Peasmarsh Parish Council has worked with RDC Planning to complete the Peasmarsh Neighbourhood Development Plan, so is already aware of the allocated sites. However, the Parish Council would like to reiterate their request for RDC to work with the utility companies, in particular, Southern Water - to make sure that the infrastructure is in place to sustain the increase in house building in an already overburdened drainage system. In addition, there is a desperate need for affordable housing (including rural exception sites) and RDC need to work with developers to make sure that this element is financially viable and can be delivered.

I have lots of evidence of slow worms living in area BRE0002 these are European protected species (EPS) are protected under The Conservation of Habitats and Species Regulations 2017.
It is an offence to: deliberately kill, injure, disturb or capture them
deliberately take or destroy their eggs
damage or destroy their breeding sites and resting places
possess, control or transport them (alive or dead). it is also an offence under the Wildlife and Countryside Act 1981 to intentionally or recklessly:
disturb them while they occupy a structure or place used for shelter or protection
obstruct access to a place of shelter or protection. under Section 41 of the Natural Environment and Rural Communities Act (2006). You must have regard for the conservation of Section 41 species as part of your planning decision. I have every intention of contacting all conservation organisations to prevent you destroying this endangered species habitat.

Objection to HELAA site BRE0035 - Land at Broad Oak Lodge, Chitcombe Road. Please see attached representation.

Comment on Rother District Council, Draft Housing and Economic Land Availability Assessment

Part 2, Site Assessments.
Chapter 4 - Rye and the Eastern Settlements Cluster

My comments relate specifically to the proposals for development in Iden. Potential sites are identified on p46 – 52 of the above document and I refer particularly to the one at Street Field, Main Street (IDE0010).



Infrastructure

Iden is not on the mains gas network. Residents have to rely on oil, electricity or wood burning for energy.

We can normally rely on two or three electricity outages per year and three or four water stoppages, sometimes for days at a time

Another ten houses in the village will place additional strain on the existing resources and contribute to further shortages.

The nearest GP practice is Rye Medical Centre. The current waiting time for a face to face appointment is a month. The extra potential patients in their catchment area will contribute to a further deterioration of an already unacceptable service.

In short, the existing infrastructure is inadequate to meet the needs of the proposal.


Road safety

The B2082 through Iden is subject to a 30 mph speed limit however there are no speed cameras or other road safety devices to deter drivers from exceeding this and many do on a regular basis. There have been at least two collisions in the last couple of months where speed has been a contributory factor.

Being relatively isolated, Iden residents often rely on deliveries by supermarkets or online retailers. This means a significant proportion of road traffic through the village consists of delivery drivers which is usually left unaccounted for by developers carrying out traffic assessments.

The addition of around 20 private motor vehicles to the village will create an increased risk of road traffic collisions.


Traffic and Transport

Iden has a small shop/ Post Office however residents rely on Rye for wider services and shops. Rye is not within reasonable walking distance and, even if it were, there are no safe walking routes along the main route (B2082).

Cycling is equally hazardous as the main road surface is in a terrible condition, even after recent 'repairs' and the national speed limit applies as soon as you go beyond the village boundary.

A bus service operates through the village but there are only six or seven buses a day and none run early or late enough to accommodate reasonable commuting, particularly to anywhere outside Rye.

Rye does have a railway station however the trains run one per hour in either direction (West to Hastings or East to Ashford). Both trains leave around the same time each hour. Unfortunately the bus from Iden arrives shortly after the trains have left resulting in a poorly connected transport service.

The result is that Iden residents have to rely heavily on their own cars.

Again, the transport infrastructure is inadequate to meet the transport needs of any additional residents unless the local authority are seeking to increase reliance on private motor vehicles.


Affordable Housing/ Community

We have seen at the proposed Conkers site (IDE0001) that developers have put forward a proposal including affordable housing but otherwise mainly unacceptable. They have then put forward a revised plan, ostensibly in response to local objections, where the affordable housing has disappeared due to 'viability' concerns. What measures are the local authority taking to ensure this doesn't happen with the proposed development site at Street Field?

Given the lack of adequate local and transport infrastructure, as well as the poor employment sustainability (see para 5.62 Proposed Rother Local Plan 2020 – 2040) any houses on the open market are more likely to be bought as second homes or let on AirBnB. There are already many of these in Iden and experience has shown that owners of such properties are less likely to engage with or contribute to the village community.


Environment

On page 47 of the Site Assessments the local authority comments

'sightlines would need to be increased by the cutting back of vegetation, and a footway provided outside the site.'

It also notes that this a historic field boundary, the effective destruction of which would surely be contrary to local authority policy.

I note also that other sites in the area have been rejected as development would entail the loss of 'rural views that are afforded eastwards [which are] important to the rural character of the village.' It is unclear how this site is any different.

In Rother's current Development and Site Allocation Plan it refers to development in Iden as follows:

There is very limited scope for development in and around the village [Iden]. There is little opportunity for infill within the development boundary. Development east of the village, where extensive views may be gained across the countryside, would encroach negatively into the wider AONB landscape. ….. (Similarly) development to the south would inappropriately extend growth along Main Street, encroaching into an area of rural character.

In light of the above, the adoption of Street Field as a potential development site appears to a contradictory and disjointed approach.


Heritage

The development of Street Field would have a direct impact on the setting of at least four listed buildings: Danesbury, Deacons, East View and Lamb's Orchard. The fact that the name of one of these (East View) references views to the east suggests any development obstructing this view would constitute significant harm to it's setting.


Existing Development Plans

The land south of Elmsmead (IDE0001) is already subject to a proposal for 12 new houses. In light of this I question the need for an additional 10 at this time.

Please see attached submission.

Please see attached:

- Representation on HELAA site PEA0034
- Site Plan - PEA0034

A number of sites in Playden have been indicated a having potential for development. I believe that Playden is entirely unsuitable for development if it`s seperation from Rye and it`s rural nature is to be maintained.
The Shellfield site in particular should not be identified as having any potential given the planning history.
Kind regards
Trevor

Representation in support of site PEA0024 in the HELAA. Supporting document attached.

I strongly oppose the designation as "HELAA potential sites" of PLA0008, PLA0012 and PLA0013. Site PLA0008 lies in the 'strategic green gap' between Rye and Playden village. Such gaps are protected under RDC, NPPF and local plans. The active Rye Neighbourhood Plan states: "To protect the profile of Rye, it is important to retain current strategic green areas as gaps between parishes, particularly with Playden, East Guldeford, Camber and Udimore".
Two recent appeal decisions by the Planning Inspectorate definitively ruled against development at 'Shellfield', the site directly adjacent to PLA0008. Local residents fought a four-year battle to save their Domesday listed village from this inappropriate application. Access to PLA0008 is poor, as it would mean disturbing a centuries-old sunken lane. Also, an adverse impact on Playden's historic character.
Site PLA0013 is unavailable. Further urban development along A268 in Playden should be resisted if village is to remain separate to Rye.

I am writing to object to the potential three sites in Playden, in particular, PLA0008.

The site in question is opposite the Shellfield site where development did not go ahead following the Planning Inspectorate's two appeal rulings regarding development in this part of Playden. This set a precedent for all the same reasons this is also unacceptable. After the long and stressful process, it seems unbelievable that Rother is proactively suggesting house building on the other side of New England Lane when as you acknowledge there is "no evidence the site is available".

This precedent was prompted by many factors including any development ignoring the strategic green gap between Rye and Playden protected by the Rye Neighbourhood Plan, disregarding the limited access to cars in the narrow top of New England Lane and the steep hill to Rye which drastically affects people's ability to walk to Rye.

Thank you.

Regarding the proposed site at the top of New England Lane, the same objections apply that applied to the Shellfield site, at the top of New England Lane directly opposite to the proposed site mentioned in the town plan.
There have been two proposals for housing on the Shellfield site, both rejected, and two appeals, both rejected. The same criteria must surely apply to the site directly opposite, namely:

The avoidance of the creeping joining of Playden (a Domesday village) to Rye, and the necessity of keeping the separation.
The lack of infrastructure required for the extra housing (drainage, utilities, refuse collection etc.)
The maintenance of Playden as an area of semi-rural openness’ (the council’s own words).
The fact that any housing will become second homes for Londoners, not affordable housing for locals.
The lack of appropriate jobs and transport in Playden and Rye.
A totally new road layout would be required to accommodate the extra traffic at the entrance to New England Lane.
And….I have always understood that development of that site has been deemed impossible because of an Iron Age fort (of historical and archeological significance) located on it.
In short, the site is totally unsuitable, and the site directly opposite has been rejected 4 times, with good reason.

Re IDE0010, Street Field, Main Street, Iden.
I previously lived in a village with very similar characteristics to Iden for over 24 years. I had no intention of moving until local developments, which I did not object to, had a negative effect on neighbouring properties. I reluctantly decided it was time to move.

I purchased my home in Iden in and particularly appreciated the open field directly behind the property, with grazing sheep and associated wildlife.

In 2022, the owners of several properties adjacent to this field were approached by estate agents acting on behalf of the non-resident owners of the field. They asked if we would consider purchasing small plots of agricultural land next to our boundaries. We had no previous intention of doing this, but did so to preserve the existing situation and try to protect against the risk of ‘increased activity’ on the land, as suggested by the agent.
I have paid out to do this and done my best to maintain the use as agricultural land with sheep grazing, the wildlife and to maintain the status quo.

There is tranquillity here, including during darkening skies in the evening. This specifically includes the view across the field (also from Main Street). This allows residents, the existing wildlife and grazing sheep to continue undisturbed, with minimal light or noise disturbance nearby.

Any development on this field would have a detrimental effect to anyone that values these qualities; this includes future residents in new local constructed dwellings elsewhere in Iden.

Ref. PLA0008 Land between Saltcote & The Steps, Playden

My previous objections to the refused Shellfield development apply in nearly every respect as site PLA0008 is almost identical in unsuitability (it is after all opposite).

In summary, there is very limited vehicle access (New England Lane is a historic single-track lane set in a hollow way), services infrastructure (in particular drainage which already fails to cope with the discharge from the existing dwellings on the lane) is totally inadequate, access to Rye town and it's amenities requires a car as public transport is limited.

I understand the need for more housing, but surely there are sites more suited to development that don't require the destruction of rural landscape?

The site and a neighbouring field provide a natural break between Broad Oak and a small number of outlying rural dwellings. Continuous ribbon development is not appropriate for a National Landscape. Two recent applications for development of this site have been dismissed on appeal as being 'inappropriate for an edge of village location'. But if the density of five houses in a slightly enlarged area is now considered satisfactory, then it should be shown accurately on the map, rather than show the complete area as having potential for development. The residential curtilage should be no further from the road than the existing houses in Whiteacres Close. Extending into the rear of the field would out of character with the settlement pattern.

1. ICK 0026 – Churchfields Industrial Estate
The ownership of this site has changed since the planning permission (RR/20/9/2850/P) for industrial use was obtained and then implemented. It now belongs to Long Rake Spar, the adjoining landowner, whose intention is to build out the planning permission and develop the units for new business tenants.

2. ICK 0040 – Land East of Churchfields, Harbour Road.
This site remains in the ownership of the adjoining landowner, Long Rake Spar. We disagree that the site should be rejected for development at this stage. It is feasible that with a sensitive design/landscape led approach, a suitable scheme can be achieved for small residential and/or commercial units. To leave the site vacant and unused would be a waste.

3. Rye 0002 – Winchelsea Road East
The central section of this allocation is now in one ownership and therefore the ability to bring forward development in the Local Plan timeframe is feasible. The flexibility of uses is helpful, as the site lends itself to a mixed-use scheme. Therefore, the residential unit numbers of ‘at least 10’ and ‘estimate 500 sqm of employment use’ should be considered as a minimum at this stage given the site’s sustainable location.

Site Rye 0040 – Slade Yard/Hoop Yard

The allocation of the site for a “residential led /mixed use” scheme is welcome and the acknowledgement that this site alone could accommodate “around 30 dwellings”. In fact, we can demonstrate that the site could deliver 40 of the smaller, more affordable units. This would help meet the demand in Rye for smaller, more affordable units for local people in accordance with Policy H2 of the Rye Neighbourhood Plan. However, for the foreseeable future the site will continue in employment use. Given the site’s sustainable location, it is also suitable for other commercial uses to meet demand in Rye, such as for small business units (Class E) or a hotel as well as care/retirement homes. These alternatives should therefore be identified as possible development scenarios for this site as well as residential.

regarding PLA0008 I'm concerned the sites are inappropriate for potential development. The area has historical significance, the village of Playden would become a suburb of Rye. Developing here would conflict the council's own policy on strategic green gaps. Its already proven unsuitable for development and shouldn't continue to be encouraged

PLA0008
I’m appalled that this site is considered for any development other than growing much needed food produce. This is Playden, a historical village which is in danger of being an extension of Rye. With development having been allowed with housing, Hospital and Doctor Surgery on the opposite side of the A268 of Playden there is no way taking any green space left on the opposite side is anything but catastrophic.

*RDC is ignoring its own policy on strategic green gaps, suggesting PLA0008 has development potential, in turn, ignoring the Planning Inspectorate’s two appeal rulings regarding development in this part of Playden (Sheffield)

* The site in question lies in the strategic green gap between Rye and Playden. Without this gap between Rye and historic Playden, the village simply becomes a suburb of Rye. Rye Neighbourhood Plan quotes: "To protect the profile of Rye, it’s important to retain current strategic green areas as gaps between parishes”.

* Playden is an historic Domesday village and New England Lane is an ancient sunken "holloway" many hundreds of years old. Any proposed development would irreversibly harm the area’s character.

*The Council appears to be ignoring the long and stressful campaign local people endured to protect their village from unwanted development and desecration of historic land.

We urge PPC to convene a meeting with residents.

Response from secretary on behalf of Co-Chairs

Comments in support of HELAA site PEA0035

A representation statement has been submitted as part of this consultation and is appended to this consultation form.

Please see attached:

- Representation on HELAA site PEA0035

Representation on HELAA site RYE0003

Site ID RYE 0003 within the HELAA states that the site is almost entirely within Flood Zone 3. As part of the preparation of planning applications RR/2024/949/P & RR/2024/960/P & RR/2024/976/P, extensive flood modeling has been undertaken.

The modeling has confirmed that the site is in tidal / fluvial Flood Zone 3A, according to the Environment Agency’s fluvial modelled flood data and confirmed by JBA’s (Flood Risk Consultant's) model. It benefits from tidal flood defences (in reasonably good condition currently), which protect it in all tidal scenarios – including the 1 in 200yrs storm + climate change. The lowest parts are liable to flood in the event of a breach/overtopping of the tidal defences.
The flood risk assessment submitted for the current live planning applications demonstrate that the Flood Zone is not a impediment for developing on the site.

We welcome the Council's acceptance that the site could accommodate more development, above the existing thresholds of Policy H6 of the Rye Neighbourhood Plan. However, as increase in 15 additional dwellings does not go far enough. As demonstrated by the current live planning applications (RR/2024/949/P & RR/2024/960/P & RR/2024/976/P), RYE 0003 is able to accommodate at least 16no. dwellings, 44no. retirement living apartments and 1863sqm of class E commercial space. We also request that greater flexibility is given within the policy to "employment space" to include Class E and to increase the flexibility on residential typology.


Appendix A - LSE Screening of Potential Development Sites:

The "brief" summary of the development proposals is below the yield of what is currently being proposed under live planning applications RR/2024/949/P & RR/2024/960/P & RR/2024/976/P which propose 16no. dwellings, 44no. retirement living apartments and 1863sqm of class E commercial space. These yields should be screened for accordingly.


The screening outcome states that the development will have a likely significant effect as the site is located within 200m of Dungeness, Romney Marsh & Rye Bay SPA/Ramsar. The screening outcome states that surface water discharge pathways can reach for several hundred metres. Therefore, it is not possible to say that the development would not have likely significant effects on the SPA/Ramsar site. Nonetheless, the outcome of the HRA does accept that this judgement is made prior to the consideration of any mitigation measures devised for the site.

With this in mind under the current planning applications RR/2024/949/P & RR/2024/960/P & RR/2024/976/P it has been confirmed that the proposed surface water drainage system has an appropriate level of pollution/runoff treatment in accordance with the CIRIA SUDS manual 753. The proposed surface water solution for the proposed development is a huge betterment on the existing, as the surface water from the site is currently untreated and flows into the combined sewer and some areas just run off untreated to the ditch which forms the south-western boundary of the site.

It also must be recognised that the protected site (Dungeness, Romney Marsh & Rye Bay SPA/Ramsar) are a significant distance away and on the other side of A259 further mitigating any potential effect.

This betterment to the surface water drainage for the site demonstrates that there will not be a likely significant effect on the protected sites.

We request that the above mitigation measures are factored into the Council's HRA document.

Please see attached comments in support of HELAA site BRE0002, and objecting to Proposed Policy GTC8: Biodiversity Net Gain.

Full submission attached.

See attached documents which comprise the submission:
- Reps- Oak Tree Homes Trust final 2207 (which includes appendices 1-3); and
- 4019_Technical Note_Pond Cottage Main Street Peasmarsh_May24 (Appendix 4).

Submission containing representations that include the following matters:

Promotion of HELAA site BEC0025 - Land West of Royal Oak Close, Beckley

Housing Need

Proposed Strategy: Overall Spatial Development Strategy

Vision for Rye & Eastern Settlements

Proposed Policy DEV3: Development Boundaries

For comments on the Spatial Development Strategy including overall housing provision, please see paragraphs 3 - 6 in the attached Main Submission Document. The representation is registered under Q54 in the Regulation 18 draft Local Plan.

For comments on proposed Policy HOU9, please see paragraph 7 of the attached Main Submission Document.

For comments in support of PEA0039, please see paragraphs 8 to 18 of the attached Main Submission Document.

Attached documents:
- Main Submission Document (including appendices)
- Technical Note: Surface Water Flood Risk