the wider AONB and yet you say:

“a development at the scale considered through the HELAA would be out of keeping with the established and historic settlement pattern of the village and would appear as an encroachment beyond the ribbon development fronting Church Lane, highly visible from the lane and having an urbanising impact, harming the rural character of this part of the village and its setting within the High Weald National Landscape”.

How can a development of up to 5 well designed properties (similar to approved application RR/2019/271/P) be of scale out of keeping with the established and historic settlement pattern of the village? This was referenced in our HELAA application. The development wouldn’t be highly visible from Church Lane as it would be mostly screened from the existing properties in Church Lane and would be as close to the existing development boundary as possible without significantly impacting upon those properties, one of which (Spring Cottage) being ours.

With reference to Potential Site CAT0029 – this is a flood plain and unless I’m mistaken this is considered a “major site constraint” so how is this even being considered?

I am at a loss how you are not even considering CAT0012 when you have put forward CAT0016 and CAT0029 as potential sites and given their site constraints and would welcome the opportunity for CAT0012 to be reconsidered, given your position as not having identified enough developable housing sites.

This is a High Weald AONB and any planned housing would cause significant damage to the immerse bin diversity of the area which comprises of ancient woodland, ancient and veteran trees, meadows, habitats and animals. Battle is a hugely important market town, home to one of the UKs 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. Viable farmland will be ruined, this comprises of grade A farmland. Battles roads cannot cope with further traffic, the highstreet already gets gridlocked at times. What are the plans for the infrastructure, schools GPs? Proposed access is unworkable.

The area is within the high weald AONB any planned housing would cause significant damage to the immense bio diversity of the area with inc wildlife life bats owls birds reptiles endangered plants old veteran trees . By adding this houses you will put strain on local schools docs the town should be kept historical not be emerged into one.

The viable land will be ruined it is currently being used for live stock and hay. Building over this will take the country away from battle again will effect any wildlife. We have seen dear run wild in these feels low flying battles lots of wildlife it would be awful to take this away.



Access via tollgate residential area is unworkable the planned access road would put immense pressure on tollgates with has just recovered from expansion

I wish to strongly object to the proposed site of 100 houses (BAT0014 Land at Almonry Farm). This area is within the High Weald National Landscape, and is of immense topographical, historical and environmental importance. This site is completely inappropriate for development and should be rescinded as an option immediately. It was formerly Battle Abbey Land and thus of immense historical significance. It is home to a huge abundance of ancient hedgerows, woodland and endangered animals. Commonly spotted are: Hares, hedgehogs, bats, roosting buzzards. The area proposed for development lies within the High Weald AONB and any planned housing would cause significant damage to the immense bio diversity of the area which comprises of ancient woodland, ancient mature trees, meadows, ancient hedgerows and habitats for endangered plants, funghi, birds, reptiles and mammals. The infrastructure required to build 100 houses (sewers, piping systems, cables, foundations etc) would decimate the ecology of the site and endanger wildlife thus not fulfilling National Policy of ‘highest status of protection.’
'Development here has the potential to harm the landscape and character of the National Landscape.' (HELAA) is precisely why it should not be considered. There is no bio diversity net gain in developing this site, only deficit as it has immense intact, established bio diversity.
It is an area Rother should be considering in response to your “Call for Sites” extension which now includes sites for nature to meet Rother’s off-site Biodiversity Net Gain requirements.
The site comprises of Grade A, viable farmland (it is currently farmed for hay and grazing sheep and has no chemical depletion to the soil). Building over this site would rob the opportunity of this area being farmed again thus demeaning food security.
The site would significantly damage the topography of Battle. Two buildings of historical significance (Almonry Oast and Almonry Farmhouse) would be degraded by the access road into the site as it would bisect these former farm dwellings. These buildings are currently visible from Battle Abbey.
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
Classification of a major development is 10 houses or more, this proposal is for 100 houses. Why? 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 +
The current Blackfriars site has had construction headaches that are putting pressure on RDC finances, has decimated local wildlife and there is no impact assessment on how this has affected residents or the town.
Building on the proposed site would have a huge impact on the already congested roads. North Trade Road and Battle High Street are already heavily congested roads that are struggling to cope with the current volume of traffic. Adding another 100 houses would significantly increase the pressure on already heavily congested roads, increasing noise, pollution and damage to the health.
The infrastructure of Battle in terms of health, social care and schools would be badly affected.

Land north of Brede Lane, Sedlescombe is assessed in the Housing and Economic Land Availability Assessment (HELAA) (April 2024) under reference SED0032. In summary it is identified as ‘not suitable’ on the grounds of landscape impact and accessibility. We do not consider this assessment to be correct and ask the Council to reconsider this site as a housing allocation.

Location and Surroundings

1.39 The site occupies approximately 2.8 hectares and is situated to the east of Sedlescombe with access from Brede Lane. The site is currently an agricultural field bounded by woodland and hedgerow. The site lies to the north of East Terrace View and the settlement edge of Sedlescombe.

Proposed Development

In response to the HELAA assessment we have undertaken a Landscape and Visual Appraisal of the site and this is attached as a separate document. This assessment has carefully considered the site within its landscape context and its capacity to accommodate development.

At this stage an indicative masterplan has been prepared in order to illustrate the type and scale of development envisioned on site. A range of homes would be delivered, with a balance of tenures and sizes to meet local needs, whilst respecting the character of the local vernacular. The proposals work with the typography of the site and the surrounding character to provide a sensitive small scale development of between 35 to 40 dwellings.

The proposal would protect the adjacent woodlands by providing a generous offset in excess of 15m. The topography of the site results in a low density scheme allowing for generous areas of open space as well as green and blue infrastructure providing opportunities for onsite biodiversity net gains and landscaping.

A well connected network of routes for pedestrians, cyclists and vehicles will link to the existing network of footpaths to the north and Brede Lane to provide the necessary connections to public transport, encouraging healthy lifestyles and sustainable travel.

Landscape

According to the HELAA, development at the scale considered through the HELAA would be harmful to the landscape and character of the National Landscape and rural setting of the village. LDA Design has considered the ability of the site and its surroundings to accommodate new residential development, identified where opportunities and constraints exist from a landscape/visual perspective, and how potential impacts could be minimised through a sensitive design response. Consequently, the landscape strategy prioritises preserving and enhancing existing vegetation onsite, ensuring the new development integrates within its surroundings. Particular attention would be given to parts of the site that contain key landscape features or are more visible from the site’s surroundings, ensuring the development can be well integrated. Longer range views are expected to be limited and where visible, the proposed development will appear as part of the broader settlement.

Therefore, it is considered that the site can readily accommodate a sensitively designed development whilst respecting the wider countryside setting without harm to landscape visual impact.

Highways and Access

The HELAA raises accessibility as a further constraint. It concludes the site is some distance from services within the village and accessed via a narrow part of Brede Lane. We disagree with this conclusion. There is a continuous footpath which runs along Brede Lane providing access to the village and public transport links. The recently consented scheme immediately to the south of this site (RR/2022/2619) for 21 units proposed some improvements to footpath links along Brede Lane and was found to be acceptable by both the LPA and the Highway Authority.

In summary, it has been demonstrated that the site represents a viable and sustainable location for developments in transport planning terms.

Ecology & Biodiversity

There are no ecological constraints on site which would prevent the site from being developed. Nevertheless the intention will be to achieve Biodiversity Net Gain including through on-site enhancements. The necessary ecological surveys will be carried out and will inform an ultimate planning application on the site.

Deliverability

The site is considered to be a logical site which can provide a suitable and sensitive small scale development on the edge of a sustainable village. Catesby Strategic Land Ltd have a legal interest in the site and this reflects the landowner’s willingness to make the land available for development. There are no known viability issues, legal or third-party constraints present and there are no impediments to the site being allocated for development commencing early within the Plan period.

I would like to submit my response to Q.64 of The Draft Rother Local Plan 2020-40 P.145.

I am writing to make a record of my concerns after reviewing Rother District Council’s draft Local Plan (2020 – 40) and draft housing and economic land availability assessments (HELAA). Specifically Chapter 3 of the HELAA document, Battle and surrounding settlements. P.31
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 site 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 100 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
The classification of a major development is 10 houses or more, this proposal is for 100 houses. Why? 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.
3. Urban Sprawl. A poor decision on a planning application on this site (100 houses) 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. Viable farmland ruined. 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 100 extra houses will put enormous pressure on the already strained road network and old buildings.
8. Infrastructure. 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 not NIMBY’s, moreover 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).
RDC need to listen to the responses of this consultation and consider the implications for future generations, in a declining population, of the impact decisions today have on Battle’s Green future. There are other sites to consider that don’t choke the life out of Battle. Leave our precious AONB alone.

Please see attached the full submission regarding Land at Breadsell Farm covering background information to the site as well as detailed responses to questions 27, 28, 32, 51, 52, 54, 55, 60, 61, 77 and 90.

On behalf of my client I write to make submissions to the Rother District Regulation 18 Local Plan consultation. My client has control over land west of Netherfield Court, Netherfield Road, Netherfield, TN33 9PX
These representations relate in particular to the following parts of the Regulation 18 document, titled Rother Local Plan 2020-2040:
•
Housing Need
• Preferred Spatial Development Options
• Relevant Draft Local Policies
A site plan outlining the land promoted for development is included at Appendix 1 and has been considered under the HELAA under reference BAT0065.
Housing Need
The key objective to significantly boost the supply of housing remains a focus of planning policy at all levels. Paragraph 60 of the NPPF states that to support this aim it is important to ensure a sufficient amount and variety of land can come forward where it is needed.
In addition, paragraph 11b of the NPPF states:
‘Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i.
the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii.
any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.’
The Regulation 18 consultation identifies the housing need in the district as 14,660 homes for over the twenty-year plan period 2020 to 2040. This figure was identified in the Housing and Economic Development Needs Assessment (HEDNA, 2024), and was derived using the Standard Method, as required by the NPPF and accompanying Planning Practice Guidance (PPG). This amounts to 733 dwellings per annum. It is not clear from the Regulation 18 consultation whether this figure includes a 20% buffer to be applied as a result of under delivery as set out at paragraph 77 of the NPPF. If the 20% buffer has yet to be applied, housing requirement would increase to 879 dwellings per annum -17,580 dwellings over the plan period.
In any event, the Council have confirmed they do not in fact intend to meet their full housing need (as calculated by the standard method) for a number of reasons most notably the significant landscape and flooding constraints which exist across the district. We accept that footnote 7 of paragraph 11 of the 2023 NPPF allows for a reduction in housing delivery in areas restricted by certain designations, including National Landscape, of which a significant part of the Rother District falls within. However, we do not consider the lower housing figures offered in the Regulation 18 Consultation have been justified or that sufficient reason has been given for not meeting the higher housing need figure identified within the ‘range’ put forward by the LPA, as discussed below. It is acknowledged that the Council have stated that the final figures to be put forward for adoption will be ‘minimum’ figures. However, the history of under delivery of housing since the adoption of the Core Strategy is well documented (as set out paragraph 5.3 of the Regulation 18 Plan) which makes all the more pressing case for the Council to be taking a more radical approach to positively plan for a higher level of housing.
The Council have made a passing reference in the Regulation 18 plan to a number of reasons as to why the housing need figure calculated using the standard methodology cannot be met including:
•
Landscape constraints
•
Constraints resulting from areas lying within flood zones
Beyond a passing reference to environmental constraint, the Council has not set out in detail why they cannot meet their full identified housing need, yet seem to acknowledge the need to plan for higher levels of growth by running an additional call for sites alongside the Regulation 18 consultation. The land west of Netherfield Court would not be constrained by any of the landscape or flooding constraints cited by the Council as reason to not meet full identified housing need.
Whilst it is located within in the High Weald National Landscape (formerly AONB), the land to the west of Netherfield Court is considered to be capable of accommodating some development without adverse effect on the natural beauty of the High Weald which underpins the designation of this area. The land is located entirely within Flood Zone 1 meaning it is not in an area of the district which is at risk of adverse flooding.
Netherfield has a range of day-to-day facilities that can be accessed from the site, including a primary school and post office. There are also bus stops within Netherfield which provide a number of services to Battle and Heathfield where a wider range of day-to-day facilities can be found.
Paragraph 70 of the NPPF recognises that small scale developments can deliver housing at a faster rate. The land is owned outright by Mr Longbottom and so there are no third-party ownership issues which might prevent or delay development. It is anticipated that a small-scale development here could be delivered at a relatively quick rate.
In accordance with the Government’s objective of significantly boosting housing supply we contend the Council should pursue a higher growth strategy to fully meet the full identified housing need for the plan period. Adopting this approach will allow the Council to develop a long-term sustainable growth strategy which provides flexibility to adapt to changes in demand and allow for the inevitable cases where development does not come forward for some reason or under delivers. This is particularly the case given the history of under delivery in the district. It would also allow for a more consistent delivery rate, allowing for a wider range of smaller sites to be delivered while the infrastructure is put in place to serve larger developments.
Proposed Strategy: Overall Spatial Development Strategy
The Regulation 18 draft local plan identifies a number of spatial strategies across the district to respond to different circumstances, including small-scale development 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 National Landscape.
We support the principle of employing a number of spatial strategies to provide the flexibility to respond to differing circumstances. As a village on the outskirts of Battle, Netherfield is well-placed to take some additional growth. Figure 21 of the Regulation 18 plan identifies housing growth of 33 dwellings based on existing allocations in the Battle Neighbourhood Plan. The Regulation 18 plan does not seek to add any additional development to Netherfield beyond the Neighbourhood Plan allocations. The existence of allocations for housing growth in the Battle Neighbourhood Plan is an indication of the fact that Netherfield is considered to be a suitable location for housing growth and we would contend that moving forward additional allocations for small-scale development should be made in Netherfield.
This is particularly the case as the Neighbourhood Plan allocations for Netherfield have existed since 2021 yet no development has been brought forward on any and there is no guarantee that these allocations will be delivered. One allocation site (White House Farm) has been the subject of a planning application which was submitted in January 2023 and remains undecided due to a number of unresolved objections from statutory consultees. The other allocation site (Swallow Barn) has been the subject of two planning applications which have been refused on a number of grounds including concerns over the proposed access arrangements. It is worth noting that the applications at Swallow Barn have been for 5no dwellings and 4no dwellings respectively as opposed to the 10no dwellings identified in the adopted allocation policy. This factor alone provides justification for making additional allocations within the Netherfield area to ensure that at the minimum the quantum of growth identified under the Neighbourhood Plan is still delivered.
Vision for Battle and Surrounding Settlements
The vision for Battle indicates allowance for ‘small-scale development 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 National Landscape’. The submitted land is situated in a settlement in the area surrounding Battle so in principle is in line with this aspect of the proposed policy. The land has the potential to deliver small-scale development which is respectful of the character of the High Weald National Landscape it lies within.
Proposed Policy DEV3: Development Boundaries
Proposed Policy DEV3 states that ‘Development boundaries define the area within sustainable settlements where development will be permitted, provided it is consistent with this Local Plan’.
The explanatory text for this policy explains that settlements identified within Figure 38 (which includes Netherfield) will have their development boundary reviewed as part of the next stage of the Local Plan process.
The development boundary of Netherfield is currently set out in the Battle Neighbourhood Plan, as included in Appendix 2. The boundary on the eastern side of Netherfield is on the eastern boundary of Netherfield Primary School and the properties immediately to the south of the primary school. The development boundary as identified excludes significant amounts of existing built form within Netherfield including facilities such as the village hall and Netherfield Arms. We would contend the development boundary for Netherfield requires a comprehensive review so that it is extended to take account of existing built form and facilities. As part of such a review the development boundary should also be extended to take into account any proposed allocations which could include our clients land.
Proposed Policy DEV5: Development on Small Sites and Windfall Development
This policy recognises that historically, small sites and windfall development have played a role in the delivery of housing growth in the District and seeks to continue this reliance. We support the inclusion of this policy.
Site Specific Considerations
The submitted land identified at Appendix 1, lies on the outskirts of Netherfield.
It is noted that Netherfield has been identified within the supporting ‘Settlement Study’ as a settlement of low sustainability despite having three ‘Essential Services’. The reason for this is cited as being low scoring in terms of public transport options. We would contend that given the presence of a relatively high level of essential services (for a settlement of its scale) and the fact that it has been allocated for growth under the Battle Neighbourhood Plan the categorisation of the settlement as a settlement of ‘low sustainability’ should be reconsidered.
Notwithstanding the categorisations of Netherfield as a ‘low sustainability’ settlement it is noted that paragraph 7.25 of the Settlement Study states: ‘Some exceptions are Catsfield, Dallington, Netherfield and Woods Corner, which have each scored 3 out of 5 for access to essential services and could benefit from the provision of additional essential services and/or better public transport accessibility. They could potentially be considered sustainable locations for limited amounts of development, depending on the recommendations of the Development Strategy.’
Coupled with the identified strategy for small-scale development in villages surrounding Battle it is considered that additional growth beyond the Neighbourhood Plan allocations should be considered for Netherfield.
Our client has control over land to the west of Netherfield Court amounting to 2.42 hectares. The land benefits from an existing field access in the south-eastern corner directly onto Netherfield Road although alternative options for a new access along the site frontage could also be explored. It is understood that previous discussions with the Highway Authority secured in-principle agreement to a new access point further west along the site frontage. If this was pursued as an alternative arrangement it would enable existing trees in the south-eastern corner of the site which are subject of a Tree Preservation Order to be preserved and an appropriate buffer from any forthcoming development maintained.
The land is largely vacant agricultural grassland which is not covered by any ecological designations. The boundaries are secured by trees and hedgerows. The retention of the existing tree cover would enable development on the site to be well-screened from adjoining residential properties.
There are no public rights of way within the vicinity of the site and the sites lies within Flood Zone 1.
On the basis of a capacity of 25-45 dph dwellings per hectare (in accordance with proposed policy LWL1) the site would be capable of accommodating up to 60 dwellings as a minimum. However, taking account of the plot sizes surrounding the site and the need to set aside areas for biodiversity net gain it is considered that a lower level of dwellings would be more appropriate likely to be in the region of 6 dwellings focused on the front (southern) portion of the site. It is noted that the HELAA assessment of the site raised concerns about the landscape impacts of development on this site. We would contend that by pursuing a lower level of development focused on the front portion of the site landscape impacts could be minimised. Any forthcoming application would be supported by detailed examination of baseline and future landscape features. Through a Landscape and Visual Impact Assessment, the impact of development on the character of the High Weald NL would be assessed and the layout of any forthcoming scheme guided by this.
There are no listed buildings within the vicinity of the site which might be impacted by development of the submitted land.
Netherfield benefits from a number of day-to-day facilities including a primary school, village shop, post office & café and 2no Public Houses. These are all within walking distance of the site although it is acknowledged that a proportion of this distance there is no dedicated footpath. Netherfield lies within relatively close proximity to Battle which has a full range of day-to-day facilities. I trust that the enclosed information is clear and I look forward to receiving confirmation of receipt of this submission.
In the meantime, should you require any further information, please do not hesitate to contact me.

I am writing to make a record of my concerns after reviewing Rother District Council’s draft Local Plan (2020 – 40) and draft housing and economic land availability assessments (HELAA). Specifically Chapter 3 of the HELAA document, Battle and surrounding settlements. P.31
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 site 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 100 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
The classification of a major development is 10 houses or more, this proposal is for 100 houses. Why? 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.
3. Urban Sprawl. A poor decision on a planning application on this site (100 houses) 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. Viable farmland ruined. 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 100 extra houses will put enormous pressure on the already strained road network and old buildings.
8. Infrastructure. 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 not NIMBY’s, moreover 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).
RDC need to listen to the responses of this consultation and consider the implications for future generations, in a declining population, of the impact decisions today have on Battle’s Green future.

I own the Caldbec House site, originally slated for 5-9 in the earlier pre- Neighbourhood Plan study.

As a Yimby not a Nimby I have recently built one, and am awaiting a decision on two more homes. It keeps getting harder and more expensive and takes longer to get anything built, and that is on land I have owned for forty years. I rent out properties there long-term and short term, and have since 1996.

In my view the field to the south of Caldbec House could take two detached houses and two pairs of semis without overdevelopment, within walking distance of Battle, by road or footpath. Importantly, a mains sewer commences in the field, so the main infrastructure is already in place without cost or disruption.

My other property over the road Hughs’ Field/Land north of Caldbec House had applications for first five houses then one house turned down on appeal. It is misdescribed in the present paperwork, which should be corrected. It is clearly within town, and not part of the Furness lands off Virgin’s Lane, or part of the two Kingsmead public meadows, though it got lumped in with them in earlier studies. In my view, it could easily accommodate one detached house and two pairs of semis, which would hardly be seen from the street or elsewhere, all within walking distance of the town, in the least traffic-clogged bit of town. It is of no earning power as a field, has no access to the public, and has effectively been expropriated to suit and benefit neighbours as if public green space without compensation. Given the pressing need for housing, it should be re-included in plans.

Both fields and Caldbec have been visited recently by X.

When the town was surveyed some years ago, what most people wanted was small developments spread out through the town, not blocks of 50 or 220. Caldbec is the only small development in town.

I would also comment on the core objectives, though it might not be in my interest to do so. I do not agree with Green to the Core as the primary objective, though it is clear it will happen. I think such issues are better dealt with by the national government. As a tourist town needing commerce, good public loos and more free parking are in my view a higher priority at this level than net zero. As someone who had a commercial shop in Battle, I’d put people and housing for locals first; I note the Rother header picture is of sheep. I like sheep, I have tried to put them in my fields, the paperwork is beyond belief. It is also not easy to be a landlord or a local developer, and I think town councils should modulate their levels of opposition and interference into private property if their members are largely unelected. That includes TPOs, which in my view should be used very sparingly on private property if they are not to have unintended effects. Our land opposite Caldbec was expropriated for a road scheme which was abandoned, the land was eventually declared green space, and then a parking lot was instituted recently on that green space at the entrance to old Battle, at the exact location deemed unsafe when the field was expropriated. There is also a culture of anonymous complaints which in my view is counterproductive, and best reduced.

Please refer to document attached

See attached document for the representation which addresses:
- Housing Need
- Preferred Spatial Development Options
- The Vision for Battl eand Surround Settlements
- Proposed Policy DEV5: Development on Small Sites and Windfall Development
- Proposed Policy ECO1: Supporting New Employment Development
- Proposed Policy ECO2: Protecting Existing Employment Sites and Premises
- HELAA sites CAT0013 (Piggery, Great Park Farm, Horns Corner, Catsfield) and CAT0021 (Nursery (glasshouses), Great Park Farm, Horns Corner, Catsfield).

For comments on the Spatial Development Strategy including overall housing provision, please see paragraphs 3 - 5 in the attached Main Submission Document. The representation is registered under Q54 in the Regulation 18 draft Local Plan.

For comments in support of HELAA site SED0020 please see paragraphs 6 to 11 in the attached Main Submission Document. The representation is registered under the Battle and Surrounding Settlements Chapter of the HELAA.

Attached documents:
- Main Submission Document (including Appendix 1 & 2)