An objection to the inclusion of BX22 in the Draft Local Plan



The effect on the ecology of a SSSI, a SAC and the internationally-recognised wetlands

This is of major concern for such a site. It is a special part of Rother and Wealden and its integrity must be preserved. It is the heritage of both districts and nothing should be allowed to damage that. Any development close to the Pevensey Levels has the potential to do just that and must be resisted. A SuDS for BX22 must be absolutely fail-safe and that cannot be guaranteed.



The effect on the flow of traffic on Barnhorn Road

This road is part of the A259 and there is no viable alternative to it. It is already heavily trafficked and operating above its capacity, as shown daily on the AA traffic news. The Planning Inspector for the recent Woodhurst Grove development commented on its relentless nature. This will increase when the Northeye site is developed for housing, the new Medical Centre (86+ parking spaces and 56 for the light industrial units) is operational and, if it happens, the Spindlewood development takes place.

It is already very difficult to drive out onto Barnhorn Road from all access points; adding another access point for the many vehicles from BX22 would negatively affect the flow of traffic and be hazardous for the drivers of those vehicles. The road would become even more congested, journeys would take even longer and it would be even more difficult to drive out onto the road.



The lack of suitable infrastructure

Although a bypass would solve some of the problems, experience shows that it could take up to 20 years before coming into being and would have to be constructed before any development took place.

The narrowness of the Barnhorn Road sewer pipe has already caused sewage outflow in the gardens of some houses south of the road. The pipe is not wide enough to take the current amount of sewage, let alone any more. Replacing that pipe with a wider one would involve digging up and therefore closing a very busy trunk road for a long time.

For the the sake of the environment, the preservation of the integrity of the Pevensey Levels and the users of Barnhorn Road, BX22 in particular should not be included in the Local Development Plan.

TO WHOM IT MAY CONCERN

I strongly oppose the above, proposed building plan, because Little Common, the small village in which the plan will surround, is not able to support, now, the high number of new residents that have recently arrived, as a result of new housing projects in the area.
The Surgery & the School are full to capacity. The pharmacy is struggling to provide the high volume of prescription requests and the only, small supermarket, Tesco, can barely stock sufficient supplies for existing residents. Parking anywhere in the village is impossible, and the roads at the roundabout are gridlocked, causing long delays along the A259 (Barnhorn Road) where most of the new housing sites are going to be built, and (A259) Bexhill Road leading to Bexhill, Hastings & the new link road to Queensway.
I hope that my concerns will be taken into consideration, when making final decisions on the RDC DRAFT LOCAL PLAN 2025-2042.

I wish to lodge further Objections to all of the above proposed developments.

Little Common is already being destroyed by unwanted unwanted developments for which existing infrastructure is inadequate.



BX22 is adjacent to the Pevensey Levels Conservation area and any development will impact badly on this unique area.



The A259 road is already badly congested at peak periods and the huge amount of additional traffic from all these proposed sites will impact negatively on road users and, more importantly, on the lives of the existing residents.



There is no plan to provide additional local employment opportunities that would be required for the thousands of new residents that would be involved.



Past local experience proves that large scale developments such as these sites proceed with utter disregard to existing residents and Council Tax payers.



I strongly Object to ALL of these proposed development sites.

My comment and objection to BX22

A housing estate so close to the Pevensey Levels SSSI, SAC & Ramsar wetlands would have a damaging effect on its ecology and on the flow of traffic on an already congested trunk road.

Damage to the ecology of a sensitive area

The need for sustainable and effective drainage
Building a high-density estate of any number of dwellings on the BX22 area would be a serious threat to the ecology of this area. This region becomes seriously waterlogged after heavy rainfall, with a tendency to flood; considerable polluting run-off from any housing development would be inevitable.. Drainage is therefore a serious issue. It is proving extremely difficult to devise a completely effective SUDs system for the smaller scale Spindlewood development. It would therefore be even more difficult to design a SUDs system for BX22 which would be totally effective in perpetuity.

Lack of the necessary infrastructure

The need for a totally effective sewerage system
The narrow Barnhorn Road sewer pipe currently cannot deal with the sewage from the dwellings on both sides of the road which feed effluent into it. This is a major health issue for some of the houses on Barnhorn Road which experience sewage outflow from manholes in their gardens. To cope with more sewage from the additional dwellings proposed for BX22 would mean replacing the narrow sewage pipe with a wider one - and the digging up of Barnhorn Road. This would be impossible without an alternative route, such as a bypass, in position first.

The congested A259 and access onto the Barnhorn Road from BX22
The A259 is a very congested trunk road, particularly in peak times. It currently operates above its capacity. It is a very busy road because there is no alternative route to the section of the A259 between Pevensey and Little Common.
Residents have difficulty driving out onto the road; it is a hazardous operation. The heavy traffic in both directions results in long waits for drivers to be able to drive safely from a driveway onto the opposite side of the road, creating long queues. Vehicles travelling eastwards are frequently held up by the Barnhorn Green/Rosewood Park traffic lights. The traffic after those lights in the westward direction speeds up to make up for lost time.
It is no surprise to those of us who have to use Barnhorn Road every day that there are so many accidents on this section of the A259.
Barnhorn Road already faces the prospect of more traffic to and from the proposed Medical Centre on Barnhorn Green, the development of the Northeye site and the possibility of 140 dwellings on the Spindlewood site.

The danger to health

Air pollution
Air pollution along Barnhorn Road is already a danger to health because of the persistent flow of heavy traffic along the road.
Air pollution from vehicles consists of nitrous oxide gases (NO2, NOX), ammonia and PM2.5 & PM10 particulates. The tiny toxic particulates PM2.5 are produced by the brakes and tyres of all vehicle and the exhaust of diesel-powered vehicles. There is no such thing as a zero-emission vehicle. The dust from tyres and car brakes is as harmful as fumes in the lungs.
Those who live along Barnhorn Road and those who travel along it suffer this air pollution, which has already increased because of the queueing traffic caused by the Rosewood Park traffic lights.

As long ago as 2017, Wealden District Council’s Air Quality report predicted a worse-case scenario of a region of up to 10m on either side of the A259 road as having, by 2028, a pollution concentration higher than the maximum annual average of 10µg/m³ recommended by the WHO. Since that report, the traffic has increased considerably, as will the pollution concentration.

Conclusion

BX22 should not be included in RDC’s Local Development Plan.

I am writing to formally object to the following planning proposals: BX20, BX21, BX22, BX23, BX24, BX25, BX26, BX27, and BX28.

My primary concern relates to the impact of the development on local traffic conditions and associated pollution. The surrounding road network is already under significant pressure, and any increase in vehicle movements would exacerbate existing problems. There have been previous instances of increased car accidents in the area due to increased traffic. Furthermore, often congestion has delayed emergency services. The proposals would likely intensify these risks, leading to further safety concerns and reduced air quality for residents.

I am also concerned about the environmental impact of the developments. The sites currently support local biodiversity, and their loss would negatively affect wildlife and the ecological balance of the area. Developments of this nature should protect and enhance biodiversity, yet these proposals appear to result in its reduction. Whilst the proposals commit to a net biodiversity gain, this is impossible to achieve whilst still in keeping with the natural surroundings.

Furthermore, the proposals appear to be inconsistent with the Council’s wider environmental commitments. In particular, they would contradict Rother District Council’s pledge to become carbon neutral by 2030, as well as its 2025 declaration of a Nature Emergency. Approving developments that result in increased traffic, higher emissions, and loss of natural habitat would undermine these stated objectives.

In addition, there are serious concerns regarding drainage and flood risk. The fields in question are frequently waterlogged, and my own garden is often affected by excess water. This strongly suggests that the land plays an important role in natural drainage. Developing these sites could worsen surface water flooding, both on-site and in surrounding residential areas. I have particular concerns about BX22 for this reason.

For these reasons, I believe these proposals are unsuitable for this location and should be refused.

Re BX15 (adjacent to BX14 already passed for 210 homes) of Local Development Plan
Can the proposed site BX15 for an additional 35 new houses be included in the Plan as it is part of Fields in Trust? You can only use this land if you can provide the same amount of land for public use in the vicinity - are you making this provision? As you are aware Ellerslie Lane is already unsafe with no pavement - I risk my life walking this route when I visit the cemetery weekly - will this be in a box sooner than I had hoped? The lane is subsiding, already much much busier with the recent occupation of new homes in Fryatts Way. Also your proposal is not in line with your recognition of the climate change crisis because you will remove biodiversity and increase flood risk. Your thinking is madness. Any tiny bit of nature needs protecting at all cost for future generations. Please remove BX15 proposal from your development plan.

See attached representations in response to questions 2, 3, 4, 6, 7, 8, 10, 12, 14, 17, 23, 38, 61, and 68

Thank you for consulting the Sussex Wildlife Trust (SWT) on the draft Rother Local Plan. SWT recognises the importance of a plan led system as opposed to a developer-led process and supports Rother District Council's (RDC) desire to produce a cohesive Local Plan. Therefore, we hope that our comments to this focused regulation 18 consultation are used constructively to make certain that RDC properly plans for the natural capital needed within the district, supports nature's recovery, and ensures that any development is truly sustainable.

Environmental evidence base

A robust environmental evidence base is essential to local plan-making. RDC must recognise the need to invest in the ongoing assessment of the district's natural environment to ensure a clear understanding of the district's natural assets, how they function and where the ecological connections are, or need to be. The emerging East Sussex Local Nature Recovery Strategy (LNRS) will further enable and support the identification and enhancement of nature recovery networks and prioritise action for nature within the district and will be a fundamental element of the environmental evidence base.

This environmental evidence should be used to inform local plan processes from the earliest of stages to ensure that decisions properly assess the cumulative impacts of site allocations; policies are effective at addressing the biodiversity and nature recovery potential within the district; and RDC has a true understanding of the district's environmental capacity to support the quantum of development proposed.

We also encourage RDC to identify what additional environmental evidence is required during the formulation of the Local Plan. RDC must take seriously that the protection of core wildlife sites, local designations and the value of the wider countryside is a clear requirement of paragraph 187 of the NPPF.

Allocation policies

We encourage all Local Planning Authorities to identify at the earliest stages of local plan making the cumulative ecological impacts of site allocations and their potential to contribute to nature recovery. This is to ensure the plan is in line with NPPF paragraphs 159, 171 and 198, and supports the ambitions of the Environment Act to deliver the 30x30 target.

First Floor, The Keep, Woollards Way, Brighton, BN1 9BP 01273 492630 I enquiries@sussexwt.org.uk sussexwildlifetrust.org.uk

Sussex Wildlife Trust is a company limited by guarantee under the Companies Act. Registered in England, Company No 00698851. Registered Charity No. 207005. VAT Registration No. 191 305969. Registered Office: First Floor, The Keep, Woollards Way, Brighton, BN1 9BPAll potential site allocations should be assessed against a robust and up-to-date ecological evidence base. As a minimum, preliminary ecological appraisals should be provided for all potential site allocations. RDC should demonstrate how potential allocations interact with the ecological networks within the district and the natural capital required to support these developments, alongside an assessment of their cumulative impact in combination with new and existing development within the district. This information must be set out clearly as part of the evidence base for the local plan.

SWT would support more detailed consideration of the LNRS against allocations as the two processes progress to adoption to ensure that allocation policies more clearly identify nature recovery priorities.

SWT is currently only able to provide comment on targeted allocation policies within this consultation, but we urge RDC to ensure that all policies compliment an approach that supports nature recovery in balance with sustainable growth and recognise RDC's responsibilities under the enhanced NERC Act.

Consultation questions

SWT's comments relating to specific consultation questions follow below.

Q2. Do you have any comments on the Council's proposed housing target for the Local Plan of 8,427 dwellings over the 17-year plan period, or 495 dwellings annually?

The proposed housing target is a significant increase on the 2014 target in the adopted Rother Core Strategy of 335 homes per year. We note that monitoring shows this target has not been met on a regular basis, with on average 215 homes built annually. SWT is concerned about cumulative impacts on the natural environment, and we question the ability of Rother district's natural capital to absorb the proposed level of development without harm, especially since many of the proposed allocations are very large and/or located on greenfield sites. Given that the standard method for calculating housing need does not consider an area's environmental limits in the calculation, we ask whether RDC is confident that the environmental evidence base supporting the local plan is sufficient to ensure this housing need can be delivered sustainably?

Q15. Do you have any comments on the proposed Vision for the Countryside?

This Vision should be strengthened to properly reflect the multiple benefits provided by rural land. NPPF paragraph 187 is clear that planning policies and decisions should contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services. SWT would support a vision that recognises the need for the countryside to provide ecological function and connectivity, and more clearly encapsulates the fundamental role played by rural land in terms of natural capital and the ecosystem services that support our health, wellbeing and the economy.

Q13. Do you have any comments on the proposed Vision and development strategy for Rye and the Eastern Settlements Cluster, including the development figures shown in Figures 23 and 24?

Paragraph 6.66 should be amended to reflect the full range of designations applied to Dungeness, Romney Marsh and Rye Bay, which is an SAC and SSSI as well as SPA and Ramsar Site. This area is of national and international conservation importance.

Paragraph 6.72 should be amended to reflect the full range of designations applied to Rye Harbour Nature Reserve, which is part of the Dungeness, Romney Marsh and Rybe Bay SSSI, SPA, SAC and Ramsar site.Q17. Do you have any comments on the proposed site allocations in Bexhill?

SWT is concerned that there appears to be no overarching consideration of the cumulative impact of the numerous development proposals around the Pevensey Levels. It is not clear how the area's natural capital can absorb this level of development and we urge Rother District Council to work with Wealden District Council to prepare a catchment plan of the whole area in order to assess the sensitivity of the wider region around the designated sites.

BX36, BX45 and BX47 - These allocations are adjacent to or overlap with (BX45) a Local Wildlife Site (LWS) and the policy should therefore stipulate a requirement for development to avoid any adverse impacts to, and protect and enhance, the LWS in accordance with NPPF paragraph 192.

Q50. Do you have any comments on the proposed site allocation in Rye Harbour, detailed in Policy RH1?

Given that the site is adjacent to a waterbody that is functionally linked to the SSSI/SPA/SAC/Ramsar site, we are concerned that the need to protect this watercourse from runoff and pollution during and post construction is not more clearly recognised in the policy wording for this allocation.

The supporting text indicates that lighting will need to be carefully designed, therefore we suggest that this requirement is captured in policy wording.

Criterion iii) within the policy wording specifies that development on this site must 'Retain and enhance the tree belt on the south-western boundary with native species, with appropriate fencing erected to maintain an effective barrier between the site and the adjacent Dungeness, Romney Marsh and Rye Bay SSSI, SPA and Ramsar Site.' We query whether this fencing is intended to be permanent and what form it will take, as there are potential implications for wildlife and ecological connectivity.

Given the sheer volume of allocations put forward, we have only had opportunity to look in detail at those directly adjacent to our nature reserves. With this in mind, we reiterate our concern about the cumulative impacts of development on the natural environment and question the ability of Rother district's natural capital to absorb the proposed level of development without harm.

We hope that RDC can use our comments constructively for the next iteration of the Local Plan. It is imperative that the protection, enhancement and restoration of the natural environment is embedded across the plan policies and allocations. We would be happy to discuss any elements of our submission for clarity or further detail, so please feel free to get in touch.

It is with a heavy heart that I submit these comments on the draft local plan. Experience has shown that even if a site is outside the current plan - notably the land adjacent to Clavering Walk - it is still the subject of a planning application by developers and is given the green light by the Planning Inspectorate.

However, I would like to register my distress that Rother's proposed development seems so disproportionately focused upon the area around and to the west of Little Common. This is despite the known existing challenges involving severe traffic congestion, water and sewage pressures, and the strain upon critical services like schools and hospitals. (I recently attended A&E at Conquest Hospital and can personally attest to the pressures there even during mid-week. Eastbourne General Hospital is in a similar position.)

The stated ambition to be 'Green to the Core' is also undermined by the existential threat to the Pevensey Levels represented by the proposed housing developments.

It is to be doubted that there is any democratic support for a 'West Bexhill Growth Area' - a term that has formed no part of the public platform of any local political party.

Moreover, the suggestion at paragraph 5 of BX18 that services like banking will form part of the Growth Area is frankly risible.

The plan itself details the reasons why further development of West Bexhill is so fraught:
• Its proximity to the environmentally sensitive area of the Pevensey Levels, meaning any new development must incorporate careful sustainable drainage (SuDS) solutions comprising at least three treatment stages in accordance with Policy ENV2 of the draft Local Plan (2024);
• Impacts on the A259 trunk road, including the Little Common Roundabout where there are known capacity constraints leading to congestion;
• The road network away from the A259, which (particularly in the west) comprises narrow, winding country lanes unsuited to additional traffic;
• Its sensitive landscape setting, with long views into the countryside to the south-west and north;
• Areas at risk of flooding, which effectively encircle the Growth Area to the south and north;
• The distance of many large sites from services, facilities and public transport connections in Bexhill and Little Common, meaning that without careful planning and provision of infrastructure, new residential development could be unsustainable and largely car-dependent.
None of the proposed sites is immune to these challenges, but BX28 does at least have the merit of being a brownfield location. BX20, BX22 and BX27 are the most egregious.

I am not persuaded that there is an overwhelming 'local need' for the proposed housing developments. They are clearly designed to meet national targets and objectives. But that is not a justification for putting so much of Bexhill's green surroundings under concrete, and bringing the area to gridlock.

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.

BX19 The Gorses Car Park - Objection

This is an unsuitable development due to:

1. Southern Water sewage problem which has been exacerbated by recent development already taking place in the area.

2. Car parking for train users, beach goers, hotel clients has become more important due to restrictions now in place at Herbrand Walk.

3. The Government has been encouraging the general public to use public transport and by restricting parking will only put them off.

4. The community bus uses The Gorses every day and with the bad parking already has trouble getting through. This is a very popular service and valuable to the community.

5. More development all hooking up with out of date infrastructure dating back to Victorian times will only lead to a massive strain & increasing the problems already being experienced!

6. The type of houses proposed will not blend in with the already established surroundings.

BX19 Objection

Objection Gorses car park and open space

Car park is necessary for train travellers rather than using cars.

Gorses not wide enough for 2-way traffic along with on-street parking.

The open space at present provides a valuable wild life habitat.

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

Q2 OBJECT on the Development Needs. I don't see the need to build on any more houses on green fields in the area near Bexhill. We don't need them and its spoiling the reason the people like the place.

Q17 OBJECT BX17 It's a car park well worth keeping where people park and shop or go to their clubs in the town for the evening.

Q17 OBJECT BX16 This is a lovely area with tall mature trees and wildlife. It should be looked after for future generations to enjoy.

Q17 OBJECT BX19 I want to continue using the car park at The Gorses as its easy to walk from there to the beach or catch the train. Its no point building houses on a station car park and then wondering why people don't use the train. I hope the green space and woodland is safe from development on The Gorses as its a wildlife haven.

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY

LOCAL DRAFT PLAN Response
The planning team have been very helpful throughout the consultation, thank you.
Also we appreciate a huge amount of work has gone into this process. However, it is
very important to make the comments and objections as follows:-
__________________________________________________________________
Q 1 OBJECTION: Although the Strategic Spatial Objectives in Fig 1 is set out with some
very commendable aims, they are not satisfactorily met within the draft Plan,
including the phrases found below:-
Objective 1 - Reducing flood risk from all sources...
Notes / Refs:
[Southern Water and South East Water should work to a combined 20 year plan with LPAs and not just 5
years ahead as they currently do.]
[Objective 1 should include; the planning system has a role in seeking to ensure the combined impacts of
urban creep and climate change protect the quality of the water environment. See para 162 NPPF,
December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into
account the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
Objective 2 - Maximise nature conservation... and protected habitat areas of Rother
and ensure sensitive development...
Notes / Refs:
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Objective 3 - Promote... and protect and enhance the significance of... natural
heritage, including its setting...
Objective 4 - Respond to the... needs of different groups in the community and
address income levels of Rother.
Objective 5 - Deliver sustainable growth and regeneration in Bexhill and its edges...
with supporting infrastructure...
Objective 6 - Employment needs of ... local businesses, improving quality and
variety of jobs...
Objective 7 - Sustainable locations across the district... through the timely delivery
of strategic and other supporting infrastructure and community facilities
2
Objective 8 - Connectivity of local communities ... sustainable transport measures
Objective 9 - Support and achieve safe, healthy... well-being of residents is a high
priority
Objective 10 - Balance strategic planning ...
Objective 11 - Deliver sustainable development .... including by prioritising
brownfield land... to appropriate densities.
Notes / Refs Would like to question the criteria applied to label ‘brownfield land’?
__________________________________________________________________
Q 2 OBJECTION: Development Needs
This is ‘top-down’ unacceptable pressure from successive government directives. We
should push back on the Government. They could be more effective and accountable
and reduce the drivers behind these housing demands, especially in this region. In
response to those revised upward housing targets, regrettably the Plans seem worse
in every subsequent revision. Before new targets are considered, we need a realistic
view and sustainable Plan to support a quality of life in local communities while
protecting our precious natural environment.
__________________________________________________________________
Q3 OBJECTION: Employment
The large residential site allocations, particularly on the west of Bexhill-on-Sea are a
far distance from the main employment opportunities in the Plan. Does this conform
to Fig. 1, Strategic Objectives 5, 7 & 8? Employment is much needed and yet the
anticipated opportunities do not seem to match the huge number of new households
and residents proposed in the Plan.
FEMA plans, being linked to Hastings seems less convincing than say to Eastbourne,
as the urban creep is westward bound. What viable public transport is available?
Where is the closest railway station to Barnhorn Road?
Is it likely new residents would be (a) Mostly economically inactive? (b) Work from
home? (c) Use their cars to add congestion on the A259 or Ninfield Road to and from
Hastings?
__________________________________________________________________
Q 5 OBJECTION: Infrastructure Needs
Infrastructure first, before the development or future commitment to higher targets.
[Plan ref 4.1] “It is vital that growth and new development... is appropriately
3
supported by infrastructure...” Please give a thought to the health and wellbeing of
residents on Barnhorn Road and the natural environment.
It was acknowledged [Plan ref 4.2] there were plenty of comments and feedback in
the previous 2024 version, regarding the deficits in infrastructure, especially with
transport and traffic congestion, sewage etc.. It would certainly compound the
problem with any new developments feeding into the A259, on the Barnhorn Road.
We understand South East Water have informed Tonbridge (12 March 2026) they can
not supply more than 1/3 of proposed housing allocations in their LPA 20 year Plan
and are likely to inform other councils of something similar.
Southern Water should be working to a combined 20 year plan with LPAs, not just 5
years ahead.
Notes / Refs:
Objective 1 in the Strategic Spatial Objective should include; the planning system has a role in seeking to
ensure the combined impacts of urban creep and climate change protect the quality of the water
environment. See para 162 NPPF, December 2024) where it states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account
the long-term implications for flood risk, coastal change, water supply, biodiversity and
landscapes...” Ref: Southern Water, as noted Mar 2026]
“South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation”.[BBC reported, 12 Mar 2026]
__________________________________________________________________
Q6 SUPPORT: Strategic Gaps
Support the retention of our precious green spaces between townships. Referencing
the Plan policy for retention of Strategic Gaps (SD014) [Plan ref 5.13]
__________________________________________________________________
Q7 OBJECTION: Density
From the choices offered, our preference is: Option A [Plan ref figure 7] = Not more
density than the baseline, business as usual.
Option B [Plan ref figure 7] is far too dense, especially as shown in the suburban area
type.
Option C is completely unacceptable [Plan Ref BX19 as example, indicated at 166
dwellings per hectare].
4
Option A for all sites should be the lowest density possible, with generous gardens
and at least 25m buffers beyond this for wildlife corridors. The only exception in
density, could possibly be in the town centre.
Q8 OBJECTION: Overall Development Strategy
This appears to be one-dimensional planning; just housing, housing, housing with
little extra infrastructure, community amenities or commercial attractions to
compensate or reflect the proposed population growth.
Infrastructure First please! Southern Water, South East Water and Highways
invariably seem to support even the largest of site allocations, e.g. BX20 to BX22,
BX24 to BX28 and BX31 to BX40. Therefore at that early proposal stage, they should
immediately set aside their required strategic funding and begin the necessary
upgrades and works beforehand, rather than chasing developers and difficulties at a
late stage. In other words, they should work to a 20 year Plan and not trail years
behind the advancing LPA Planning process, with inadequate afterthoughts and foboffs
for the residents to endure.
__________________________________________________________________
Q9 OBJECTION: Growth opportunities in sub-areas in Fig.10 – The proposed figures are
far too high, especially for Bexhill-on-Sea.
__________________________________________________________________
Q10 OBJECTION: Proposed Vision and development strategy for Bexhill-on-Sea in Fig 13
and 14.
The residential figures are too high, compared to the employment floor space.
Given the older demographic here, being higher than national average, we ask for
more supported or sheltered independent living options for the elderly and/or
disabled in the Bexhill-on-Sea area
(Ref. Plan p 52) Bexhill-on-Sea is becoming less of a community hub, (except for the
DLWP, museum, some pubs and friendly welcoming clubs of interest, run by private
committees etc.) Many shops and banks have closed.
In the Plan with the ‘two towns’ ideology (Ref. Plan p52) linked with Hastings, it
seems a ‘cop-out’ by encouraging Bexhillians to use another town. It offers little
compensation for the lack of provision in Bexhill-on-Sea itself.
Hastings is not always easily reached by public transport, as on occasions when trains
are cancelled due to engineering works*. Meanwhile no equivalent opportunity or
event is offered in Bexhill-on-Sea (*Hastings Bonfire Society parade).
5
Employment: Are there any new exciting commercial opportunities in the offing, to
bring substantial inward investment into the town? Where is our nearest ‘High
Street’ bank now? (Eastbourne or Hastings?) Just to demonstrate two popular
indicators in a thriving high street economy, where is the nearest ‘Greggs’ or
‘MacDonalds’ or a popular retail chain (other than Boots and supermarkets)? We
acknowledge this is not within the scope of this Plan, however, it may reflect the
outlook and trajectory.
A predominance of housing does little to enhance the character. If this Plan is
implemented, our lovely town will become a suburban sprawl, blighted by water
shortages, sewage pollution and traffic congestion with unhealthy outcomes and
irreparable damage to the environment.
In preference instead, could we at least set aside a very generous site, a wildlife
country park, as an essential green lung to the west of Bexhill-on-Sea at Barnhorn
Road?
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. These structures are often decades or even centuries
old and are protected by law, making it illegal to interfere with them. A designated
buffer zone of at least 25 metres (not 15 metres) should be left undisturbed, which
does not include residential gardens.
Notes/ Refs:
HEDNA 2024 suggests the need for Retirement living or sheltered housing and Extra care housing or housing-withcare.
We support some ground floor living type, Specialist Housing for Older People (as defined in the Planning Practice
Guidance – excluding residential care homes and nursing homes which are under Policy HOU10) Ref: p263 Draft
Local Plan (Reg 18) Version April 2024.
__________________________________________________________________
Q17 SUPPORT:
BX3 - London Road and Sackville Road Enhancement Plan. We welcome an
improvement to attract more businesses, only if there is no loss of parking.
__________________________________________________________________
6
Q17 OBJECTION:
BX7 - Sainsburys Site Buckhurst Place. Although we welcome any enhancement to
the street scene and new opportunities for retail and flats above, we object to any
loss of car parking spaces at Sainsburys supermarket or within the town centre. Not
much detail is given.
Notes/ Refs:
Strategic Plan Objective 10 - Balance strategic planning ...
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX13 - Eversley Road Car Park. This is the only car park (35 cars) in this central
location; essential in both daytime for shoppers and /or business clients and in the
evening for local clubs.
It supports access for the over 55s Club venue, just across the road at 45 Eversley
Road and for other meetings and gatherings, including Bexhill Town Council. We
promote accessibility for the communities of all ages to help them socialise and to
prevent isolation and loneliness.
We also want to support the remaining local shops and businesses in the town
centre. This is a well-used parking facility and its loss would be an unwarranted
setback for the community and local commerce.
Notes / Refs:
Strategic Plan Objective 6 - Employment needs of ... local businesses, improving quality and variety of
jobs...
Strategic Plan Objective 10 - Balance strategic planning .
Plan Ref: 3.31 NPPF – “support the role that town centres play at the heart of local communities, by taking
a positive approach to their growth, management and adaptation” ...
__________________________________________________________________
Q17 OBJECTION:
BX16 Land at Pages Lane for any development (care home or housing) causing loss of
meadow open space, mature trees and wildlife habitat.
The trees should be considered for individual and group Tree Preservation Orders.
Some are of such height and scale as can be viewed and enjoyed from a significant
distance.
We would like to question the definition of ‘Brownfield’, as this is a longstanding
open green field. The site gives tranquil character to the neighbourhood and
attractively frames the local scene. It’s a valuable wildlife habitat and supports many
species of birds and mammals, which should be given protection
7
with no disturbance [Environment Act 2021). To support conservation within this
natural setting, a comprehensive wildlife and tree survey should be undertaken with
a presumption to protect e.g. species and their foraging areas. These structures
are often decades or even centuries old and are protected by law, making it illegal to
interfere with them. A designated buffer zone of at least 25 metres (not 15 metres)
should be left undisturbed, which does not include residential or formally managed
gardens.
Notes / Refs:
All site allocations should ensure the natural environment is conserved, enhanced and managed for the
benefit of present and future generations, thereby contributing to sustainable development [ref: Natural
England as noted to RDC, Mar 2026]
Strategic Plan Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
Natural England –“Objective 2 should add; to comply with the objectives of emerging Local Nature
Recovery Strategies (supporting non-strategic policy ENV5: Habitats and Species and strategic policies
GTC7: Local Nature Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF” [Ref: Natural England, as
noted Mar 2026 and the Environment Act 2021].
__________________________________________________________________
Q17 OBJECTION:
BX19 – Car Park & Open Space at The Gorses.
An unnecessary loss of crucial parking spaces and if the proposed development
creeps beyond it, then great risk of harm to the open space, trees and wildlife habitat
would be unacceptable. This car park is very useful and popular, to leave the car and
to take the train to work or for shopping in Hastings or Eastbourne etc. Park and ride
by train, is a preferred mode of movement in strategic planning and the retention of
a station car park offers this incentive. Otherwise, we are just as likely to continue
our whole journey by car (via the congested A259 along Barnhorn Road) and park up
at our destination. Many people who use the train do not live in easy walking
distance of their nearest station.
The Gorses car park is also useful for families going to the beach or when popular
events are held at the Cooden Relais Hotel which attract crowds, like Craft Fairs. So it
can support businesses. When the car park is full any street parking congests
residential roads. The Gorses is not wide enough for on-street parking with 2-way
traffic, including the community bus. This proposal would be detrimental to safety,
the appearance of the street scene and unfair to the local residents.
Also there must be something wrong with the sewage outflow system because there
is a detectable unpleasant odour by this site, nearest to the previous new-builds.
This should be identified and upgraded, rather than exacerbating the problem.
8
We note the proposed density for the site, indicated at 166 dwellings per hectare is
incredibly high. Not more than a few dwellings allowing reasonable amenity space
would fit within the car park area. So we fear there is a serious risk of encroachment
into the open space and causing serious harm to the wild habitat. At one time the
whole area, known as the Gorses, was about three times its present size before it
was developed. The remainder is a beloved Greenfield, not a “Brownfield”, except
for the car park itself.
The open space and ancient wooded area to the south is a very attractive feature,
adding character to the local scene. This valuable wildlife habitat supports many
species, which should be given protection with no disturbance
[Environment Act 2021). A comprehensive wildlife and tree survey should be
undertaken with a presumption to protect e.g. species and their foraging areas.
These structures are often decades or even centuries old and are protected by law,
making it illegal to interfere with them. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs:
Strategic Planning Objective 2 - Maximise nature conservation... and protected habitat areas of Rother and
ensure sensitive development...
[Objective 2 should add; to comply with the objectives of emerging Local Nature Recovery Strategies
(supporting non-strategic policy ENV5: Habitats and Species and strategic policies GTC7: Local Nature
Recovery Areas, GTC8: Biodiversity Net Gain) and NPPF [Ref: Natural England, as noted Mar 2026 and the
Environment Act 2021].
Strategic Planning Objective 3 - Promote... and protect and enhance the significance of... natural heritage,
including its setting...
Strategic Planning Objective 8 - Connectivity of local communities ... sustainable transport measures
Strategic Planning Objective 9 - Support and achieve safe, healthy.....well-being of residents is a high
priority
Strategic Planning Objective 10 - Balance strategic planning ...
Natural England as noted Mar 2026 -
All allocations should ensure the natural environment is conserved, enhanced and managed for the benefit
of present and future generations, thereby contributing to sustainable development
Infrastructure Delivery Plan (IDP) (Plan Ref: 4.8 4.9)
__________________________________________________________________
Q17 OBJECTION:
BX20 - Dwellings off Spindlewood Drive (146)
This proposal will have a severe impact on the traffic on the heavily congested A259
Barnhorn Road, which is already operating above capacity. An increase in the number
of vehicles needing to access this trunk road will have a negative impact on the lives
of local people and on all its users.
9
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that their 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. It therefore cannot deal with more sewage unless the
pipe is replaced with a much larger one, which would mean completely closing and
digging up the road.
Meanwhile, South East Water, has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is a huge and sensitive Greenfield site. Wildlife species and their natural habitats
including trees and mature shrubs should be respected and protected, leaving ample
wildlife corridors as standard. This includes non-designated sites in addition to the
sites labelled for special protection. All allocations should ensure the natural
environment is conserved, enhanced and managed for the benefit of present and
future generations, thereby contributing to sustainable development [ref: Natural
England as noted Mar 2026]
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX21 - Dwellings (20) adjacent to the caravan site
This proposal again, like BX20, will add further impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
10
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
This is another precious sensitive Greenfield site. Wildlife species and their natural
habitats including trees and mature shrubs should be respected and protected,
leaving ample wildlife corridors as standard. This includes non-designated sites in
addition to the sites labelled for special protection. All allocations should ensure the
natural environment is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development [ref:
Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX22 - Dwellings (400) + plus 3000 m² commercial space south of Barnhorn Road
This is the probably the worst proposal in the whole Plan, on a vast and extremely
sensitive Greenfield site. It may offer some employment, however it is the most
sensitive of sites. Not a balanced plan.
The site is adjacent 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.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
11
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
__________________________________________________________________
Q17 OBJECTION:
BX23 - Dwellings north of Rosewood Park (340)
Similarly, this huge proposal on another precious Greenfield site will have a severe
impact on wildlife and natural mature habitats.
The traffic on this heavily congested A259 Barnhorn Road, is already operating above
capacity. An increase in the number of vehicles needing to access this trunk road will
have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted 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. It therefore cannot deal with more sewage unless the
9” pipe is replaced with a larger one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
wildlife and tree surveys should be made with a presumption to protect e.g. species and their foraging areas. A designated buffer zone of at least 25 metres (not 15
metres) should be left undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX24 - Dwellings east of Sandhurst Lane (25)
This proposal, as with BX20, BX21, BX22, BX23, BX25, BX26, BX27 and BX28 will have
an equally severe impact on the traffic on the heavily congested A259 Barnhorn
Road, which is already operating above capacity. An increase in the number of
vehicles needing to access this trunk road will have a negative impact on the lives of
local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
The narrow 9” diameter sewer pipe under Barnhorn Road, already choked, cannot
cope with the current quantity of sewage from the buildings on both sides of the
road in hard rain conditions. So cannot deal with more sewage unless the narrow 9”
pipe is replaced with a larger one, which would mean completely closing and digging
up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX25 - Medical Centre with 86+ parking spaces and light industrial units with 50+
parking spaces.
Although this may appear to offer worthy facilities and employment, this is not the
right site allocation and will exacerbate the concerns raised in the site allocations as
BX20, BX21, BX22, BX23, BX24, BX26, BX27 and BX28. It would have an equally severe
13
impact on the traffic on the heavily congested A259 Barnhorn Road, which is already
operating above capacity. An increase in the number of vehicles needing to access
this trunk road will have a negative impact on the lives of local people and on all its
users.
We are aware this site allocation BX25 may be likely to progress, regardless. This is
already of concern because the negative effects of these developments will be
experienced by all users of this trunk road, with more frequent hold-ups and longer
queues of air-polluting vehicles at the Barnhorn Green/Rosewood Park traffic lights.
Additional housing development would be disastrous for road-users and Little
Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has confirmed that the narrow 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. It therefore cannot deal with more sewage unless the
narrow pipe is replaced with a wider one, which would mean completely closing and
digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive and
objective wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
14
__________________________________________________________________
Q17 OBJECTION:
BX26 - Dwellings south of Sandhurst Lane (25)
Yet again, this proposal will have a severe impact on the traffic on the heavily
congested A259 Barnhorn Road, which is already operating above capacity. An
increase in the number of vehicles needing to access this trunk road will have a
negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
It is only a narrow 9” diameter sewer pipe (probably less with ‘fat build-up’) under
the Barnhorn Road and it cannot cope with the current quantity of sewage from the
buildings on both sides of the road in storm conditions. It therefore cannot deal with
more sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. A designated buffer zone of at least 25
metres (not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
15
BX27 - Dwellings on Beeches Farm and land north of Barnhorn Road (540 )
This is an alarming proposal, bringing the most severe adverse impact on the traffic
on the heavily congested A259 Barnhorn Road, which is already operating above
capacity. Any increase in the number of vehicles needing to access this trunk road
will have a negative impact on the lives of local people and on all its users.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water has admitted that the narrow 9” sewer pipe (probably less with ‘fat
build-up’) under the Barnhorn Road and cannot cope with the current quantity of
sewage from the buildings on both sides of the road in storm conditions. It therefore
cannot deal with more sewage unless the 9” pipe is replaced with a larger one, which
would mean completely closing and digging up the road.
South East Water, meanwhile has just warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive
unredacted wildlife and tree surveys should be made with a presumption to protect
e.g. species and their foraging areas. These structures are often decades or
even centuries old and are protected by law, making it illegal to interfere with them.
A designated buffer zone of at least 25 metres (not 15 metres) should be left
undisturbed, which does not include residential gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION:
BX28 - Dwellings at Northeye and adjoining land (384)
It is not a welcome resolution to develop beyond the Northeye Brownfield site. No
Greenfield should be included as this is extremely sensitive land and we are not
16
persuaded by the HELAA. We object to the density and proposed number of
dwellings. The recreational space including sports ground should be provided, along
with either a modest residential setting or a school – should all fit within the
Brownfield site boundary alone.
The former RAF site would need to be carefully and safety cleared (removing the
toxic asbestos throughout the existing buildings and grounds with due consideration
to the close neighbouring residents).
School places in most years are in very short supply. Little Common Primary School
and Bexhill Academy are almost at capacity. We would not object to a school or a
small estate with sheltered bungalows to provide independent living and specialist
care for elderly, supported by a warden 24/7. Both these options would utilise a
Brownfield site and offer an evidenced need in the area. However, more general
housing does not and therefore we do not support the proposal in this Plan.
This proposal, whatever size, will add impact on the traffic on the heavily congested
A259 Barnhorn Road, which is already operating above capacity. An increase in the
number of vehicles needing to access this trunk road will have a negative impact on
the lives of local people and on all its users.
The negative effects of all these developments will be experienced by all users of this
trunk road, with more frequent hold-ups and longer queues of air-polluting vehicles
at the Barnhorn Green/Rosewood Park traffic lights. Any additional housing
development would be disastrous for road-users and Little Common as a whole.
The air-polluting traffic, the incomplete and unsafe cycle-lane and the unreliable bus
service mean that most residents will be reliant on car usage for their travel needs.
Southern Water had already confirmed 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. It therefore cannot deal with more
sewage unless the 9” pipe is replaced with a larger one, which would mean
completely closing and digging up the road.
South East Water, meanwhile has now warned Tonbridge & Malling Borough Council
(TMBC) that it cannot supply water to 2/3 of their new Plan for dwellings due to
insufficient infrastructure capacity. It is likely to tell other councils something similar.
Wildlife species and their natural habitats including trees and mature shrubs should
be respected and protected, leaving ample wildlife corridors as standard. This
17
includes non-designated sites in addition to the sites labelled for special protection.
All allocations should ensure the natural environment is conserved, enhanced and
managed for the benefit of present and future generations, thereby contributing to
sustainable development [ref: Natural England as noted Mar 2026]
To demonstrate appropriate conservation of the natural setting, comprehensive unredacted
wildlife and tree surveys should be made with a presumption to protect e.g.
species and their foraging areas. A designated buffer zone of at least 25 metres
(not 15 metres) should be left undisturbed, which does not include residential
gardens.
Notes / Refs
South East Water has warned Tonbridge and Malling Borough Council (TMBC) that it cannot supply water to twothirds
of the ~19,000 new homes planned for the borough by 2042 due to insufficient infrastructure capacity. This
follows significant,, repeated water supply failures in late 2025/early 2026, prompting a March 2026 Ofwat
investigation.[BBC reported 12 Mar 2026]
__________________________________________________________________
Q17 OBJECTION
BX50 - Land at Sidley Car Park, Ninfield Road, Bexhill-on-Sea
This car park provides an essential amenity for the local community and allows access
to shops and services. No loss of parking spaces is acceptable on this site.
__________________________________________________________________
Thank you for your attention, taking the time to consult and for reading this response.
Yours faithfully, PERRY