Regarding BX19: I don't consider the statement that there is ample on-street parking to be a fair one. Whilst I agree there is ample on-street parking at the current time with the public car park being in use, closure of the car park would have a significant impact locally. The car park is not always completely full, but it is certainly well used with the majority of spaces being occupied during the working day. At the same time, the available on-street parking on Cooden Sea Drive from the station north to the vehicular entrance to the golf course is almost always fully utilised throughout the day and there are often also a number of cars parked on The Gorses opposite the green space adjoining the car park. At times when the parking opposite the station has been unavailable to the public (not uncommon due to the electricity and Southern Water utilities located by the public conveniences - tankers were there for weeks last winter) resulting in additional cars parked along The Gorses, this has made it problematic for drivers using The Gorses as the curve in the road makes it difficult to see if there is on-coming traffic. Loss of the car park would create that situation and it would be worse still when parking opposite the station is not available. Please can this be properly assessed before any decision is made so that the safety of drivers is not compromised.

It is critical that adequate green space and sports provision is provided for the community and that this is of a good quality. One issue to take into account when assessing the provision to be made for outdoor sports pitches with reference to the current playing pitch strategy which identifies a deficit in provision is that the increasingly wet winters are reducing the scope for football to be played on grass pitches throughout the winter and early spring. Consideration should perhaps therefore be given to the feasibility and benefit of providing all weather surfaces where there is scope for such provision to be managed by the community/club/management organisation etc.

BX13 - Eversley Road car park shiuld not be lost to development, there is a major lack of parking facilities in the town. Loss of parking means the loss of shoppers who are prepared to cruise around endlessly looking for a parking space and further closure of shop units due to lack of footfall. The Town Centre is dying already from ESCC parking;policies. the Councils should be trying to regenerate it, not close it.

BX7 - Sainsburys development is impractical. It shows the car park for development which would lose the only miod size supermat]rket in Bexhill. Building 75 flats on the roof is crazy, there is all the supermarket equipment and it is unluikeelly the existing structure could take the load.
BX20 to 28 - Provision should be made for a A259 bypass around Little Common, the area is currently congested and will become more so with the proposed housing. If a route is not integrated for a bypass there will be no space for it in the future.

Qu. 17 Bexhill Urban area.

I see you are mostly using a hard site, except Land West of pages Lane. I hope the infrestructure will cope! Why are you building ON Eversley Rd Car park. which is used by shops etc. and why is Cooden Beach station car park going to be built ON. and used by many train users, will this discourage people using trains and driving to their destination. Or parking the roads.

Qu. 23. West Bexhill
So many houses to be built. I hear that due to Heavy rainfall the Sewers are backfilling into the houses in this area. the use of greenfields, to build ON is sad. all these houses, and the traffic to come on to the A259. which is already very busy & congested at different times of the day. So can this road cope with more!

Building on Northeye. Is it safe for people to live & garden on when the aspestos is removed?

Qu. 24 North Bexhill
Lunsford Cross. This is traffic is to come out on to Ninfield Road which is a very busy road. If there is as accident in Barnhorn Road the traffic is diverted through country Lanes to Ninfield Road. So many houses to be built on greenfields. Lovely county side. Handy these roads will not cope with all this extra traffic. The interstucture, as explained at the beging is just not there ALSO give respect to many different

Species of WILD Life, Insects and trees and plants. As we share our wonderful Planet.

Dear BEXHILL will never be the Same. Why build on Sidley Car Park. used By shoppers & visitors, carpark off busy road. No Street Parking.

Qu.1 Rother Local PLAN as this covers a very large area. Take notice of the people who live in this area.

Qu.5 THE Infrestructure of all these into areas, will have to be looked before houses are built! eg. water which is already a great problem to surply especially when the reservoirs are low. So more houses a real problam!

THE Sewer's old and new. Can the treatment plants cope!
The roads, how will they stay safe & maintained as there are many potholes already. plus this area has many county Lanes, not suitable for the heavey building Lorries! with all these extra people. how are the hospitals, Conquest, Bexhill and EASTBOURNE going to cope?

There is already a great shortage of Doctors & Dentist more people will make things worse.

See attached letter responding to questions 7, 8, 10, 12, 17, 19, 20, 21, 22, 36, 48 and 69.

To the Planning Strategy Team,

I am writing to submit my formal objection to the proposed Rother Local Plan 2025–2042. As a resident of Sidley, I am deeply concerned that the current proposals represent an unsustainable level of growth that will irreparably damage the historic character, landscape integrity, and infrastructure of our village, as well as potential future damage to my own property (address North Road, Bexhill).

My specific objections, relating to BX41, are outlined below:

This current green space is a hive of nature, including some protected species, which is enjoyed and appreciated by local residents despite the lack of public access to this site.

My property backs onto this green space and during winter months we already have issues in our rear gardens with flooding and water ingress, so any building or concreting over of this green space would cause significant and long term damage to existing properties, especially those down slope from the site. Historically there was a large pong at the bottom of North Road which would have acted as a sustainable drainage system, but this has already been filled in and built upon, hence current drainage issues. In fact only a couple of months ago the street itself flooded and was in places impassable due to flooding after rain water drains were overwhelmed. This will only happen more often.

With huge amounts of green space already being built on, or proposed, we will soon lack green spaces but also Sidley risks losing it's village feel.

The air-polluting traffic and the unreliable bus service, and distance from the train station mean that most residents will be reliant on car usage for their travel needs. Many of the local roads are simply not coping now, without the possibility of such a high increase in road users.
Both Southern Water and East Sussex Water have publicly stated they cannot cope and this will cause future issues. I am aware they are appealing to the government to become statutory consultees at the planning stage to try to address this.

School places in most years are in very short supply. All Saints Primary School is are capacity with no room to expand and Bexhill Academy is almost at capacity. In fact my own children were sent to secondary school in Hastings as there was not enough space and Bexhill Academy.
My specific objections, relating to BX50, are outlined below:
I run a youth club on Ninfield road for vulnerable young people and losing any amount of parking in Sidley will have a massive impact on these children accessing our venue. Many of these young people have special educational needs or disabilities and require parking to be close by to minimise walking or to avoid the risk of running, particularly those with autism or other disability. Families found it particularly difficult to access our venue with the recent roadworks shutting off or limiting traffic up and down Ninfield Road.

I'm am sure equally that other businesses and the local primary school will also suffer greatly.

The Council must reconsider this scale of development, not just in North Bexhill but across the district. Our natural landscape and historic heritage should be protected for future generations, not compromised by unsustainable housing targets. I urge the Council to remove sites BX41 and BX50 from the Local Plan.

To the Planning Strategy Team,
I am writing to submit my formal objection to the proposed Rother Local Plan 2025–2042, on behalf of local environmenal education charity Community Supporters.
We are deeply concerned that the current proposals includes area labelled BX15.

Our specific objections, referenced by the relevant consultation questions, are outlined below:

Most importantly, in 2022 Community Supporters submitted an application business plan to Rother District Council, as per the councils request, to outline taking on a long term lease on this plot of land and some neighbouring land to protect it from development and to maintain and enhance the biodiversity by creating a conservation area and outdoor education space - open to the public. So we are deeply concerned that this project and need to protect this land from development is now at risk.

This are is one of very few natural green corridors and is a haven for wild flora and fauna. Community Supporters commissioned a Preliminary Ecological Appraisal as part of our submitted business plan which outlined how the land could be improved for biodiversity and showed there was evidence of ecologically important and protect wildlife using this land.

We also strongly object to the proposed housing targets. The move to a “standard method” calculation of 912 units per year — a threefold increase over previous targets — is fundamentally incompatible with a district where 83% of the land is protected within the High Weald National Landscape.

The plan fails to demonstrate how Rother’s infrastructure, which is already under significant pressure, can accommodate this increase. GP surgeries, schools, and our narrow historic road network are not equipped to support this level of growth. The Council should prioritise a lower, locally derived target that reflects the constraints of our protected landscape, in line with national planning policy.

The strategy to focus growth contradicts the Council’s duty to conserve and enhance natural beauty, plus the fact Rother District Council has in 2019 declared a Climate emergency and more recently in December 2025 declared a Nature emergency. While the plan refers to prioritising brownfield land, the proposed allocations rely heavily on greenfield development.

The Council must reconsider this scale of development. Our natural landscape and historic heritage should be protected for future generations, not compromised by unsustainable housing targets. I urge the Council to remove site BX15 from the Local Plan.

Thank you

I object to proposals below.

Bx20, bx21, bx21, bx26, bx26,

I live 0.6 miles from little common primary school and yet my son can not have a place at the school because it's full
I also regularly spend an extra 10 minutes each way moving just half a mile along Barnhorn rd due to the extra traffic caused by the recent developments north of that road and the new traffic lights. This part of Bexhill has more than played it's part in providing new homes for the country why doesn't the council tell the developers where they can build rather than the other way around.

I object strongly to the following proposals.
BX20
BX21
BX22
BX24
BX26
BX27
BX28

I live on Barnhorn rd and the previous construction of houses etc nearby in recent years has already impacted my and my families quality of life. I can now never open my widows even in summer due to the noise and pollution. Dust appears constantly within 24 hours of my dusting. Large vehicles make an incredibly amount of noise even in the early hours of the night. I also worry the pollution. It is a known fact that living on a busy road has been proven to shorten the life of residents.

RE: Objection to Proposed developments BX20, BX21, BX22, BX23, BX24, BX26 and BX27

To the Planning Team

I am writing to formally object to the above proposals. We have lived at 93A Barnhorn Road for 5 years and am familiar with these sites and surroundings.

I wish to object to all proposals on the following grounds:
Impact on Residential Amenity: Proposals would lead to a significant loss of privacy and overlooking of my [garden/living room]. Its scale and proximity would also cause overshadowing, resulting in a loss of natural daylight to my property.

• Character of the Area: The design and density of the development are out of character with the surrounding neighborhood, which is primarily [e.g., low-density Victorian housing].

• Highway Safety and Traffic: These developments would generate a substantial increase in traffic in the local area and particularly on Barnhorn Road, which is already frequently congested and the ability to drive out of our property often takes many minutes due to the volume of existing traffic.

• Greenfield sites: all of these proposed developments are on Greenfield sites. We oppose the devastating development of these sites which historically were for farming. A more appropriate use of the land would be for farming activities to be resumed, particularly given the financial and environmental impact of the UK importing food to sustain our national needs.

• Natural habitats: the creation of hundreds of new dwellings clearly would destroy the natural habitat of many rare creatures including Fen Raft Spiders, Freshwater molluscs, Great Silver Water Beetles and rare snails including Little Whirlpool Ram’s-horn snails and Shining Ram’s-horn snails. The habitats that survive there are incredible and should be protected for future generations. You will be aware that these proposed sites are close to the Pevensey Levels which are a major wetland area and a Site of Special Scientific Interest (SSSI) famous for rare aquatic life and bird populations. The habitat is characterized by low-lying grazing marshes and a complex network of freshwater drainage ditches. Clearly run off from these additional houses will contaminate the freshwater supplies these animals depend on.

• Historic trees: there are several mature trees on the sites that appear to have been there for many years. We would not be confident that a developer could be trusted to not destroy these wonderful tress. The existing development from Spindlewood Drive has already seen several beautiful fields and meadows irretrievably destroyed.

• Drainage: it is clear to see that when walking on the public footpaths throughout the year that the area is susceptible to flooding and is not an appropriate site for hundreds of new dwellings.

• Sewerage: you will see from the water companies records that our home and neighbouring properties have a history of sewage problems from the dated soil pipe running down Barnhorn Road, often resulting in raw sewage backing up onto the front of our property. Addition dwellings will only make this situation worse.

In summary, we believe the proposals are inappropriate development that will harm the local area. I urge the council to refuse the named proposals.

Please acknowledge receipt of this letter and keep me informed of any committee dates or final decisions.

We wish to object to the proposed development of the land south of Barnhorn Road, Bexhill (Reference: BX22). We request that BX22 be removed from the draft plan for the following reasons:

1. Water stress — The Environment Agency designates this area as “serious water stressed” (since 2013) and it remains so. Additional housing will increase demand on an already constrained supply.

2. Sewage capacity — The sewerage system serving Barnhorn Road and Little Common was installed in the 1950s. Pipes are only 9 inches (23 cm) in diameter, have not been upgraded, and are frequently operating at or near capacity.

3. Pumping requirement — The BX22 site lies below the main sewer pipe on Barnhorn Road and would require a new pumping station to service the site, adding cost, risk, and disruption.

4. Traffic and air quality — Barnhorn Road (A259) is already heavily congested with daily bottlenecks of slow moving traffic to the Little common roundabout from the west. The Policy text requires vehicular access from Barnhorn Road; any new junctions, traffic signals, or roundabouts for the BX22 site will worsen congestion, increase journey times, and raise traffic-related pollution for local residents.

5. Surface water, flooding, and ecology — The BX22 site slopes and will drain towards the Pevensey Levels (Hydrological Catchment), a SSSI/SAC/Ramsar site. Urban runoff from development would increase flood risk and harm sensitive habitats unless stringent mitigation (for example a three-stage treatment system as required by policy ENV2) is provided.

For these reasons — water stress, inadequate sewage infrastructure, increased traffic/congestion and pollution, and significant flood and ecological risk — we object to the allocation of site BX22 and ask that it be removed from the draft plan.

Please find attached the representation from Sussex Butterfly Conservation (BC) on the above consultation. Butterfly Conservation is the UK charity dedicated to saving butterflies, moths and our natural environment. We are a world-leading authority on the conservation of these beautiful and vital creatures. Sussex BC is a member of the Sussex Local Nature Partnership and has recently made comments on the draft Sussex Local Nature Recovery Strategy.

I wish to register my opposition to the draft local plan.

While I appreciate the challenges of any development in those parts of Rother that are in the AONB, the emphasis upon West Bexhill is unfair and unjustified. I endorse what the plan itself says about the perils of further development adjacent to the Pevensey Levels and the traffic impact upon the already heavily congested A259. I would add that pressure upon other infrastructure - from water supply and sewage to schools and medical care - is also close to breaking point. West Bexhill is simply not designed to become what you term a Growth Area.

Of the sites listed, it is most difficult to challenge BX28 as it is a brownfield site that has had relatively little use since closing as a prison many years ago, and is already in the hands of the Government's housing and regeneration agency, Homes England. Nevertheless, the residents of some 384 new dwellings would in themselves generate huge demands upon local services.

I particularly, object to sites BX20, BX22 and BX27.

I urge you to think again.

I object to BX20 & BX21 on the draft plan, there is not enough infrastructure in the area. Access here is dangerous and traffic is getting worse on Barnhorn Road already. Development here is greedy and will put unnecessary strain on local services, traffic, roads, schools, health care and emergency services.

This has not been built on for hundreds of years for a reason, the levels will be at risk of pollution as it is on the side of a hill and any pollutants will wash down into the levels. Just look at what happens at Cooden Beach Station when the pumping station breaks down.

The effect on wildlife here would be devastating.

Having lived in Bexhill for the past 26 years, my family have seen many changes, some for the better others not so.
But we have always felt that Bexhill was a quieter East Sussex town, but this is rapidly changing, for the worse.
More housing, more people, less employment opportunities, more traffic congestion.
The roads are poorly maintained, GP surgeries are at breaking point, school places are constantly under pressure, the sewage system can't cope if it rains, and we now seem to have a hosepipe ban every year from the summer through to the middle of winter.
Surely until all of these well documented issues are resolved building over a thousand new properties is complete madness.
I hope the planning department takes notice of public opinion and say NO to some if not all the proposed development outlined in the local draft plan.
Please protect Bexhill - On Sea from becoming an urban sprawl, one the land has gone, it's gone forever.

RDC has formally sought views upon the Draft Local Plan. The comments below represent my response to this invitation.

A/ THE DRAFT PLAN. (the Plan):
The Plan lacks ambition,
Repeats the errors and failings of the existing and previous Local Plans,
Is discordant with its failure to adopt an "infrastructure first" approach to new development
is short sighted in its allocation of possible housing sites
1/ The RDC "State of the District" (SD) report 2025 sets out clearly why an ambitious Plan is required. RDC is ranked 135 out of 317 English local authorities (1 being highest) with higher percentages than the local average claiming a range of welfare benefits. Though employment is generally above regional and national averages, gross median pay is substantially lower at £31k compared with England's average of £38k. Significantly this negative gap of 17.5% is increasing. Employment is dominated by small and micro-businesses with businesses employing more than 250 people comprising just 0.02% of total businesses in the District. (sources: RDC State of the District report). There are correlations arising from this data supplemented by the facts that working age people in the District have lower than national average degree level education (38% v 43% in England) (source:SD). With the District's working age population being 51% of the whole, those under 16 comprising 17% and, significantly, and growing, those over 65 representing 33%, and with the employment and income profiles set out above, it should be a clear objective of the Plan show intent to improve both economic and social facets across Rother. As drafted the Plan demonstrates no such intent or ambition.

2/ The draft Plan repeats much of what has been seen in previous Local Plans but which has demonstrably failed to be the economic drivers expected of them. The number of existing, but undeveloped, "Enterprise Park" sites is testimony to this failure, but the draft Plan simply repeats them. Unless a much more radical approach is adopted future RDC "State of the District" reports will show a greater, and accelerating decline of weekly earnings compared with the national average, increasing demands for welfare benefits and a continuing exodus of higher educated working age people to other areas where their aspirations can be achieved. The "gap" is likely to be filled by more people of pensionable age with their consequent demands on the NHS and other age related benefit services.

3/ The draft Plan sets out no clear and practical approach to the provision of the infrastructure necessary for the successful and sustainable development of the sites allocated within it. Specifically, the District has a woeful primary road network comprising a discordant and fragmented series of routeways connecting to the principle east west and northerly Strategic Roads (the A259 and the A21). There is no defined "northern bypass" avoiding the urban areas for through traffic, the vestigial Link Road joins the A259 within Bexhill town and the Sidley bypass arm peters out on the Battle Road. The A259 is already noted as being over capacity. The Draft Plan refers to the Jacobs Study of three possible "extensions" to the Link road, yet none offer the correct solution. Clarity is needed about the purpose of any western extension of the Sidley bypass or an alternative route connecting to the A259 west of Bexhill with equal clarity about where such a road needs to connect to the north and west of that town. It is further noted that the Plan repeats suggestions from the current Local Plan suggesting improvements to Little Common roundabout. Such improvements are not specified. However, Little Common roundabout has already been subject to very limited modifications as a result of planning consents recently granted. It is noted that any further changes will be very difficult to accomplish. Not only do neither National Highways, nor East Sussex County Council (Highways) own or control much of the surrounding paved areas alongside the public footpaths (they are private forecourt spaces), but the roundabout itself is elongated with four points of entry onto tight turning circumference. Dual lane traffic movement is highly restricted, and impossible when articulated vehicles are maneuvering. With shops, a pub, a bus stop and other built features bordering the roundabout site it is quite unclear what, if any, changes can now be made. Moreover, were these to be possible, the question must be asked ; "why have they not been carried out already?"
The draft Plan assumes foul and drinking water facilities will be available or will be provided at some, indeterminate future date. This is disingenuous and flies in the face of reality. The many problems across the water industry have been well documented and RDC has experienced the failings of our local suppliers, Southern Water and South East Water, to manage their businesses in the ways we should all expect. This said, it is noted that RDC expects new developments to be approved only where connections to foul water systems "with adequate capacity" already exist. This vital caveat is crucial to decision taking about any planning applications for those sites. Officers must hold fast to their principles on this point, and it would not be appropriate for them to deflect this issue of system capacity by simply defaulting to the Water Industry Act which enables developers to hold a statutory right to connect to drainage systems. A right to connect is not the same as a right to connect to a system with adequate capacity. Accordingly, it is suggested that the RDC condition of adequate capacity should be more strongly worded to avoid any misunderstandings.
The assessment under point 1 above points to increasing pressure upon the already pressurised NHS, schools and other social services in the District. Again, despite an intent to build a considerable number of new homes in the District, mostly in Bexhill, no commitments are provided about the provision of the essential support services that will be required.
The Draft Plan fails to offer an "infrastructure fist" programme, or, even an "infrastructure and development integrated" programme to ensure essential services are provided contemporaneous with housing and other development. Without such committed and funded programmes, intolerable burdens will be imposed on already well overstretched social services.

4/ In housing development terms the District is constrained by its geography and topography. The coastline, wetlands to the east and west and the National Landscape (AoNB) to the north impose a range of specific challenges if housing sites are to be allocated as required by central Government. The draft Plan continues the historic approach of allocating the majority of new housing around Bexhill (Ref: the Emerging Local Plan site allocations). The small towns and villages within the National Landscape designated area make a contribution to the whole but this is relatively small in aggregate terms. I will make some specific comments about the allocations in the Bexhill West Growth area below but note here that in the Plan sites in Bexhill are allocated to the north and west of the town. Crucially, the Plan observes that the main reason for this is that the protected wetlands of the Glynde valley dividing Bexhill from St. Leonards precludes further development in that area. The Pevensey Levels to the west of Bexhill provide an equally inviolate buffer from development to the west of the town. The site allocations in the draft plan to the west of Bexhill (BX 20 to BX28) for 1923 new homes, should they all be approved, would leave no further land available for development west of Bexhill. This would be equally true should not all the sites be approved for development. Either way, RDC would have only one remaining direction for alternative site allocation within this Plan or for, what might be called, the next round of site requirements looking beyond the current allocations. The only way any such further sites can be found must be by allowing some form of development in larger volumes within the National Landscape (NL). Such proposals would, necessarily, have to be very carefully assessed and considered within the context of NL limitations. I venture that a large number of village/small town extensions for housing development of volume would not be appropriate. I propose that the alternative of a new large village or small town concept, integrating homes, schools, shops,employment and health services and connected to rail and road networks would be preferable. The simultaneous provision of these forms of infrastructure would be essential for the successful creation of a vibrant, sustainable new community which could be focussed towards upwards of 6,000 new homes. Choosing a site for such a new community would need research, but, given the restrictions already outlined above on future development near Bexhill, the draft Plan should include proposals to bring forward a new community proposition as soon as possible. In this way the many and various important studies required to create a truly integrated, planned and funded master plan for the chosen site can be undertaken in a properly project managed way, avoiding the crisis managed approach that would become necessary if action is delayed. My own research has identified a possible site. This is in the valley to the south of Robertsbridge. Ready access to the railway and A21 would be available, the new community could be connected to and enhance Robertsbridge without imposing on the historic heart of that town and, visually, the new community would be relatively hidden from view (limited views mostly from the A21 Robertsbridge bypass). The visually more open area of the "high" National Landscape area would be untouched.
I do not believe RDC can defer action to include this form of proposal from inclusion in the draft Plan. Were it to do so, it would be abdication responsibility for an action that will inevitably be required. Not to start now will make decisions later much, much harder with delivery of resultant development deferred into the far distance. Starting now, offers the prospect of the start of delivery within the draft Plan horizon, with various agencies, (highways, water, health, education) being able to simultaneously plan, budget and fund their contributions to the integrated whole.

B/ HOUSING SITE ALLOCATION - WEST BEXHILL:
Ref: Rother Local Plan 2025-2042 - Development Strategy and Site Allocations. Part 4 - Site Allocations. section 7 - Site Allocations.)

BX19; I object to the removal of this public car park which enables folk to enjoy the coastline at Cooden Beach, where, in summer especially, parking close to the beach is a valuable asset for families. Parking distances away, on public roads, is a burden on families who will have buggies and beach equipment to manage.

BX20: This site is already subject to lengthy debate and assessment. Despite an Outline planning consent having been granted, the developers have failed so far to produce acceptable proposals for a highway connection to the A259 ( Barnhorn Road), surface water drainage and ecological objections. Indeed their most recent drainage ideas were seriously retrograde and did not comply with earlier principles. It is noteworthy that these issues were first raised as concerns by objectors to the RDC DaSA some 9 years' ago. It remains very unclear if this development can proceed.

BX21: This site would become an extension to the development of BX20. As such it would result in an increase in traffic accessing Barnhorn Road for the intended junction. However, this junction is not yet capable of meeting the National Highways requirements of the Design Manual for Roads and Bridges within the BX20 planning application process so it is impossible to see how this site can be allocated . National Highways has previously stated that the maximum number of houses it would accept having access via the Barnhorn Road junction under BX20 was 160 (ex the caravan site). The inclusion of BX19 takes this above that threshold.

BX22: this allocated site has no point of access to the A259, Barnhorn Road, identified. As such, and given that access cannot be via the BX20 access point for reasons of traffic volume and non-compliance with the Design Manual for Roads and Bridges, it is difficult to see how this site could possibly be treated as "deliverable". It is clearly not deliverable without an access point. RDC should be clear about where this will be or remove this site from the allocation.

BX24, BX26 and BX27: These three sites are taken together as my comments are common to each of them. Fundamentally the access of these sites onto the A259 Barnhorn Road, create grounds for deep uncertainty about the deliverability of the sites for development. The use of Coneybarrow Lane is denied and the Barnhorn Road in the vicinity of the potential alternative access points, topographically difficult, subject to sight line restrictions because of road curves and existing side road/cul;-de-sac access points. National Highways will require compliance with the Design Manual for Roads and Bridges if it is to accept further junctions onto this busy and overcapacity Strategic National Highway. It is hard to see them accepting these proposals.

Generally - BX20 to BX 28:
These sites continue the RDC approach of allocating sites in an unplanned way. Each is regarded individually with no declared master plan for the housing development or any supporting infrastructure (of which there is little). The result is a series of incoherent individual housing neighbourhoods (BX23 excepted) - very far from placemaking and lacking in any form of collective community.
Beyond this, when considering the traffic impacts, effects on the protections of the Pevensey Levels and drainage intentions, it is necessary to look at the potential cumulative impacts. No mention of these is made in the Plan, yet it is already known that National Highways has safety and traffic volume concerns about the A259 from Pevensey Roundabout into central Bexhill. The site allocation proposals will exacerbate these, already unacceptable highways concerns.
Foul water disposal is a further area of concern. The existing sewer in Barnhorn road is too small - even before the current Rosewood Park development was approved, with resultant foul water flooding a frequent event (if mainly in winter). Southern Water acknowledges that it has no plan in the pipeline to fund and commission any upgrades to the system so adding up to 1900 extra houses will exaggerate the current pollution problem. This cannot be allowed to happen - and, again, the cumulative impact of the proposals must be the starting point for assessment of future drainage requirements if foul flooding is to be avoided. At the minimum a clear, defined upgrade plan, costed, funded and programmed, must be in place before any planning approvals are granted for these sites, noting again the condition of adequate foul water capacity listed in the Plan details for each site.
Strict protections for the Pevensey Levels must be ensured with cumulative impacts central to decisions taken. It is noted that each site specifies the need to ensure compliance with the Habitats Regulations.

Finally, the risk that some of these sites may not be developable reinforces the strategic proposition I set out in point A/ para 4 above. If RDC cannot progress with any of these sites, or those elsewhere in the draft Plan, it will be forced to look in the designated National Landscape for volume sites. I urge that it does so now and incorporates a proposal into the next iteration of the draft Plan.

I commend these comments to you.
Yours

RDC has formally sought views upon the Draft Local Plan. The comments below represent my response to this invitation.

A/ THE DRAFT PLAN. (the Plan):
The Plan lacks ambition,
Repeats the errors and failings of the existing and previous Local Plans,
Is discordant with its failure to adopt an "infrastructure first" approach to new development
is short sighted in its allocation of possible housing sites
1/ The RDC "State of the District" (SD) report 2025 sets out clearly why an ambitious Plan is required. RDC is ranked 135 out of 317 English local authorities (1 being highest) with higher percentages than the local average claiming a range of welfare benefits. Though employment is generally above regional and national averages, gross median pay is substantially lower at £31k compared with England's average of £38k. Significantly this negative gap of 17.5% is increasing. Employment is dominated by small and micro-businesses with businesses employing more than 250 people comprising just 0.02% of total businesses in the District. (sources: RDC State of the District report). There are correlations arising from this data supplemented by the facts that working age people in the District have lower than national average degree level education (38% v 43% in England) (source:SD). With the District's working age population being 51% of the whole, those under 16 comprising 17% and, significantly, and growing, those over 65 representing 33%, and with the employment and income profiles set out above, it should be a clear objective of the Plan show intent to improve both economic and social facets across Rother. As drafted the Plan demonstrates no such intent or ambition.

2/ The draft Plan repeats much of what has been seen in previous Local Plans but which has demonstrably failed to be the economic drivers expected of them. The number of existing, but undeveloped, "Enterprise Park" sites is testimony to this failure, but the draft Plan simply repeats them. Unless a much more radical approach is adopted future RDC "State of the District" reports will show a greater, and accelerating decline of weekly earnings compared with the national average, increasing demands for welfare benefits and a continuing exodus of higher educated working age people to other areas where their aspirations can be achieved. The "gap" is likely to be filled by more people of pensionable age with their consequent demands on the NHS and other age related benefit services.

3/ The draft Plan sets out no clear and practical approach to the provision of the infrastructure necessary for the successful and sustainable development of the sites allocated within it. Specifically, the District has a woeful primary road network comprising a discordant and fragmented series of routeways connecting to the principle east west and northerly Strategic Roads (the A259 and the A21). There is no defined "northern bypass" avoiding the urban areas for through traffic, the vestigial Link Road joins the A259 within Bexhill town and the Sidley bypass arm peters out on the Battle Road. The A259 is already noted as being over capacity. The Draft Plan refers to the Jacobs Study of three possible "extensions" to the Link road, yet none offer the correct solution. Clarity is needed about the purpose of any western extension of the Sidley bypass or an alternative route connecting to the A259 west of Bexhill with equal clarity about where such a road needs to connect to the north and west of that town. It is further noted that the Plan repeats suggestions from the current Local Plan suggesting improvements to Little Common roundabout. Such improvements are not specified. However, Little Common roundabout has already been subject to very limited modifications as a result of planning consents recently granted. It is noted that any further changes will be very difficult to accomplish. Not only do neither National Highways, nor East Sussex County Council (Highways) own or control much of the surrounding paved areas alongside the public footpaths (they are private forecourt spaces), but the roundabout itself is elongated with four points of entry onto tight turning circumference. Dual lane traffic movement is highly restricted, and impossible when articulated vehicles are maneuvering. With shops, a pub, a bus stop and other built features bordering the roundabout site it is quite unclear what, if any, changes can now be made. Moreover, were these to be possible, the question must be asked ; "why have they not been carried out already?"
The draft Plan assumes foul and drinking water facilities will be available or will be provided at some, indeterminate future date. This is disingenuous and flies in the face of reality. The many problems across the water industry have been well documented and RDC has experienced the failings of our local suppliers, Southern Water and South East Water, to manage their businesses in the ways we should all expect. This said, it is noted that RDC expects new developments to be approved only where connections to foul water systems "with adequate capacity" already exist. This vital caveat is crucial to decision taking about any planning applications for those sites. Officers must hold fast to their principles on this point, and it would not be appropriate for them to deflect this issue of system capacity by simply defaulting to the Water Industry Act which enables developers to hold a statutory right to connect to drainage systems. A right to connect is not the same as a right to connect to a system with adequate capacity. Accordingly, it is suggested that the RDC condition of adequate capacity should be more strongly worded to avoid any misunderstandings.
The assessment under point 1 above points to increasing pressure upon the already pressurised NHS, schools and other social services in the District. Again, despite an intent to build a considerable number of new homes in the District, mostly in Bexhill, no commitments are provided about the provision of the essential support services that will be required.
The Draft Plan fails to offer an "infrastructure fist" programme, or, even an "infrastructure and development integrated" programme to ensure essential services are provided contemporaneous with housing and other development. Without such committed and funded programmes, intolerable burdens will be imposed on already well overstretched social services.

4/ In housing development terms the District is constrained by its geography and topography. The coastline, wetlands to the east and west and the National Landscape (AoNB) to the north impose a range of specific challenges if housing sites are to be allocated as required by central Government. The draft Plan continues the historic approach of allocating the majority of new housing around Bexhill (Ref: the Emerging Local Plan site allocations). The small towns and villages within the National Landscape designated area make a contribution to the whole but this is relatively small in aggregate terms. I will make some specific comments about the allocations in the Bexhill West Growth area below but note here that in the Plan sites in Bexhill are allocated to the north and west of the town. Crucially, the Plan observes that the main reason for this is that the protected wetlands of the Glynde valley dividing Bexhill from St. Leonards precludes further development in that area. The Pevensey Levels to the west of Bexhill provide an equally inviolate buffer from development to the west of the town. The site allocations in the draft plan to the west of Bexhill (BX 20 to BX28) for 1923 new homes, should they all be approved, would leave no further land available for development west of Bexhill. This would be equally true should not all the sites be approved for development. Either way, RDC would have only one remaining direction for alternative site allocation within this Plan or for, what might be called, the next round of site requirements looking beyond the current allocations. The only way any such further sites can be found must be by allowing some form of development in larger volumes within the National Landscape (NL). Such proposals would, necessarily, have to be very carefully assessed and considered within the context of NL limitations. I venture that a large number of village/small town extensions for housing development of volume would not be appropriate. I propose that the alternative of a new large village or small town concept, integrating homes, schools, shops,employment and health services and connected to rail and road networks would be preferable. The simultaneous provision of these forms of infrastructure would be essential for the successful creation of a vibrant, sustainable new community which could be focussed towards upwards of 6,000 new homes. Choosing a site for such a new community would need research, but, given the restrictions already outlined above on future development near Bexhill, the draft Plan should include proposals to bring forward a new community proposition as soon as possible. In this way the many and various important studies required to create a truly integrated, planned and funded master plan for the chosen site can be undertaken in a properly project managed way, avoiding the crisis managed approach that would become necessary if action is delayed. My own research has identified a possible site. This is in the valley to the south of Robertsbridge. Ready access to the railway and A21 would be available, the new community could be connected to and enhance Robertsbridge without imposing on the historic heart of that town and, visually, the new community would be relatively hidden from view (limited views mostly from the A21 Robertsbridge bypass). The visually more open area of the "high" National Landscape area would be untouched.
I do not believe RDC can defer action to include this form of proposal from inclusion in the draft Plan. Were it to do so, it would be abdication responsibility for an action that will inevitably be required. Not to start now will make decisions later much, much harder with delivery of resultant development deferred into the far distance. Starting now, offers the prospect of the start of delivery within the draft Plan horizon, with various agencies, (highways, water, health, education) being able to simultaneously plan, budget and fund their contributions to the integrated whole.

B/ HOUSING SITE ALLOCATION - WEST BEXHILL:
Ref: Rother Local Plan 2025-2042 - Development Strategy and Site Allocations. Part 4 - Site Allocations. section 7 - Site Allocations.)

BX19; I object to the removal of this public car park which enables folk to enjoy the coastline at Cooden Beach, where, in summer especially, parking close to the beach is a valuable asset for families. Parking distances away, on public roads, is a burden on families who will have buggies and beach equipment to manage.

BX20: This site is already subject to lengthy debate and assessment. Despite an Outline planning consent having been granted, the developers have failed so far to produce acceptable proposals for a highway connection to the A259 ( Barnhorn Road), surface water drainage and ecological objections. Indeed their most recent drainage ideas were seriously retrograde and did not comply with earlier principles. It is noteworthy that these issues were first raised as concerns by objectors to the RDC DaSA some 9 years' ago. It remains very unclear if this development can proceed.

BX21: This site would become an extension to the development of BX20. As such it would result in an increase in traffic accessing Barnhorn Road for the intended junction. However, this junction is not yet capable of meeting the National Highways requirements of the Design Manual for Roads and Bridges within the BX20 planning application process so it is impossible to see how this site can be allocated . National Highways has previously stated that the maximum number of houses it would accept having access via the Barnhorn Road junction under BX20 was 160 (ex the caravan site). The inclusion of BX19 takes this above that threshold.

BX22: this allocated site has no point of access to the A259, Barnhorn Road, identified. As such, and given that access cannot be via the BX20 access point for reasons of traffic volume and non-compliance with the Design Manual for Roads and Bridges, it is difficult to see how this site could possibly be treated as "deliverable". It is clearly not deliverable without an access point. RDC should be clear about where this will be or remove this site from the allocation.

BX24, BX26 and BX27: These three sites are taken together as my comments are common to each of them. Fundamentally the access of these sites onto the A259 Barnhorn Road, create grounds for deep uncertainty about the deliverability of the sites for development. The use of Coneybarrow Lane is denied and the Barnhorn Road in the vicinity of the potential alternative access points, topographically difficult, subject to sight line restrictions because of road curves and existing side road/cul;-de-sac access points. National Highways will require compliance with the Design Manual for Roads and Bridges if it is to accept further junctions onto this busy and overcapacity Strategic National Highway. It is hard to see them accepting these proposals.

Generally - BX20 to BX 28:
These sites continue the RDC approach of allocating sites in an unplanned way. Each is regarded individually with no declared master plan for the housing development or any supporting infrastructure (of which there is little). The result is a series of incoherent individual housing neighbourhoods (BX23 excepted) - very far from placemaking and lacking in any form of collective community.
Beyond this, when considering the traffic impacts, effects on the protections of the Pevensey Levels and drainage intentions, it is necessary to look at the potential cumulative impacts. No mention of these is made in the Plan, yet it is already known that National Highways has safety and traffic volume concerns about the A259 from Pevensey Roundabout into central Bexhill. The site allocation proposals will exacerbate these, already unacceptable highways concerns.
Foul water disposal is a further area of concern. The existing sewer in Barnhorn road is too small - even before the current Rosewood Park development was approved, with resultant foul water flooding a frequent event (if mainly in winter). Southern Water acknowledges that it has no plan in the pipeline to fund and commission any upgrades to the system so adding up to 1900 extra houses will exaggerate the current pollution problem. This cannot be allowed to happen - and, again, the cumulative impact of the proposals must be the starting point for assessment of future drainage requirements if foul flooding is to be avoided. At the minimum a clear, defined upgrade plan, costed, funded and programmed, must be in place before any planning approvals are granted for these sites, noting again the condition of adequate foul water capacity listed in the Plan details for each site.
Strict protections for the Pevensey Levels must be ensured with cumulative impacts central to decisions taken. It is noted that each site specifies the need to ensure compliance with the Habitats Regulations.

Finally, the risk that some of these sites may not be developable reinforces the strategic proposition I set out in point A/ para 4 above. If RDC cannot progress with any of these sites, or those elsewhere in the draft Plan, it will be forced to look in the designated National Landscape for volume sites. I urge that it does so now and incorporates a proposal into the next iteration of the draft Plan.

I commend these comments to you.
Yours

OBJECTION TO PROPOSED SITES BX20-BX28 inc.

1. Lack of infrastructure to cope with even more development.

2. Barnhorn Road is currently unable to cope with the present volume of traffic with frequent traffic queues and gridlock at Little Common roundabout. There is no alternative route when the road is blocked.

3. Already there are not enough Doctors and pressure on local schools.

4. Limited public transport therefore increased car use.

5. Drainage and sewerage unable to cope.

6. A serious increase in traffic pollution.

7. BX22 in particular could well damage the SSSI and Ramsar sites of Pevensey levels, especially the commercial development proposed.

Good afternoon
I would like to make the following observations on the above sites:

BX22 - there is currently no access to this site and I understand that it cannot use access for BX20. It will therefore require one of the residents on the south side of Barnhorn Road to sell their property to the developer. As there is no control over this, there is no guarantee that the access will be in the "best place" in relation to the access points at Brooklands Road and BX20, therefore adding to more congestion and pollution on the A259.

BX 27 - the southern part of this site which abuts Barnhorn Road has been refused development on two occasions. In the officer's report for one of the applications RR/2021/2403/P, the ESCC landscape office did not support the application because, "it would have an unacceptable impact on local landscape character and views". This was for a development of 49 houses.

BX 28 - this site was on the 2019 DASA and proposed 140 dwellings on a site of 15ha plus a full sized playing pitch for either football or cricket. The site has now increased in size by approx 33% to 19.21ha. However the number of proposed dwellings is now 384 - a 274% increase.

My objections to these site are focussed on the following:

Congestion on the A259. It is not unusual to experience eastbound traffic queued back from the Apple Green petrol station at the entrance to Northeye to Little Common roundabout a distance of at least half a mile. Westbound traffic in the morning is often queued back from Little Common roundabout to the Denbigh pub, again another half a mile of traffic. I am very concerned about the pollution levels on this road for residents, cyclists and pedestrians. An increase in development will undoubtedly lead to more queuing traffic and the possibility that drivers will seek alternative routes along narrow lanes such as Conneyburrow and Sandhurst, some of which is single track and unsuitable for high volumes of traffic. This is currently happening to an extent as drivers seek to access the NBAR without having to queue along the A259. A bypass from the Marsh Road to NBAR would obviously be the solution but will never be a reality. A busy road with regular queuing traffic will not encourage businesses to set up in west Bexhill.

Lack of school places - I am concerned about the availability of secondary school places as Bexhill Academy took 298 Year 7 students out of its 300 places for the year 2025/26. I do not believe you can include St Richard's Community College in any calculation as it is a church school which controls its own admissions policy. There is currently one nursery in Little Common and the primary schools is (and always has been) close to capacity. If children cannot get a place at the local primary school or nursery then this will inevitably lead to more traffic as children are taken and collected from other schools in the Bexhill area.

We are writing to object to the Local Development Plan BX20 BX 21 BX22 These are at present farmlands and numerous wildlife and birds inhabit this area there is also ancient woodland.
BX22 is adjacent to Pevensey level a special area of Conservation and pollution from sewage from inadequate present drains cannot sustain the amount of sewage from the new houses that have been recently been built. In 2023 and 2026 due to high rain fall the sewage system failed and led to overflowing sewers for 16 hours due to severe blockage in main sewer pipe which is only 9 ins wide totally inadequate and special equipment had to be brought from Worthing to clear it.
Southern Water have admitted in their report “There is limited local network and phasing development may be needed prior to dwellings in each policy”
We had a hose ban nearly all of last year in this area the Environmental Agency estimates a shortfall of 5 billion litres per day due to population growth.
No new reservoirs have been built in our area for 30 years.
Also on BX 22 the land behind numbers 115 Barnhorn Road upwards is the site Old Town field it dates back to 1305 and was then called Oldeton and is said to be the medieval village of Barnhorn (see map) There are also in this area 2 ponds which have a large colony of great crested newts which has been declared RED ZONE by Nature Force.

Regarding Sites BX23, BX24,BX 25, BX26, BX 27 and BX28 the same difficulties apply.
1. Access to Barnhorn Road from the proposed housing and industrial unit developments through Sandhurst Lane or Brooklands Road is dangerous and this is confirmed by National Highways and East Sussex Highways. This busy trunk road is already functioning at well above its capacity as the only road linking Eastbourne and Bexhill and beyond.An increase in the number of vehicles accessing the already highly congested A259 in this area will have a negative effect on the lives of residents and all those using this important trunk road.
2. Traffic along Barnhorn Road is already at maximum numbers at most times of the day but especially during rush hours and more traffic entering the road in the Little Common area simply cannot be justified. Most people will continue using their cars because of the poor public transport links and so the problem can only get worse and eventually someone will be killed trying to cross Barnhorn Road. Despite having an incomplete cycle route along this road, it would be a very full hardy cyclist who might try to risk their life riding along Barnhorn Road during the times of heaviest traffic! It is a very dangerous stretch of road especially for elderly and vulnerable people.
3. Whenever there is heavy rain local residents all suffer from the effects of the 9 inch wide sewage pipes which run along Barnhorn Road. These were built for the original houses but with all the extra developments along this stretch of road, the pipes can no longer cope with extra liquids and solids entering the system. Southern Water has to come out to pump raw sewage from the gardens of our nearest neighbours, regularly and we also have to deal with sinks and toilets which do not flush away and sewage smells entering our house. All the above proposed developments will only add to our problems. There is no mention of upgrading sewage facilities in the area and the so called SUDS systems cannot be relied on if we continue to have huge rain storms in the future, which seems highly probable. Southern Water have admitted that the only solution to the problem is for the sewage pipe to be dug up and renewed in Barnhorn Road which would mean closing the whole road for a lengthy period. This is not likely to happen because of the expense and difficulties it would create for haulage and public transport as well as other vehicles.
4. While I am not against developments that are well thought out and planned for the next generation, I feel that no thought is being given to up grading all the necessary structures which need to be put in place BEFORE any houses are built. Build a new school BEFORE houses, as children are already having to travel to Hastings and beyond for their education. Build the new medical centre BEFORE houses, as people in Little Common are already unable to get GP appointments. Work out how to improve traffic management on Barnhorn Road BEFORE houses are built so that we don't have gridlock and accidents on a regular basis. Ensure that the sewage system in Barnhorn Road is fit for purpose BEFORE building more houses so that we don't have to suffer raw sewage on our properties. Improve the public transport systems in the area BEFORE houses are built so that new residents wont need to use cars. Make clear to developers that the Pevensey Levels and the surrounding areas must be kept free from pollution risks 'in perpetuity' so that Bexhill will still be thought of as a beautiful place to live in the future.

We object to the inclusion of Site BX22 in the Draft RDC Plan as a potential site for development for the following reasons.



Green field site. There is need for the country to feed itself, this is prime agricultural land which has been used for many years to sustain dairy cattle. The more prime land that is converted to housing the more food stuffs the country has to import. This area is still a viable farm. The land in question can still be used for farming. Milking is currently not taking place on site because the Farmer chose to knock his own milking sheds down and move his cattle off site.



Wild Life The fields in question are adjacent to some ancient woodland. These are home to a wide variety of wild life including [redacted], Hedgehogs, Foxes, Shrews and Field mice. These mammals need the open ground to hunt in. The open pasture land, used for many years for dairy cattle, is perfect for their needs. For hundreds of years these different species have coexisted in perfect harmony. Turning the fields into housing stock will upset this delicate balance between natural habitat and domestic cattle, and more of our natural wild life will die off.

In spring 2024, we have seen, heard and recorded a [redacted] which has nested in these fields for the first time since 2013. The [redacted] is on the RSPB’s red list of endangered birds and is scarce in the UK. The [redacted] needs open scrub land and the loss of this habitat reduces the chance of this species’ survival.

Every spring we always hear a [redacted], a bird that does not populate all parts of East Sussex. Like the [redacted], the [redacted] likes dense scrubland and is also on the RSPB Red list.

Both the [redacted] and the [redacted], as well as being on RSPB red list of endangered species, migrate to west Africa in winter. Developments here in the UK will have a detrimental knock-on effect across the world. We are all custodians of the whole world, and we all have a responsibility to maintain the whole planet. A farmer making a “quick buck” by selling land in Bexhill to a building developer, will have a detrimental effect on the ecology of the planet.

Buzzards use this area for hunting, and the loss of the green habitat will mean the loss of this beautiful raptor. Occasionally we are beginning to see red kites in the area. Loss of this green land will reduce the chance of them repopulating the Pevensey levels. Barn Owls are resident in these fields and seen frequently.

This area contains an ancient pond, home to [redacted], which we have photographed, plus lizards, grass snakes, frogs and toads. Many of these species help keep down a wide range of pests. As soon as you remove such habitat, and feeding grounds, you upset the fine natural balance, and many of these species are lost; consequently, you get a rampant increase in the pests that they prey on. These small mammals and reptiles are all preyed upon by the birds of prey mentioned above.

If farm land is turned into housing there will be a Biodiversity NET LOSS, though the consultation document claims Biodiversity Net Gain.





Trees This site contains many ancient trees. The more trees we cut down the more we contribute to global warming.



Specific Area’s of Conservation and Sites of Special Scientific interest.

As these are adjacent to the Pevensey levels, (Site of Specific Scientific Interest [SSSI] and Special Area of Conservation [SAC]). Wildlife migrate across this whole area. Development of this area (BX22) would have a severe detrimental impact on the Pevensey levels. Water-born pollution from BX22 would damaging the Pevensey levels.



Infrastructure (Water and sewage) The current sewage pipe serving Barnhorn Rd was constructed in about 1950. It is 9 inches in diameter. It was suitable for the number of houses in Barnhorn Rd built at that time. Since then, there have been many additional developments. This pipe is now not coping with the sewage that it is being asked to transport. Consequently, during peaks of bad weather raw sewage is pumped onto residents’ gardens. Further developments south of Barnhorn Rd would make this situation worse. The current waste water facilities are being pushed to capacity. They cope with average conditions but fail frequently. In 2024 damage was done to the pumping station near Cooden Beach. The system failed and Cooden Beach was flooded. More development will put more pressure on the system and flooding will occur more often.



When rainfall is heavy, our house experiences sewage back up. The house has a foul smell, and toilets don’t flush properly. Upgrading sewage facilities in the area is not mentioned. The so called, SUDS systems cannot be relied on if we continue to have huge rain storms in the future, which seems highly probable. Our problems however are nothing to those of our neighbours who in times of high rain experience raw sewage pumped into their front gardens.





Infrastructure (Road and pedestrian links) A development south of Barnhorn Rd would not improve or provide an enhanced cycle route into Little common. This is rubbish. Cycle lanes do not link up or continue far enough; this has been confirmed by Planning inspectors.

The cumulative effect of all the many developments along the A259 is causing much congestion. There should not be further developments.



There is currently no suitable access from this farm land onto the A259. Nor is there a suitable lead in from the development near Clavering Walk. If a lead in was found then it would give further congestion onto the already overloaded A259, and slow down this major trunk road. Tragically, there have been several fatal accidents in Barnhorn Road and additional traffic will lead to more accidents and help put up the death toll.

Additional traffic will increase air pollution and negatively affect the lives of current residents.



Balanced community. Building just houses without the additional shops, schools and doctors’ surgeries etc might make a profit for the land owners and property developers, and satisfy Rother’s housing quotas, but it does not build a stable balanced community. Places in local schools are oversubscribed. You cannot build extra houses without building an additional school; however as there is little profit in building schools, developers are not interested.





Listed buildings This site contains two ancient barns constructed of cobbled stones typical to the Bexhill area. They are grade II listed buildings and need to be preserved.





Tourism The farmland concerned currently contains a caravan site with about 40 caravans on it. Throughout the summer this is full of holiday makers which brings revenue into the area especially within aspects of local hospitality and would have an impact on Bexhill as a whole.



Foot paths There are several ancient foot paths in this area which need to be preserved. The loss of access to the countryside and public footpaths reduces the quality of life of Rother’s residence and tourists. From these foot paths there are magnificent views of the country side leading down to the sea. The coastline of Sussex is noted for its stunning views of the sea. This special area of natural beauty needs to be preserved. Its loss would be bad for the area, bad for tourists and day trippers and bad for residents. Its loss would have a knock on effect on revenue brought into Bexhill shops and businesses.



Flooding This area includes land that is in risk of flooding. Also, it acts as a sponge which absorbs and holds water reducing the risk of flooding in lower ground on the Pevensey levels (Hydrological Catchment).

In heavy rain the ground south of Barnhorn Rd can partially act like a sponge and can soak up water. If it were built on, without this sponge like action, it would increase the risk of flooding in other parts of the Pevensey levels.

If it is developed into a housing development it would cause greater risk of flooding on the Pevensey levels below. Many of the houses in Barnhorn Rd have had grass banks constructed at the ends of their gardens. These are to protect our gardens against flooding. The fields South of Barnhorn Rd are at risk of flooding.



Access to main roads. This site at present has no road link to the A 259. To access a road link, housing stock would need to be obtained and demolished. The A 259 currently experiences much congestion and more local traffic would increase congestion.



Compounding damage caused by existing developments.

There has already been granted substantial development in this area.

(570 housing units plus a 72 bed Care Home, approved substantial medical facility and 2,015msq of light industrial un the Bexhill West/Cooden areas. There is also a current pending application for up to 340 dwellings North, and an extension of, the recent Rosewood Park development).

Granting permission for further developments would build on the damage that has already been caused to this area, and cause devastating damage to the Pevensey levels.



The recent development at Rosewood Park, required a new set of traffic lights. If the BX22 site, which would be larger, was developed, a second set of traffic lights would be needed within a distance of about 500 Meters from the first set. This would cause greater congestion on the already overburdened A259.



Recent Government statements on the need for increased housing provision state also that it should only be considered if the required infrastructure is available or to be provided. The infrastructure is not there.



Is there a need for this housing in the area?

The Gateway development to the East of Bexhill has build many new houses that the developer cannot sell. In desperation developers are letting them out to London housing associations for rental. Why build more houses than are currently needed in the area?



This development would not be sensitive to the local landscape; it would change the character of the Pevensey levels and should be rejected. I totally oppose all development South of Barnhorn Rd as such a development would cause serious harm to the Pevensey levels in perpetuity, and I urge members of Rother council to agree with me.

I am writing to object to development proposals included in the Draft Local Plan for the Rother area.

Specifically:

The sites:
BX20: 146 dwellings off Spindlewood Drive
BX21: 20 dwellings adjacent to the caravan site off Barnhorn Road
BX22: 400 dwellings + plus 3000 m² commercial space south of Barnhorn Road
BX23: 340 dwellings north of Rosewood Park
BX24: 68 dwellings east of Sandhurst Lane
BX26: 25 dwellings south of Sandhurst Lane
BX27: 540 dwellings on Beeches Farm and land north of Barnhorn Road
BX28: 384 dwellings at Northeye

I object to the above proposals because of the impact it will have on the traffic on the already heavily congested A259 Barnhorn Road. Since the building of the new developments on the Barnhorn Road and elsewhere in Bexhill the A259 Barnhorn Road already operates above capacity causing queues through Little Common village every day. An increase in the number of vehicles needing to access this road from any new properties will have a negative impact on the lives of local people and on all its users.

I am very concerned about how Southern Water will be able to deal with the sewage from all these new properties. I understand that the narrow 9” sewer pipe under Barnhorn Road cannot cope with the current quantity of sewage from the buildings on both sides of the road in storm conditions. How can it possibly cope when more residential properties are linked to its systems.

BX 22 is next to the Pevensey Levels SSSI (Site of Special Scientific Interest), SAC (Special Area of Conservation) and the Ramsar designated wetlands. It is essential that the ecological integrity of this area is preserved. Any drainage water flowing onto it requires a Sustainable Drainage System, to exclude any water-borne pollutants, as well as the creation of an attenuation pond. These requirements are proving very difficult to fulfil for the smaller development BX20. Building any more houses, particularly a high-density estate with its polluting run-off, would severely compromise the ecological integrity of this special area.

School places are currently very hard to come by. Little Common Primary School and Bexhill Academy are almost at capacity. How will they be able to cope with even more school age residents in the area.

Has the impact on the provision of primary care (GPs etc) and also the impact on secondary care (hospital services) been considered? We can't just keep building new houses without assessing the consequential impact on these essential services.

OBJECTION

SITES: BX20; BX21 & BX22

Reasons for my Objection:

Developing these sites have the real potential of irreparable damage to protected Pevensey level, Ramsar, SSSI, SAC & Ancient woodlands sites. Which seems to be in contravention of ‘The Conservation of habitats and Species Regulations 2017’ & ‘The Habitats Regulations 1994’.

It seems, the legal requirements of government agencies and local planning departments state that no planning permissions, outlining or otherwise should be approved without definitive evidence that absolutely no harm will come to Ramsar, SAC & SSSI sites, unless it has imperative reasons overriding public interest. Therefore how can Rother council consider placing these sites as potential for housing or commercial development without fully understanding the limitations of the site in particular the impact sewage treatment plants, drainage system, discharge, surface runoff, flooding will negatively impact such a important site. The current outlining planning permission regarding BX20 site still has not overcome many of these obstacles. So why encourage more development that will have the same disastrous conditions and affects on this protected site?

This ‘Urban Creep’ will increase the volume of water run-off onto the protected site. Surface water run-off has the potential to be a major source of water pollution. Pollutions reach wetland areas mainly through run-off whereby water flows over impervious surfaces picking up a number of pollutants generated by human activity, Such pollutants can include sediment from construction sites, toxic metals and petroleum wastes from roadways and industrial or commercial areas, nutrients and bacteria from residential areas and nutrients and pesticides from agriculture and gardening activities. In turn, this has the potential to significantly affect the hydrology, soil and flora and fauna of the Pevensey levels and ultimately affect the conservation objectives of the site.

Important Legal Points
***Regulation 48 of the Habitats Regulations restricts the granting of planning permission for development which is likely to significantly affect a European site, and which is not directly connected with or necessary to the management of the site, by requiring that an appropriate assessment is first carried out of the implications of the development for the site’s conservation objectives.

RDC need for housing has no relevance when considering this site for development, as housing is not directly connected with or necessary to the management of the site. Therefore, is not supported by NPPF 1.2 & Habitats Regulation 48.

***NPPF(1.2) 119 The presumption in favour of sustainable development (paragraph 14) does not apply where development requiring appropriate assessment under the Bird or Habitats Directives is being considered, planned or determined.

The Planning Department at RDC must also be mindful of its legal obligation under Regulation 49 of the Habitats Regulations to notify the First Secretary of State if it is proposing to allow development that it can not be ascertained will not adversely affect a European site.

The European Court of Justice ruled In the case of Waddenzee judgment (ECJ Case C-127/02), - A plan or project may be authorised only if a competent authority has made certain that the plan or project will not adversely affect the integrity of the site. “That is the case where no reasonable scientific doubt remains as to the absence of such effects”. Competent national authorities must be “convinced” that there will not be an adverse affect and where doubt remains as to the absence of adverse affects, the plan or project must not be authorised, subject to the procedure outlined in Article 6(4) of the EC Habitats Directive regarding imperative reasons of overriding public interest.

Another point made by the European Court of Justice ruled in the Waddenzee judgement, ‘an appropriate assessment implies that all the aspects of the plan or project which can, by themselves or in combination with other plans and projects, affect the site’s conservation objectives must be identified in light of the best scientific knowledge in the field.’

By virtue of the potential of outlining planning permission approval (I am assuming if BX21 & BX22 are included in the councils potential development sites, which was previously the case with BX20), the council would be putting itself in a precarious position. Once, full planning permission is submitted, with full details, were those details found by Natural England, Environment Agency, ESCC or others, posed the possibility of adverse effects on the Conservation Areas. Recommendations to object would then be issued. This would prevent RDC from granting full planning permission and the need to revoke outlining permission if no solutions to prevent any adverse effects to the protected sites, were found.

As RDC tax payers, we do not see it necessary for Rother to take such a chance on including these sites in its site allocation plan, when there is a chance that the developer may not be able to meet the requirements needed, to prevent any adverse effects to the protected conservation sites. Nor do we believe RDC planners should be encouraging site allocations that maybe outside the constraints of Statutory Obligations.
• Light Pollution risk to the natural environment adversely affecting wildlife
• Noise pollution on the existing residence and natural environment adversely affecting wildlife
• Air pollution: The increase of of debris and decrease of air quality from construction methods, vehicles, petrol garden equipment next to the Ancient Woodland and Ramsar, SAC, SSSI site would inevitably have a adverse affect the wildlife and pond life that have gone mainly undisturbed for centuries.

• Lack of school places: Schools are near capacity as it is.

• Lack of doctor surgeries: struggle to get a doctors appointment currently

• Removes a lot of green spaces that are currently used and enjoyed by current residents

• Destroys land of outstanding beauty

• Little Common particularly Barnhorn Stretch is already suffering from lack of sewage infrastructure. It is already struggling to cope with the existing housing. Southern Water has confirmed that a narrow 9” sewer pipe under Barnhorn Road is all we currently have is is not coping with the current quantity of sewage from the building on both sides of Barnhorn Rd. I am aware of sewage seeping into gardens of properties West of Rosewood Development. The understanding is that since Rosewood development opened the sewage West gets bottled necked where Rosewood is connected to the mains sewage and therefore is backing up.

• Traffic Congestion is already a issue for this busy stretch of the A259 particularly during rush hours.

• Barnhorn Rd (A259) is a ‘Trunk Road’, therefor it defies reason that RDC believes that Barnhorn Rd (A259) or the heart of the village could absorb further traffic, pouring directly onto its busiest most congested areas. What will become of our village?

• The addition of 3000+ extra vehicles entering/exiting directly onto the A259/Barnhorn Rd will be devastating for our community. Also safety of other drivers, cyclist and pedestrians will be at greater risk.

• Buses will become less reliable than currently due to the higher level of traffic these developments accessing directly onto A259/ Barnhorn Rd

• The current outlining permission for the Barnhorn entrance for site BX20, Highways made it clear that it was to be used for a maximum of 160 properties only.

• BX20 developers are still struggling to provide drawings/plans that conform with ‘The Chartered Institution of Highways & Transportation- Manual for Streets 2 or the Highways Agency’s Design Manual for Roads and Bridges.

• Highways is still refusing to give permission for access as the developers have not been able to illustrate/demonstrate how the entrance can be designed within the Highways agency minimum requirements onto this very busy trunk road known as A259 by the Highways Agency.

• Regarding BX22 and the suggestion of commercial premises. This will be catastrophic for this stretch of A259 due to the commercial vehicles coming and going. This will make the congestion and frustration of drivers, cyclist and pedestrian, households living directly on Barnhorn Rd/A259 even greater.

• Urban Creep into surrounding areas will change our village into something of a town. I for one love living in Little Common because of its ‘village’ feel and community. developing to this level of 1900+ new houses will destroy that.

• Density of the developments will also destroy the village. If all these sites were utilised Little Common will no longer have any resemblance of a village including the destruction of our areas of ‘Outstanding Beauty’ that currently wrap around us.

In conclusion we strongly object to this planning application.

OBJECTION

SITES: BX23; BX27 & BX28

Reasons for our Objections:

• Little Common particularly Barnhorn Stretch is already suffering from lack of sewage infrastructure. It is already struggling to cope with the existing housing. Southern Water has confirmed that a narrow 9” sewer pipe under Barnhorn Road is all we currently have is is not coping with the current quantity of sewage from the building on both sides of Barnhorn Rd. I am aware of sewage seeping into gardens of properties West of Rosewood Development. The understanding is that since Rosewood development opened the sewage West gets bottled necked where Rosewood is connected to the mains sewage and therefore is backing up.
• Traffic Congestion is already a issue for this busy stretch of the A259 particularly during rush hours.
• Barnhorn Rd (A259) is a ‘Trunk Road’, therefor it defies reason that RDC believes that Barnhorn Rd (A259) or the heart of the village could absorb further traffic, pouring directly onto its busiest most congested areas. What will become of our village?
• The addition of 3000+ extra vehicles entering/exiting directly onto the A259/Barnhorn Rd will be devastating for our community. Also safety of other drivers, cyclist and pedestrians will be at greater risk.
• Buses will become less reliable than currently due to the higher level of traffic these developments accessing directly onto A259/ Barnhorn Rd
• Light Pollution risk to the natural environment adversely affecting wildlife
• Noise pollution on the existing residence and natural environment adversely affecting wildlife
• Air pollution: The increase of of debris and decrease of air quality from construction methods, vehicles, petrol garden equipment next to the Ancient Woodland and Ramsar, SAC, SSSI site would inevitably have a adverse affect the wildlife and pond life that have gone mainly undisturbed for centuries.
• Lack of school places: Schools are near capacity as it is.
• Lack of doctor surgeries: struggle to get a doctors appointment currently
• Removes a lot of green spaces that are currently used and enjoyed by current residents
• Destroys land of outstanding beauty
• Urban Creep into surrounding areas will change our village into something of a town. I for one love living in Little Common because of its ‘village’ feel and community. developing to this level of 1900+ new houses will destroy that.
• Density of the developments will also destroy the village. If all these sites were utilised Little Common will no longer have any resemblance of a village including the destruction of our areas of ‘Outstanding Beauty’ that currently wrap around us.
• Too high of a concentration of building in such a small area.

In conclusion we strongly object to this planning application.

Objections to the draft local plan.

BX20: 146 dwellings off Spindlewood Drive
BX21: 20 dwellings adjacent to the caravan site
BX22: 400 dwellings + plus 3000 m² commercial space south of Barnhorn Road
BX23: 340 dwellings north of Rosewood Park
BX24: 68 dwellings east of Sandhurst Lane
BX25: Medical Centre with 86+ parking spaces and light industrial units with 50+ parking spaces
BX26: 25 dwellings south of Sandhurst Lane
BX27: 540 dwellings on Beeches Farm and land north of Barnhorn Road
BX28: 384 dwellings at Northeye

These comments relate to all the above sites in the draft plan.

I understand that the Government are putting pressure on all local authorities to build new houses but the following sites are of particular concern as they will all need access onto the A259/ Barnhorn Road. This is already a very busy road that suffers long queues, not only at peak travel hours but also at other times. It is also frequently blocked due to accidents and there is no viable alternative without travelling miles. Whilst claims will be made that new residents will use bus services they are unreliable and so in most cases the preferred method of transport will be by car. There is also the issue that all of these new homes will have residents who order their goods on the internet so the impact of increased delivery vehicles will also be felt.

The local doctors and hospitals are already at stretching point, my own doctors has a permanent answerphone message saying they have limited appointments so please phone the next week, if you do so you get exactly the same message. I note that BX25 includes a new medical centre but from a pre-planning meeting I attended it was obvious that this would simple replace the current Little Common Surgery so not provide additional doctors. The NHS is also struggling with an "urgent" MRI scan having a current waiting list of 7 weeks.

In regard to education, Little Common Primary school, as the nearest school to these sites, is already almost at capacity and even if they had spaces the parents would have to drive their children to the school as it would not be in walking distance to the new homes.

I understand that Southern Water have already stated that the current sewer pipe in the area can not cope with the current level of sewage during storm conditions so it is unclear how they could cope with all these additional homes.

BX22 is next to the Pevensey Levels SSSI, the Special Area of Conservation and the Ramsar designated wetlands. It is essential that the ecological integrity of this area is preserved which with the likely polluting run off from high density housing seems very unlikely.

OBJECTION

SITES: BX20 BX21 & BX22

Further Reasons for my Objection:

* Site BX21 is full of asbestos and disturbing it could be detrimental to the health not only of those working on the site but the residents of Little Common particularly those living close to the site. This has been reported to the Environmental Agency as well as the Environmental officers at Rother.

* Damage to the setting of listed buildings and medieval farm.

* We strongly object on the grounds that the Development of these sites would harm the oldest recorded historic site in Bexhill-on-sea/ Little Common.

* Currently Barnhorn(e) Manor, as well as the cottage on the grounds are Grade 2 listed. For those of you that are unaware of the Antiquity of the site……..The Manor of Barnhorn(e) dates back to 772 (shown on the gated wall as you approach the drive from Barnhorn Rd), when King Offa granted its lands. That was over 1,200 years ago. Later on the manor of Barnhorn was owned by the Abbots of Battle. Barnhorn Manor had a very interesting history. The tenants took hay and wheat to Battle Abbey in lieu of rent. There was a very real connection between Barnhorn and Battle Abbey until the time when Battle Abbey and Barnhorn passed to the mother of Henry VIII.

The actual Barnhorn(e) Manor House ,was moved before 1305 from a site to the East named ’Old Town Field’ to the present site of Barnhorn Manor Farm, a 2-story house with flint facing and a tile roof (Brandon, ‘Barnhorne’ 70). There is one payment for entertainers of the Duke of Gloucester recorded in the Battle abbots’ accounts at Barnhorn ca. 1478-82. In 1539 Barnhorn Manor & Farm was granted to Sir Anthony Browne after the dissolution of Battle Abbey.

* A positive strategy for the historic environment in Local Plans should ensure that site allocations AVOID harming the significance of both designated and non-designated heritage assets, including effects on their settings. Great weight should be given to the asset’s conservation.

In conclusion we strongly object to this planning application.

I have attended one of the consultation events and though not a member of Spindag, I am in full agreement with the points succinctly made by Graham Stone as shown below:

1. That unless local infrastructure was significantly improved and updated before the building works began, the proposed developments would cause serious difficulties not only for current residents but also for new residents and this would certainly be detrimental to Bexhill as a whole.
In particular:
a. The apparent lack of planning for and delivery of major new job opportunities to address the earning needs of c 30,000 new residents who will inhabit the new dwellings proposed over the next 16 years
b. The lack of any new school and nursery places proposed
c. The enormous impact of so many extra vehicles needing access from additional entry points to Barnhorn Road (strategic trunk road A259) in order to use this already highly congested route. This would result in further serious detrimental effect on the local and wider economy
d. Based on previous experience, there is doubt that South East Water and Southern Water would have sufficient fresh water and sewage capacity to cope with all these new residents (please see the attached summary of an article recently published by the Independent news paper. This highlights the concerns we should all have about SE Water's ability to provide adequate fresh water supplies to us all). - NOTE, no attachment was received by RDC.
e. Whether there would be sufficient GPs to cope with so many new residents
2. There was also much discussion and concern about whether it was fair and reasonable that Bexhill (especially west and north) should be bearing the brunt of the total number of new dwellings (at least 50%) in Rother instead of spreading them more widely in rural areas where there is less congestion and far more land available.
The RDC planning department staff assured us that all potentially affected infrastructure bodies were being consulted on the plans including:
1. East Sussex County Council responsible for schools and local roads
2. South East Water
3. Southern Water (sewage)
4. NHS (hospitals and GPs)
5. National Highways responsible for the A259

Draft Rother Local Plan 2025-2042 Consultation
Thank you for sharing the Draft Rother Local Plan 2025-2042 with the Pevensey and
Cuckmere Water Level Management Board, after reading the document we have made
some observations and have the following comments:
The draft Environmental Policy ENV2 recognises the role Internal Drainage Boards play in
ensuring water is appropriately managed within their districts as well as the need to reduce
flood risk and promote the benefits of blue /green infrastructure. The PCWLMB recognises
this as an important strategic objective for Rother District Council.
However, it is noted that policy text for Part 4 Site Allocations is not consistent when referring
to the application of ENV 2 at each site. Sustainable Drainage should apply to all new
development, not a select few within the local plan for example BX20 correctly states that
ENV 2 applies to the site while there is no mention of the policy in BX19. And like wise CR1
correctly states that ENV 2 applies to the site but no mention of the policy in CR2.
ENV 2 recognises that drainage systems should allow for ongoing maintenance. However,
the proposed development should also reserve adequate space for access and maintenance
of Sustainable Drainage Systems and other water bodies within the sites. This is to ensure
that the water bodies and drainage system can be maintained and operated safely and
sustainably for the lifetime of the development. This should apply to all development sites,
including those in the PCWLMB’s catchment area.
Development sites in West Bexhill Growth Area discharge their water to watercourses in the
Pevensey Levels whose drainage is supplemented by pumping during extreme rainfall
events. These pumps were installed in the 1970s and have reached the end of their design
life with limited funding available for their replacement. There is, therefore, a likelihood that
these watercourses will have high water levels over long periods in winter where drainage
systems might struggle to discharge water into the watercourses. During such periods,
drainage systems should have been designed to take that into account to ensure it does not
result in flooding on or offsite. In addition, the PCWLMB has a byelaw that requires anyone increasing the flow or volume of
water discharged into its drainage district to agree the discharge rates with the Board prior to
making the discharge. Applicants should seek pre-applications with the Board and LLFA at
the earliest opportunity for all sites within the water level management board’s catchment
area. This applies West Bexhill Growth Area, North Bexhill Growth Area, parts of Central
Urban Area, Catsfield and Crowhurst
There is little opportunity for infiltration in the catchment area of the water level management
board due to impermeable geologies and high / perched groundwater. Therefore, space
should be considered when designing surface water drainage as a lager area could be
required for attenuation prior to discharge to a waterbody.
The PCWLMB will also take into consideration water quality passing into the Boards
drainage district especially in the Pevensey Levels. This is because there are a number of
species within the watercourses that are dependent on clean water.