BT1 Fails to demonstrate safe and suitable highway access Would increase traffic and highway safety risks on Hastings Road Would cause harm to the High Weald National Landscape Places additional pressure on already constrained infrastructure Is located in a position that is not sustainably connected to services For these reasons, the allocation does not meet the requirements of national planning policy, statutory landscape protection duties, or the tests of soundness. I therefore respectfully request that Site BT1 be removed from the Local Plan.

BT8 Fails to demonstrate safe and suitable highway access Would increase traffic and highway safety risks on Hastings Road Would cause harm to the High Weald National Landscape Places additional pressure on already constrained infrastructure Is located in a position that is not sustainably connected to services For these reasons, the allocation does not meet the requirements of national planning policy, statutory landscape protection duties, or the tests of soundness. I therefore respectfully request that Site BT8 be removed from the Local Plan.

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)

Date:



We are writing to formally submit our objection to the proposed allocations of site BT1 and adjacent sites. As local residents we have suffered the Blackfriers build on unsuitable land which has had a huge impact on the local area with mass destruction of trees, vegetation and wild life, the pollution of the build with the builders parking everywhere, which of course has affected the air quality in the local area. Which leads us to believe that another such site will have the same impact on the surrounding area.

This development is unsupportable based on material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies).



1. Traffic Congestion and Safety on Hastings Road



Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites mentioned above). The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding a major junction to this existing chaos without significant infrastructure upgrades is negligent.

Junction Interference and "Staggered" Conflict At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (250 dwellings) will frequently be blocked by "tailback" traffic exiting or entering Blackfriars (210+ dwellings). This creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.

The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.

● Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.

● Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.

Placing two high-volume junctions in a high-speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.









2. Environmental Impact and Air Quality

Unjustified Harm to the National Landscape (AONB) and Greenfield Land

● Greenfield Loss: BT1 proposes building on 11.09 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.

● National Landscape (AONB) Impact: The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 40 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major development should only occur in exceptional circumstances (NPPF Paragraph 189).

● Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 250 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises.

Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT1 explicitly acknowledges a "surface water flooding risk to the southern boundaries of the site". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on 11 hectares of land already identified as a flood risk is reckless planning that endangers existing properties downhill, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests.

3. Infrastructure Deficits and Delivery Failures

Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management)

● Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.

● Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.

● Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.

The Blackfriars Precedent: "Watered Down" Commitments We have no confidence in the "policy compliant" assurances for BT1 because we have seen the Council fail to deliver on similar promises at Blackfriars. That development was sold as a "gold standard" of green, high-tech housing. However, documents show it faced an £8 million funding gap and underwent "redesign" to "better align with market demand" and "improve efficiencies" due to rising costs. If the flagship Blackfriars project had to be value-engineered due to market pressures, the high-quality, landscape-led masterplan promised for BT1 is likely to be similarly watered down once permission is granted.

Conclusion

This proposal expands development to 250 units on a Greenfield National Landscape site amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further.

Yours faithfully,

Cooper Estates Strategic Land Limited submits this representation on behalf of landowners within the eastern part of the draft allocation at Battle, (Policy Reference: BT1), as identified within the Rother Local Plan 2025–2042 Development Strategy and Site Allocations Regulation 18 Draft, published for public consultation.

The allocation is fully supported. The site represents a logical and sustainable extension to Battle and has clear potential to deliver approximately 220 dwellings alongside open space and community uses, as set out in the draft allocation. The broad approach to development, including suburban character and landscape-led design, is also strongly supported.

In supporting the allocation, it is suggested that a greater degree of flexibility within the policy wording would assist in ensuring effective and timely delivery. The site comprises a number of distinct parcels with varying characteristics and constraints, and it is therefore preferable that the policy framework allows for a responsive and adaptable approach to delivery.

The eastern parcel, in particular, represents a suitable and available opportunity to come forward as an early phase of development. It has the ability to achieve a clear and deliverable point of access from Hastings Road, in accordance with the allocation requirements. This provides a strong basis for early delivery, without reliance on infrastructure across the wider site.

In this context, it is suggested that the requirement for vehicular access from both Hastings Road and Glengorse is applied flexibly, recognising that an initial phase of development could be appropriately served from Hastings Road. This would reflect the site’s characteristics and support a deliverable early phase, with the potential for additional connections to be delivered as the wider allocation comes forward.

Similarly, it is preferred that the requirement for a single comprehensive masterplan is framed in a way that supports a coordinated approach to phased or parcel-based delivery. This would allow development to come forward in a timely manner, while still ensuring that proposals demonstrate integration with, and do not prejudice, the wider allocation.

It is also suggested that the access strategy allows for proportionate and deliverable solutions on a phased basis, recognising the role of Hastings Road as a primary and effective access point capable of facilitating early delivery from the eastern parcel.

Finally, it is considered that the stated capacity of approximately 220 dwellings, or up to 250 dwellings as referred to in the supporting text, should be treated as indicative, allowing for appropriate optimisation through detailed design and layout.

With these refinements, the allocation would be better positioned to achieve its full potential, ensuring flexibility, deliverability, and the ability to contribute to housing supply at an early stage in the plan period.

I object to the plans BT2. My objections are due to the environment effects, strain on local infrastructure and amenities.
The proposed area is adjacent to ancient woodland that is home to many different species including bats, deer and many different bird species including owls, woodpeckers and buzzards. Building on thos site will have detrimental effect on their habitat. It is also adjacent to Marline valley nature reserve, which will also be at risk of pollution from the building work.
The proposed entrance of the development is onto a already busy and congested road.
I feel there would be an increase risk of flooding due to surface water. There has recently been issues with the southern water pump near this area as it couldn't cope with the current houses and surface water.
I feel local schools, Gps, dentists and hospitals already struggle with the amount of residents within this area and there is no sufficient services to accommodate more people

BT4. I own this approved site (previously BAT0109), and BAT0035 (2/3rds), and BAT0048 Caldbec House South Field, and BAT0009 Hughs' Field, a total of 12 acres. It has been in continuous family ownership for 100+ years, and BT4 is the only site picked in North Battle which does not add to traffic to the stuffed High Street from Tesco to Claverham. The Beech farm land is fed off North Trade Road. In my view it is therefore the best location for more housing truly in Battle with least damage, all within close walking distance to town. Almost all of it is unseen from the road or paths, because of the relief of the land, and because of dense hedges and woodland, some TPOd. I have been doing minor development at this site since 1995, adding to local housing stock and long term and tourism-supporting short rentals. Originally approved for 5-9 at Caldbec House as BAT0109, I think I can provide sites for 20--25 more homes at this location, on the three different deeded parcels which make up the present holding. I have five existing entrances to the lands with a private road as well, and am prepared to dedicate and covenant half of the land as green space for non-development, protecting sightlines of the existing homes.

I do not expect to use all of the 5-9 assigned to the main garden of Caldbec House, and i suggest some not built there might be reassigned to other areas, not least as I have this month added The Dodo House from my father's estate to Caldbec. Here is my proposal.
Deed 1, Caldbec House. Apart from BT4, I propose a large family house either end of the south part of Procession Field, BAT0048, hidden from road and town behind high hedges and in a dip in the land, sensitive to the views from existing houses above. Three small houses, one or one and a half storey, to the south of Birchwood, would suit starters or finishers. Road access would be from the existing metalled road at Caldbec House Loft, would turn out of sight of Caldbec House to the right and west to the three, down past the house in the hollow to the east of the Cottage, behind and along the hedge on the south boundary of the field to a turning circle to Procession House East. I have sold land to West Court now heavily hedged and higher so its views are respected, I retained heavy planting to the south of Hammonds, likewise, and the heavily wooded land I sold to Birchwood after its creation the owners chose to raze recently, and have planted new hedging. There is a berm to the north of Procession House East where I am relocating a beech hedge from the garden, so the Herritage Asset of Caldbec House will retain its views out to the Abbey and the sea with little effect.

Deed 2 The Dodo House. New Site Offering. In returning this part of Caldbec to the main property, in the garden curtilage I will keep the Brick Museum and either annex it to the unanimously approved Museum House, or apply for it to be a separate small dwelling, with driveway possible from Dodo Lane or Caldbec House Cottage drive. I will be selling Dodo House and Caravan Shed 20x26ft and 12ft high - highly suitable for an annex - shortly. I have cleared the overgrown fields and think three family homes can go in the field south of Dodos, Procession Field East, accessed from Dodo Lane. Three starter/finisher (i.e. one main ground floor bedroom one upstairs carer/child bedroom) homes can go to the east of the ancient hedge line just restored. Mains sewer and high voltage cable are both on site from when all was to be expropriated for a care home. Two more homes can continue the line of Prospect Cottages, Holly Lodge retaining most of its recently much-enhanced view. Three more can go in the land between Windgrove Cottages and Caldbec Lodge 1, as it is already developed land curtilege, recently referred to in planning approval for Holly Lodge as suburban. Parking is available in quantity if there is a desire to get rid of the horrible and unsafe lot newly created the wrong side of the road from Dodo Lane.

Deed 3. Hughs' Field. BAT0009. This has been refused twice but is now different and should be reviewed again. I suggest two terraces of three houses, with a large covenanted gap between so nothing appears between the TPOd trees from the road, preserving the sightline from Caldbec House. The need for housing is greater than when last proposed, the entrance has been enlarged and fully fenced from the road so not seen, and electric and water is on site, and all aspects were approved at vast expense and effort. And the site is now distinguished from BAT0073, whereas before both very different parcels were muddled together.

To the Planning Strategy Team,

I am writing to submit my formal objection to the proposed Rother Local Plan 2025–2042. As a resident of Battle, I am deeply concerned that the current proposals represent an unsustainable level of growth that will irreparably damage the historic character, landscape integrity, and infrastructure of our market town.

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

Q2: Proposed Housing Target (Policy 3.24 / Figure 2)
I strongly object to the proposed housing target of 8,427 dwellings. The move to a “standard method” calculation of 912 units per year — a threefold increase over previous targets — is fundamentally incompatible with a district where 83% of the land is protected within the High Weald National Landscape.

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

Q8: Overall Development Strategy and the High Weald National Landscape
The strategy to focus growth within the High Weald National Landscape contradicts the Council’s duty to conserve and enhance natural beauty. While the plan refers to prioritising brownfield land, the proposed allocations rely heavily on greenfield development.

The justification that housing need constitutes “exceptional circumstances” for major development in a protected landscape is not convincing. This approach risks eroding the distinct character of Battle and surrounding settlements.

Q36: Proposed Site Allocations in Battle (Policies BT1 to BT11)

Objection to Site BT1: Land south of Hastings Road, Battle
I strongly oppose the allocation of this site for 220 dwellings.

Traffic and safety: Additional access onto the A2100 and surrounding roads will worsen congestion and increase accident risk.

Density: A density of 40 dwellings per hectare is inappropriate for this rural edge-of-town location.

Environmental impact: The proximity to ancient woodland and priority habitats means development would cause significant ecological harm.

Objection to Site BT7: Land at Almonry Farm, Battle
I object in full to the proposed development of this site for 80 dwellings.

Heritage impact: The site lies close to the 1066 Battlefield and Battle Abbey, and development would harm their setting.

Listed buildings: The proposals would negatively affect the setting of the Grade II listed Lower Almonry Farmhouse.

Landscape and biodiversity: The site contributes significantly to the character of the area and supports valuable habitats.

Flood risk: Development may increase surface water runoff and exacerbate local flooding.

Safety concerns: Increased traffic near busy junctions and disruption to footpaths used by Claverham students raises additional risks.

Conclusion
The Council must reconsider this scale of development. Our National Landscape and historic heritage should be protected for future generations, not compromised by unsustainable housing targets. I urge the Council to remove sites BT1 and BT7 from the Local Plan.

I object to the proposed development of the Breadsell Farm site, BT2.

This is active farmland, and its loss would mean the permanent loss of productive agricultural land. Once developed, it cannot be replaced, and this should be given proper weight.

The site is also in a sensitive location, bordering ancient woodland and close to Marline Valley Woods SSSI. These are irreplaceable habitats, and development risks indirect harm through changes in drainage, increased disturbance and pressure from nearby housing. The fact that further monitoring is still required shows the impacts are not yet fully understood.

There are also concerns about infrastructure, with reliance on the A2100 and limited safe pedestrian access.

In addition, the proposal depends on a wider cross-boundary scheme, which is uncertain, making this allocation speculative.

Overall, this is not a suitable or sustainable site for development, and I strongly object.

BT2. There are breeding birds. There are deers and many other woodland animals who’s habitat will be destroyed if this goes ahead.

1. BT1 to 11 appear to encroach development beyond existing residential boundaries losing important buffer zone.
2. BT5 appears to be a wooded area which should not be encroached upon.
3. Battle already has, in recent years, undergone significant development but has not benefitted from improved infrastructure. Battle is a small market town of historic importance and should retain this important feature. Our existing wildlife, pasture, trees, hedgerow and woodland cannot be replaced and such areas should not be considered for development.

Object to ref BT2
I fully object to the site located at Breadsell, Battle being added to the local plan allocation, for the following reasons;
1 Due to the location being adjacent to an area of SSSI the ecological and hydrological impact to the SSSI is too high.
2. This location at BT2 which links to a wider propsed area for development by HBC was previously rejected as quote
"A scoping level hydrological and hydrogeological assessment of a proposed housing development on this site was carried out in 2009 by specialists, Rigare, to investigate the potential effects on the Marline Valley Woods SSSI. This indicated that a development would likely lead to impacts on the SSSI, and set out that significant work, including a lengthy period of ecohydrological monitoring, is required to understand impacts. Consequently, following advice from Natural England, the site was not included in the adopted Hastings Local Plan"
And should be rejected for these same reasons again.
3. The BT2 area frequently floods across the adjacent highway A2100 during moderate to heavy rainfall and substantial development would increase flood risks
4. Increased traffic to an already conjested A2100 and tributary road The Ridge West is not sustainable for traffic management especially when considered alongside recent new housing developments located further along The Ridge West at the top of Harrow Lane and in the other direction new and propsed developments in Battle in BT1 and Starrs Mead will make the Hastings Road A2100 highly conjested and unsafe due to increased traffic. Furthermore lack of pedestrian access and bus routes would make this area reliant on car use.
5. Impact of over development on both water provision and sewage across the whole of the Hastings and Rother area with water companies unable to meet and maintain current use
6. Risk to the current woodland corridor and adjacent grassland which has TPO areas and links to both the SSSI at Marline Valley Woods and Coneyburrow woods should be actively preserved to support habitat.
7. The strategic gap between Hastings Battle and Crowhurst should be maintained The area BT2 would allow access to land and over development by HBC with proposed wider development linking to BT2
8. Due to the sloping site land stability and geotechnical reports would need to be provided to ensure no risk to the SSSI and adjoining habitats.

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)

We are writing to formally submit our objection to the proposed allocations of site BT1 and adjacent sites. As residents of Hastings Road, we have direct, daily experience of the site conditions. This development is unsupportable based on material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies).

1. Traffic Congestion and Safety on Hastings Road

Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites mentioned above). The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding a major junction to this existing chaos without significant infrastructure upgrades is negligent.
Junction Interference and "Staggered" Conflict At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (250 dwellings) will frequently be blocked by "tailback" traffic exiting or entering Blackfriars (210+ dwellings). This creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.
The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
 Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
 Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.
Placing two high-volume junctions in a high-speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.

2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
 Greenfield Loss: BT1 proposes building on 11.09 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
 National Landscape (AONB) Impact: The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 40 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major development should only occur in exceptional circumstances (NPPF Paragraph 189).
 Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 250 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises.
Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT1 explicitly acknowledges a "surface water flooding risk to the southern boundaries of the site". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on 11 hectares of land already identified as a flood risk is reckless planning that endangers existing properties downhill, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests.

3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management)
 Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
 Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
 Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.
The Blackfriars Precedent: "Watered Down" Commitments We have no confidence in the "policy compliant" assurances for BT1 because we have seen the Council fail to deliver on similar promises at Blackfriars. That development was sold as a "gold standard" of green, high-tech housing. However, documents show it faced an £8 million funding gap and underwent "redesign" to "better align with market demand" and "improve efficiencies" due to rising costs. If the flagship Blackfriars project had to be value-engineered due to market pressures, the high-quality, landscape-led masterplan promised for BT1 is likely to be similarly watered down once permission is granted.

Conclusion
This proposal expands development to 250 units on a Greenfield National Landscape site amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further.

I am writing to formally object to the proposed allocation of land at Almonry Farm (Policy BT7) within the Draft Rother Local Plan (2025–2042).

I am a local resident living in close proximity to the site, which forms part of the open landscape directly behind existing homes. This land contributes significantly to the character of Battle and to the living environment of those who live here.

The policy itself acknowledges that the site is highly constrained. It lies within the High Weald National Landscape and in close proximity to the Registered Battlefield, Battle Abbey and other designated heritage assets. The requirement for multiple assessments and protections demonstrates the sensitivity of this location. In my view, this is not an appropriate site for housing allocation, as development would inevitably harm the character and setting of this historically significant landscape.

The proposal would result in the permanent loss of greenfield land. Once this land is developed, it is lost forever, and the rural setting that defines this part of Battle cannot be recreated.

There are also clear environmental constraints. The site borders ancient woodland and supports biodiversity, including protected and priority species. The need for buffer zones and mitigation measures highlights the ecological importance of the site and the risk of irreversible harm.

Flood risk is a further concern, with parts of the site identified as being at risk from surface water flooding. Developing greenfield land in such areas has the potential to worsen runoff and impact neighbouring properties.

Traffic and highway impact is a major issue. North Trade Road and the A2100 are already heavily used and frequently congested, as they are key routes in and out of Battle. Traffic regularly builds up and can become difficult to manage even under current conditions. The addition of a significant housing development, with access via Tollgates, would inevitably increase traffic and place further strain on roads that are already under pressure. This is particularly concerning given the proximity to Claverham Community College and the presence of pedestrians and school children.

Local infrastructure is also already stretched. GP surgeries, schools and local services are operating at or near capacity, and there is no clear or guaranteed provision to ensure that the necessary infrastructure improvements would be delivered alongside this development.

Overall, the number and scale of constraints affecting this site demonstrate that it is not suitable for allocation. This is not a case where impacts can simply be designed around or mitigated without fundamentally changing the character of the area. This is not a suitable location for development, and no amount of mitigation would outweigh the harm caused.

For these reasons, I strongly object to the inclusion of Almonry Farm (Policy BT7) as a housing allocation and request that this site be removed from the Draft Local Plan.

I am writing to submit my formal objection to the proposed Rother Local Plan 2025–2042. As a resident of Battle, I am deeply concerned that the current proposals represent an unsustainable level of growth that will irreparably damage the historic character, landscape integrity, and infrastructure of our market town.

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

Q2: Proposed Housing Target (Policy 3.24 / Figure 2)
I strongly object to the proposed housing target of 8,427 dwellings. The move to a “standard method” calculation of 912 units per year — a threefold increase over previous targets — is fundamentally incompatible with a district where 83% of the land is protected within the High Weald National Landscape.

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

Q8: Overall Development Strategy and the High Weald National Landscape
The strategy to focus growth within the High Weald National Landscape contradicts the Council’s duty to conserve and enhance natural beauty. While the plan refers to prioritising brownfield land, the proposed allocations rely heavily on greenfield development.

The justification that housing need constitutes “exceptional circumstances” for major development in a protected landscape is not convincing. This approach risks eroding the distinct character of Battle and surrounding settlements.

Q36: Proposed Site Allocations in Battle (Policies BT1 to BT11)

Objection to Site BT1: Land south of Hastings Road, Battle
I strongly oppose the allocation of this site for 220 dwellings.

Traffic and safety: Additional access onto the A2100 and surrounding roads will worsen congestion and increase accident risk.

Density: A density of 40 dwellings per hectare is inappropriate for this rural edge-of-town location.

Environmental impact: The proximity to ancient woodland and priority habitats means development would cause significant ecological harm.

Objection to Site BT7: Land at Almonry Farm, Battle
I object in full to the proposed development of this site for 80 dwellings.

Heritage impact: The site lies close to the 1066 Battlefield and Battle Abbey, and development would harm their setting.

Listed buildings: The proposals would negatively affect the setting of the Grade II listed Lower Almonry Farmhouse.

Landscape and biodiversity: The site contributes significantly to the character of the area and supports valuable habitats.

Flood risk: Development may increase surface water runoff and exacerbate local flooding.

Safety concerns: Increased traffic near busy junctions and disruption to footpaths used by Claverham students raises additional risks.


The Council must reconsider this scale of development. Our National Landscape and historic heritage should be protected for future generations, not compromised by unsustainable housing targets. I urge the Council to remove sites BT1 and BT7 from the Local Plan.

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

I am writing to formally submit our objection to the proposed allocations of sites BT6 and BT7. As residents of North Trade Road, we have direct, daily experience of the site conditions. These developments are unsupportable based on material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies).


1. Traffic Congestion and Safety on North Trade Road
North Trade Road is already at breaking point. Traffic is backed up every morning and afternoon, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of new 10 dwellings in BT6 and 80 dwellings in BT7. The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding major junctions to this existing chaos without significant infrastructure upgrades is negligent.
Junction Interference and "Staggered" Conflict: At a distance of around 600 metres, these two major junctions will interfere with one another and North Trade Road would inevitably be blocked by "tailback" traffic exiting or entering BT7 (80 dwellings), especially considering that in between BT6 and BT7 Claverham College is located with around 1,150 students being dropped off in the morning and picked up in the afternoon – both of which already causing congestion on North Trade Road. All this creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.

The 30mph to 40mph Transition Danger: The site (BT6) sits at a critical transition point where the speed limit increases / decreases from 30mph to 40mph.
• Acceleration Risk: Vehicles traveling outbound (west bound on North Trade Road) are accelerating where the BT6 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from west on North Trade Road (inbound) often carry higher speeds before decelerating.
Placing a high-volume junction in a high-speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.


2. Environmental Impact and Air Quality

Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT6 and BT7 propose building on 0.58 and 4.80 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
• National Landscape (AONB) Impact: The sites are within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 35 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major developments should only occur in exceptional circumstances (NPPF Paragraph 189).
• Ancient Woodland, Deciduous Woodland Priority Habitat and Heritage Constraints: The construction of a minimum of 10 (BT6) and 80 (BT7) homes will inevitably sever wildlife corridors, mature trees and hedging, most importantly ancient woodland. Both the BT6 and the BT7 proposals threaten and affect Ancient Woodland and Deciduous Woodland Priority Habitat located adjacent to the sites. The BT6 plans negatively impact Grade II listed buildings: Beacon Cottage as mentioned in the policy text as well as adjacent Frederick Thatcher Place which is not mentioned in the policy text despite the development being right next to Frederick Thatcher Place. Further to that, BT7 would have an impact on Grade II listed Lower Almonry Farmhouse adjacent to what would be the access to the site, and the site would require an assessment and evaluation of the site’s archaeological potential; the policy text also highlights the site having potential to be of high value for biodiversity including protected species; furthermore it mentions the proximity to heritage assets including the Registered Battlefield where the 1066 Battle of Hastings was fought and Battle Conservation Area.

Flooding Risk and Surface Water (NPPF Paragraph 170): The policy texts for both BT6 and BT7 explicitly acknowledge that parts of the sites are at risk of surface water flooding. Replacing natural drainage with impermeable surfaces (housing/roads) on land already identified as a flood risk is reckless planning that endangers existing properties, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests.


3. Infrastructure Deficits and Delivery Failures

Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management).
• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
• Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
• Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.

The Blackfriars Precedent: "Watered Down" Commitments We have no confidence when the policy text for BT7 mentions that “the site is well located in relation to amenities and services in Battle” but no assurances are given how these amenities and services would be sufficient for that many additional dwellings (BT6 doesn't even mention any of that) – we have seen the Council fail to deliver on similar promises at Blackfriars. That development was sold as a "gold standard" of green, high-tech housing. However, documents show it faced an £8 million funding gap and underwent "redesign" to "better align with market demand" and "improve efficiencies" due to rising costs. If the flagship Blackfriars project had to be value-engineered due to market pressures, “an appropriate layout, form and detailed design to ensure the conservation and enhancement of the landscape and character of the High Weald National Landscape and the protection of the setting of heritage assets” for BT7 is likely to be similarly watered down once permission is granted; the same applies to the promise mentioned in the BT7 policy text of “an area of public open space (and no built development) across the western part of the site in line with the ratios indicated above, in order to protect the setting of the adjacent listed building and views from the Battle Abbey Gatehouse Scheduled Monument”.

Conclusion

These proposals expand development to 10 (BT6) and 80 (BT7) dwellings on a Greenfield National Landscape site amidst an infrastructure crisis, with both sites at risk of surface water flooding and threatening ancient woodlands as well as Grade II listed buildings. The plans are unsound as they ignore statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plans further.

Yours faithfully,

To: Rother District Council Planning Department

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)
Date:

We are writing to formally submit our objection to the proposed allocations of site BT1 and adjacent sites. As residents of Hastings Road, we have direct, daily experience of the site conditions. This development is unsupportable based on material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies).

1. Traffic Congestion and Safety on Hastings Road

Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites mentioned above). The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding a major junction to this existing chaos without significant infrastructure upgrades is negligent.
Junction Interference and "Staggered" Conflict At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (250 dwellings) will frequently be blocked by "tailback" traffic exiting or entering Blackfriars (210+ dwellings). This creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.
The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
• Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.
Placing two high-volume junctions in a high-speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.




2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT1 proposes building on 11.09 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
• National Landscape (AONB) Impact: The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 40 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major development should only occur in exceptional circumstances (NPPF Paragraph 189).
• Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 250 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises.
Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT1 explicitly acknowledges a "surface water flooding risk to the southern boundaries of the site". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on 11 hectares of land already identified as a flood risk is reckless planning that endangers existing properties downhill, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests.
3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management)
• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
• Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
• Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.
The Blackfriars Precedent: "Watered Down" Commitments We have no confidence in the "policy compliant" assurances for BT1 because we have seen the Council fail to deliver on similar promises at Blackfriars. That development was sold as a "gold standard" of green, high-tech housing. However, documents show it faced an £8 million funding gap and underwent "redesign" to "better align with market demand" and "improve efficiencies" due to rising costs. If the flagship Blackfriars project had to be value-engineered due to market pressures, the high-quality, landscape-led masterplan promised for BT1 is likely to be similarly watered down once permission is granted.
Conclusion
This proposal expands development to 250 units on a Greenfield National Landscape site amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further.

RE: Objection to proposed Allocation Policy BT1 (Land south of Hastings Road, Battle) Draft Rother plan (2025-2042)

I live at [address redacted] Hastings Road, Battle. [post code redacted] which backs onto the proposed allocation for development of site known as BT1. Also adjacent to sites BT8 and BT10. Please see my objections to this proposal which I have, for convenience, stated in bullet points.

• Pressure on already congested and busy road. This stretch of Hastings Road (A2100) cannot cope with additional traffic. During morning and afternoon rush hours the road is at a standstill, and this is without the new Tapestry development (Blackfriars) being built or open yet. The same at the weekends too.

• Disruption by increased traffic, pollution and noise on already busy road.

• In addition, any local road closures or diversions will bring more traffic through Battle town centre which is already a bottleneck.

• No safe footpath or pavement along this stretch Hastings Road for walking to Battle. Only a narrow pavement on one side and not wide enough for a mobility scooter, pram, or dog walker. The need to step into the road to avoid other people makes it unsafe, and a danger to life. There is history of fatalities on this section.

• Lack of parking or stopping places on the main road. No safe places for van deliveries, except on the pavement or by blocking the road. Not a Red-Route.

• Seriously dangerous to cross the road, 40 mph zone, no lights or zebra crossings anywhere except in Battle town.

• Harm to conservation area and impact on historic character of Battle town.

• Loss of green spaces and natural habitat for wildlife (impact on protected species). Negative impact on High Weald National Landscape.

• Urbanisation of countryside and lack of proper ecological survey. Loss of ancient woodland, trees, hedgerows, and wildlife corridors.

• Unsafe site access onto the A2100. Proposed site entrance immediately opposite the Blackfriars (Tapestry) main development entrance too.

• Pressure on local services, lack of amenities. No schools within a mile or more No doctor. No dentist. No recreational facilities.

• Overdevelopment, too many houses in the area. Long construction timelines affecting quality of life.

• Shortage of water supply to the area. Not enough for current needs. The government are restricting development considering this.

• Noise disturbance during and after construction. We have suffered noise pollution from the Blackfriars development (opposite) for 2 years now and it is nowhere near complete yet.

This proposal represents an overdevelopment of the area, is out of character with locality and surrounding properties, and would harm the HWNL.

Surely there are other more suitable neighbourhood areas to build on.

To conclude may I strongly suggest that the council remove this proposed allocation.

I am a resident of Battle and I fully support BT8 as a well thought through site plan, which enhances the neighbourhood rather than scars it: -

BT8 (Land adjacent to 1 Loose Farm Cottages, Battle) should be assessed on policy consistency. It provides clear criteria-based policies against which any site can be tested. The key question is therefore whether BT8 can meet the Plan’s requirements on design, integration, access, infrastructure and landscape impact — and it is capable of doing so.

In the emerging Rother Local Plan, BT8 is identified for around 5 dwellings (potentially including live-work units), with requirements for affordable housing, new vehicular access from Hastings Road, new pedestrian and cycle links, and a strong boundary hedge, while also supporting the kind of small-scale employment that is otherwise limited in the Plan. This is expressly framed as small-scale development subject to sensitive design.

That approach aligns with the made Neighbourhood Plan’s policy framework: HD6requires new housing to be visually integrated;IN1 requires a Transport Assessment and mitigation where traffic impacts are significant;IN2 supports infrastructure provision; IN4requires safe pedestrian links to existing footways and services; and EN3 requires development in the High Weald AONB to conserve and enhance natural beauty, respect settlement pattern and historic routeways, and conserve hedgerows and trees. These are not “anti-development” policies — they are safeguards to ensure development is shaped to place. A very small, hedge-contained edge-of-settlement site with controlled access, pedestrian links and landscape buffering is inherently easier to reconcile with these policies than a large strategic allocation.

The Neighbourhood Plan also recognises that Battle must accommodate significant growth (including at least 475 dwellings for Battle and Telham and the BA11 Blackfriars allocation of around 220 dwellings) while also noting that the town’s linear form already creates traffic bottlenecks. That context reinforces that scale and mitigation matter. BT8 stands out precisely because it is not a high-yield proposal: it is limited to about five homes and described in the draft Local Plan as acceptable only as a small-scale scheme with sensitive design.

Accordingly, a consultation response can reasonably state that allocating BT8 would be consistent with the made Battle Neighbourhood Plan, because it represents a modest, controlled form of growth that can be tested against — and shaped by — policiesHD6, IN1, IN2, IN4 and EN3, alongside the general access, landscaping and biodiversity expectations in HD2. In short: if further growth is required, the policy framework points toward small, integrated, mitigated and landscape-sensitive sites as the most defensible option.

I am a resident of Battle and I fully support BT8 as a well thought through site plan, which enhances the neighbourhood rather than scars it: -
BT8 (Land adjacent to 1 Loose Farm Cottages, Battle) should be assessed on policy consistency. It provides clear criteria-based policies against which any site can be tested. The key question is therefore whether BT8 can meet the Plan’s requirements on design, integration, access, infrastructure and landscape impact — and it is capable of doing so.
In the emerging Rother Local Plan, BT8 is identified for around 5 dwellings (potentially including live-work units), with requirements for affordable housing, new vehicular access from Hastings Road, new pedestrian and cycle links, and a strong boundary hedge, while also supporting the kind of small-scale employment that is otherwise limited in the Plan. This is expressly framed as small-scale development subject to sensitive design.
That approach aligns with the made Neighbourhood Plan’s policy framework: HD6requires new housing to be visually integrated;IN1 requires a Transport Assessment and mitigation where traffic impacts are significant;IN2 supports infrastructure provision; IN4requires safe pedestrian links to existing footways and services; and EN3 requires development in the High Weald AONB to conserve and enhance natural beauty, respect settlement pattern and historic routeways, and conserve hedgerows and trees. These are not “anti-development” policies — they are safeguards to ensure development is shaped to place. A very small, hedge-contained edge-of-settlement site with controlled access, pedestrian links and landscape buffering is inherently easier to reconcile with these policies than a large strategic allocation.
The Neighbourhood Plan also recognises that Battle must accommodate significant growth (including at least 475 dwellings for Battle and Telham and the BA11 Blackfriars allocation of around 220 dwellings) while also noting that the town’s linear form already creates traffic bottlenecks. That context reinforces that scale and mitigation matter. BT8 stands out precisely because it is not a high-yield proposal: it is limited to about five homes and described in the draft Local Plan as acceptable only as a small-scale scheme with sensitive design.
Accordingly, a consultation response can reasonably state that allocating BT8 would beconsistent with the made Battle Neighbourhood Plan, because it represents a modest, controlled form of growth that can be tested against — and shaped by — policiesHD6, IN1, IN2, IN4 and EN3, alongside the general access, landscaping and biodiversity expectations in HD2. In short: if further growth is required, the policy framework points towardsmall, integrated, mitigated and landscape-sensitive sites as the most defensible option.

Dear Rother Planning Team

I write as a resident of Asten Fields, Battle, to formally object to your proposed development land at Almonry Farm.

I object on grounds of:

Local infrastructure not being able to support a development in this area:

Anyone local who has tried to pass down north trade road at key points during the day will realise that the road can already be impassable, with school traffic from both battle and langton and Claverham becoming compounded and affecting the area around tollgates especially. Another large housing development being accessed from here will be a disaster, this is surprisingly poorly planned and is not a viable option.

Loss of habitat and impact on local biodiversity:

The southerly tip of the field directly behind The gardens of Asten Fields is home to wild orchids, the site should be properly surveyed for species of interest. This field is also used as a feeding thoroughfare for all uk 3 species of woodpecker, including the endangered lesser spotted woodpecker. They cross from the tree line of Mansers Shaw to feed in the trees that line the bottom edge of the recreation ground, and I sight them regularly crossing this area. The woods there are also home to breeding pairs of tawny owls and bats. I do not believe that the impact on local important species has been properly assessed.

I hope that you will take in to account the objections of local residents, who are far better equipped to comment on the impact that this would have on our area, than those planners and developers who would take this decision out of the hands of those residents who can, and cannot object.

Kind regards

Dear Sir/Madam,
I am writing to formally object to the proposed allocation of sites BT1, BT8 and BT10 (Land south of Hastings Road, Battle).
As a resident of Hastings Road, near the junction with Starrs Green Lane and in close proximity to the proposed access point for site BT1, I have direct, daily experience of the traffic conditions at this location, where congestion, queuing, and limited gaps in traffic already make movement difficult, particularly at peak times.

I consider the proposed development to be unsound when assessed against material planning considerations, the adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25, including subsequent updates relating to National Development Management Policies.

1. Traffic Congestion, Pedestrian Safety and Highway Risk
Hastings Road (A2100) is already operating beyond its effective capacity, with regular peak-time congestion and queuing in both directions. The addition of a minimum of 250 dwellings across these sites would significantly increase vehicular movements, exacerbating an already critical situation.

The Battle Neighbourhood Plan identifies traffic congestion as a key constraint within the parish. The introduction of additional major junctions onto this route, without substantial infrastructure upgrades, fails to address this known issue.

The proximity of proposed access points (within approximately 200 metres of existing and recently approved developments such as Blackfriars) creates a high likelihood of junction interference. This will lead to vehicle “tailbacks” blocking access and egress, increasing the risk of rear-end collisions and side-swipe incidents.
Furthermore, the sites are located at a transition point between 30mph and 40mph speed limits. Vehicles travelling southbound are accelerating at this point, while northbound vehicles are often decelerating from higher speeds. The siting of high-volume access points in this transition zone presents a clear and demonstrable safety risk.

Pedestrian Safety and Pavement Constraints
In addition to vehicle-related risks, pedestrian safety along Hastings Road is already a significant concern. Sections of the pavement are narrow and are frequently obstructed by parked or loading vehicles, forcing pedestrians into the carriageway.

This is particularly concerning for children walking to and from school, who are required to navigate a busy A-road with fast-moving traffic and limited protection. Increased traffic flows from the proposed development would materially worsen this already unsafe situation.

The combination of narrow footways, increased traffic, and existing speeding behaviour creates an environment that is unsuitable for safe walking or active travel.

Under NPPF Paragraph 115, development should only be permitted where “safe and suitable access to the site can be achieved for all users.” This clearly includes pedestrians, and in this case that requirement is not met.

2. Construction Impact and Disruption

In addition to the permanent impacts, the construction phase itself would cause significant and prolonged disruption to Hastings Road and surrounding residents.
Given the scale of development, it is highly likely that works would require temporary traffic management measures, including traffic lights, lane restrictions, and construction vehicle movements over an extended period.
On a road that is already heavily congested, such measures would exacerbate delays, increase journey times, and further reduce road safety. Construction traffic, including heavy goods vehicles, would add to the hazard, particularly near the proposed access point and along narrow sections of the road.

Residents would also experience prolonged disturbance from noise, dust, and general construction activity. These impacts would not be short-term or minor, but sustained over several years given the scale of the development.
This level of disruption represents a significant adverse impact on residential amenity and highway function, which has not been adequately addressed.

3. Environmental Impact, Noise and Air Quality

The proposed development would result in the loss of approximately 11 hectares of Greenfield land. This is directly contrary to the objectives of the Battle Neighbourhood Plan, which prioritises the use of brownfield land and the protection of the surrounding countryside.

The site lies within the High Weald National Landscape (formerly AONB), which is afforded the highest level of protection under NPPF Paragraph 190. The scale and density proposed (circa 40 dwellings per hectare) is urban in character and fails to respect the intrinsic landscape qualities of the area.

Under NPPF Paragraph 189, major development within a National Landscape should only be permitted in exceptional circumstances. No such exceptional circumstances have been demonstrated.

Noise, Air Quality and Residential Amenity

Hastings Road is already heavily trafficked, resulting in significant levels of traffic noise and air pollution. Vehicles frequently travel at speed along this stretch, particularly near the 30mph to 40mph transition.

The addition of substantial new traffic flows would inevitably increase both noise and air pollution, to the detriment of existing residents and future occupants. This conflicts with the NPPF’s requirement to protect living conditions and ensure developments contribute to a safe and healthy environment.

In addition, the development would result in the loss and fragmentation of important habitats, including paddocks, hedgerows, and areas identified as High Weald Wildflower Meadow Priority Habitat. The cumulative impact would be a significant disruption to established wildlife corridors.

4. Flood Risk and Surface Water Management

The policy wording for BT1 acknowledges an existing surface water flood risk affecting the southern part of the site.

The replacement of permeable Greenfield land with impermeable surfaces will increase runoff and exacerbate flood risk to surrounding areas.
This approach conflicts with NPPF Paragraph 170, which requires development to avoid increasing flood risk and incorporate appropriate climate resilience measures.

5. Infrastructure Deficits

The existing infrastructure within Battle is insufficient to support the scale of development proposed.
The NPPF (Paragraphs 20 and 35) requires Local Plans to identify and secure the necessary supporting infrastructure, including healthcare, education, and transport.
• Healthcare: There is a well-documented shortage of NHS dental provision in East Sussex, and GP services are already under sustained pressure.
• Education: The reliance on “active travel” is unrealistic given the traffic conditions, narrow pavements, and safety concerns outlined above.

6. Deliverability and Precedent

There is limited confidence that the infrastructure and quality assurances associated with this development will be delivered as proposed.

The Blackfriars development demonstrates how schemes can be altered due to financial pressures, resulting in reduced quality and diluted commitments.
This raises serious concerns that similar outcomes could occur here.

In summary, the proposed allocation of BT1, BT8 and BT10 represents an unsustainable and unsafe form of development. It would:
• Exacerbate severe traffic and highway safety issues
• Create unacceptable risks for pedestrians, including schoolchildren
• Cause significant construction disruption over a prolonged period
• Harm a protected National Landscape
• Increase flood risk
• Worsen noise and air pollution
• Place further strain on inadequate infrastructure
For these reasons, the proposal is unsound and inconsistent with both local and national planning policy.
I respectfully urge the Council to remove these site allocations from the Local Plan before it progresses further.
Yours faithfully,

Re: Draft Rother Local Plan (2025–2042) – Regulation 18 Consultation

Policy BT7 – Land at Almonry Farm, Battle

I write to formally object to the proposed allocation of Land at Almonry Farm (Policy BT7) for residential development of approximately 80 dwellings.

In my view, this allocation fails the tests of soundness set out in the National Planning Policy Framework (NPPF). It is not justified, not effective, and is not consistent with national policy relating to protected landscapes, heritage assets, biodiversity and infrastructure.

1. Impact on the High Weald National Landscape
The site lies wholly within the High Weald National Landscape. Under Section 85 of the Countryside and Rights of Way Act 2000, the Council has a statutory duty to conserve and enhance the natural beauty of this nationally protected landscape.

The site comprises undeveloped greenfield land forming part of an intact historic field system defined by mature hedgerows and trees — characteristic features of the High Weald. The proposed suburban development at approximately 35 dwellings per hectare would introduce urban form into a sensitive rural landscape, resulting in permanent harm.

The allocation does not demonstrate exceptional circumstances or overriding public interest sufficient to justify development within this protected landscape.

2. Heritage Significance and Setting
The site lies in close proximity to nationally significant heritage assets, including:
• The Registered Battlefield (1066 Battle of Hastings)
• Battle Abbey Gatehouse Scheduled Monument
• Battle Conservation Area
• Grade II listed Lower Almonry Farmhouse

The land forms part of the historic agricultural setting associated with Battle Abbey and contributes to the wider battlefield landscape. Even where development does not directly affect designated assets, the NPPF requires great weight to be given to the conservation of their setting.

There is also recognised archaeological potential in this area, with local historical evidence suggesting nearby Manser’s Shaw may correspond to the “Malfosse” episode of the 1066 battle. Allocation at this stage, prior to comprehensive archaeological assessment, is premature.

Development would suburbanise part of the Abbey’s wider landscape context and erode the rural character that contributes to the significance of these nationally important assets.

3. Ancient Woodland and Biodiversity
Ancient Woodland and Priority Habitat lie immediately adjacent to the eastern boundary of the site.

While a 15-metre buffer is proposed, national guidance often recommends greater separation to prevent long-term degradation caused by light spill, recreational pressure, domestic pets and hydrological change.

The site supports wildlife including deer, bats and other protected species. The cumulative ecological impact of development in this sensitive location has not been adequately demonstrated at plan-making stage.

The allocation therefore risks conflict with national policy requiring protection of irreplaceable habitats and delivery of genuine biodiversity net gain.

4. Surface Water and Flood Risk
The supporting text acknowledges that parts of the site are at risk of surface water flooding. Development of greenfield land increases hard surfacing and run-off, potentially exacerbating flood risk to neighbouring properties and downstream systems.

The Local Plan should not allocate sites where flood risk mitigation remains uncertain.

5. Highway Safety and Infrastructure Capacity
Vehicular access is proposed via Tollgates, with impacts on North Trade Road and the A2100. The Plan itself acknowledges that further junction capacity assessments are required.

Given existing congestion and the proximity to Claverham Community College, there are legitimate concerns regarding pedestrian safety and traffic conflict. Allocation prior to confirmed modelling and mitigation measures renders the proposal unjustified and potentially ineffective.

In addition, Battle’s healthcare provision, school capacity and local services are already under pressure. The allocation does not secure clear, deliverable infrastructure improvements aligned with the scale of growth proposed.

6. Cumulative and Precedent Effects
Almonry Farm currently contributes to the rural character of the southern edge of Battle. Allocation of this parcel risks incremental erosion of the wider landscape and may create pressure for further development across remaining farmland.

The cumulative impact of multiple allocations around Battle must be properly assessed to avoid gradual suburbanisation of a town of exceptional historic importance.

Conclusion
For the reasons outlined above, Policy BT7 is not justified by robust evidence, fails to give appropriate weight to nationally protected landscape and heritage assets, and does not adequately address infrastructure and environmental constraints.

I respectfully request that Policy BT7 – Land at Almonry Farm – be removed from the next iteration of the Draft Local Plan. Please save our green areas. Our world needs them.

As part of the Regulation 18 phase, I would like to express my objection to the proposal to build over 700 new homes in Battle.

I understand that the original Battle Neighbourhood Plan suggested 145 new homes which has now increased four-fold.

I live on Lower Lake with my family and can say that the infrastructure of this town (with the addition of three housing estates recently built/in construction) is already not able to cope; with limited options to expand with the extra demand.

We have seen a (seemingly) ever-increasing number of heavy goods vehicles and general traffic over the 19 years that we have lived on Lower Lake. The environmental effect on my family from Battle being used as a by-pass has already been felt (we are all asthma sufferers and my son's room faces the road).
In relation to parking, this is limited for locals anyway, let alone tourists to whom the town relies heavily upon economically. The High Street cannot be widened or expanded.

As regards schools, There remains only on primary school and secondary school which have both been rebuilt.
As far as I know, the surrounding areas also rely on these schools to send their children to and would likely be excluded with the new local homes being constructed.

Please consider my family's concerns during your consultation process.

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)
Date:

We are writing to formally submit our objection to the proposed allocations of site BT1 and adjacent sites. As residents of Hastings Road, we have direct, daily experience of the site conditions. This development is unsupportable based on material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies).

1. Traffic Congestion and Safety on Hastings Road

Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites mentioned above). The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding a major junction to this existing chaos without significant infrastructure upgrades is negligent.
Junction Interference and "Staggered" Conflict At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (250 dwellings) will frequently be blocked by "tailback" traffic exiting or entering Blackfriars (210+ dwellings). This creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.
The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
• Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.
Placing two high-volume junctions in a high-speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.




2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT1 proposes building on 11.09 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
• National Landscape (AONB) Impact: The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 40 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major development should only occur in exceptional circumstances (NPPF Paragraph 189).
• Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 250 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises.
Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT1 explicitly acknowledges a "surface water flooding risk to the southern boundaries of the site". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on 11 hectares of land already identified as a flood risk is reckless planning that endangers existing properties downhill, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests.
3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management)
• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
• Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
• Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.
The Blackfriars Precedent: "Watered Down" Commitments We have no confidence in the "policy compliant" assurances for BT1 because we have seen the Council fail to deliver on similar promises at Blackfriars. That development was sold as a "gold standard" of green, high-tech housing. However, documents show it faced an £8 million funding gap and underwent "redesign" to "better align with market demand" and "improve efficiencies" due to rising costs. If the flagship Blackfriars project had to be value-engineered due to market pressures, the high-quality, landscape-led masterplan promised for BT1 is likely to be similarly watered down once permission is granted.
Conclusion
This proposal expands development to 250 units on a Greenfield National Landscape site amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further.

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)

We are writing to formally submit our objection to the proposed allocations of site BT1 and adjacent sites. As residents off Hastings Road, we have direct, daily experience of the site conditions. This development is unsupportable based on material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies).

1. Traffic Congestion and Safety on Hastings Road
Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites mentioned above). The Battle Neighbourhood Plan (Battle NP) explicitly identifies tra􀆯ic congestion as a critical weakness of the parish. Adding a major junction to this existing chaos without significant infrastructure upgrades is negligent.

Junction Interference and "Staggered" Conflict At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (250 dwellings) will frequently be blocked by "tailback" traffic exiting or entering Blackfriars (210+ dwellings). This creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.

The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
 Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
 Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.
Placing two high-volume junctions in a high-speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.

2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
 Greenfield Loss: BT1 proposes building on 11.09 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
 National Landscape (AONB) Impact: The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 40 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major development should only occur in exceptional circumstances (NPPF Paragraph 189).
 Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 250 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "bu􀆯er zone" promises.

Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT1 explicitly acknowledges a "surface water flooding risk to the southern boundaries of the site". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on 11 hectares of land already identified as a flood risk is reckless planning that endangers existing properties downhill, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests.

3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management)
 Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
 Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
 Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.

The Blackfriars Precedent: "Watered Down" Commitments We have no confidence in the "policy compliant" assurances for BT1 because we have seen the Council fail to deliver on similar promises at Blackfriars. That development was sold as a "gold standard" of green, hightech housing. However, documents show it faced an £8 million funding gap and underwent "redesign" to "better align with market demand" and "improve efficiencies" due to rising costs. If the flagship Blackfriars project had to be value-engineered due to market pressures, the highquality, landscape-led masterplan promised for BT1 is likely to be similarly watered down once permission is granted.

Conclusion
This proposal expands development to 250 units on a Greenfield National Landscape site amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further. I am an Architect and well aware of the need for development and the success of it when implemented sensitively, appropriately and in accordance with Planning Policy and Local Development Plans. This proposed development and zoning is not an appropriate site for the reasons outlined and it is essential that we protect the natural environment of the Greenfield National Landscape sites and the unique character of Battle and its rural surrounds. We must appropriately address the infrastructure demands of increased housing and population by building on more suitable Brownfield sites. We must not be the generation that urbanises historic Battle and creates a legacy of poor decisions that irrevocably affect the local environment and infrastructure forever, by building on precious National Landscape sites.

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)

I am writing to formally submit our objection to the proposed allocations of site BT1, BT8 and BT10. As residents of Hastings Road, we have direct, daily experience of the site conditions. This development is unsupportable based on material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies).

1. Traffic Congestion and Safety on Hastings Road
Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites mentioned above). The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding a major junction to this existing chaos without significant infrastructure upgrades is negligent.
Junction Interference and "Staggered" Conflict At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (250 dwellings) will frequently be blocked by "tailback" traffic exiting or entering Blackfriars (210+ dwellings). This creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.
The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
• Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.
Placing two high-volume junctions in a high-speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.

At site BT8, the road cannot accommodate more traffic / users due to its narrow and predominantly single track layout. Turning out onto the already congested, fast, Hastings Road A2100 which is a 40mph stretch of road has a blind spot and is already dangerous without more vehicles using it. There is also a care home with numerous staff and visitors on the lane. Having more vehicles may cause problems for the care home and emergency services who need to attend.

As stated, there is a Private Care Home along the private road, off Hastings Road, which relies heavily on ease of vehicle access. They regularly need unobstructed access for emergency vehicles, due to the nature of the care home. The access is relied on for either ambulances, patient transport or supplies linked to the business. This needs preserving for the safety and well-being of the residents at the care home.

There is a very limited bus service around BT8 which means that more vehicles will be forced to use the road which impacts the environment, causes more traffic congestion and makes the road even more dangerous.

The A2100 is a regular walkway route for schools in the Battle area, using both sides of the road’s pavements. The road is already busy and a danger to pedestrians and cyclists who use it for school and commuting traffic. Increasing the housing numbers to such a size, would increase the traffic volume and potentially put more danger on to those people who are young and vulnerable, but still rely on the Hastings Road.

2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT1 proposes building on 11.09 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
• National Landscape (AONB) Impact: The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 40 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major development should only occur in exceptional circumstances (NPPF Paragraph 189).
• Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 250 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises.
• BT1, BT8 and BT10 are sites of Historic Interest - The surrounding fields were once owned by the Montague Family and are surrounded by sites of significant historic interest / archeological sites regarding Battle Abbey and English Heritage.
Flooding Risk and Surface Water (NPPF Paragraph 170)The policy text for BT1 explicitly acknowledges a "surface water flooding risk to the southern boundaries of the site". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on 11 hectares of land already identified as a flood risk is reckless planning that endangers existing properties downhill, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests.

3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools)The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management)
• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
• Schools: Our local schools are already oversubscribed and overstretched. The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions. As stated above, at site BT8, there is a lack of public transport which forces people to use their cars to attend the local schools which makes our roads more dangerous, congested and not environmentally friendly.
• Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.
The Blackfriars Precedent: "Watered Down" Commitments We have no confidence in the "policy compliant" assurances for BT1 because we have seen the Council fail to deliver on similar promises at Blackfriars. That development was sold as a "gold standard" of green, high-tech housing. However, documents show it faced an £8 million funding gap and underwent "redesign" to "better align with market demand" and "improve efficiencies" due to rising costs. If the flagship Blackfriars project had to be value-engineered due to market pressures, the high-quality, landscape-led masterplan promised for BT1 is likely to be similarly watered down once permission is granted.

Conclusion
This proposal expands development to 250 units on a Greenfield National Landscape site amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further.

Policy BT7 – Land at Almonry Farm, Battle
further to my objection to the above policy emailed to you on 17th March I would like to add that over the last few years 67 new houses have been built at the end of Tollgates, about 30 new houses have been built just past Claverham College in the North Trade Road and there is another large new development (Conquerors Gate) further along the North Trade Road thus creating further traffic problems in the part of Battle.

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)
Date:

We are writing to formally submit our objection to the proposed allocations of site BT1 and adjacent sites. As residents of Hastings Road, we have direct, daily experience of the site conditions. This development is unsupportable based on material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies).

1. Traffic Congestion and Safety on Hastings Road

Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites mentioned above). The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding a major junction to this existing chaos without significant infrastructure upgrades is negligent.
Junction Interference and "Staggered" Conflict At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (250 dwellings) will frequently be blocked by "tailback" traffic exiting or entering Blackfriars (210+ dwellings). This creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.
The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
• Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.
Placing two high-volume junctions in a high-speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.




2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT1 proposes building on 11.09 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
• National Landscape (AONB) Impact: The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 40 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major development should only occur in exceptional circumstances (NPPF Paragraph 189).
• Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 250 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises.
Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT1 explicitly acknowledges a "surface water flooding risk to the southern boundaries of the site". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on 11 hectares of land already identified as a flood risk is reckless planning that endangers existing properties downhill, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests.
3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management)
• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
• Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
• Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.
The Blackfriars Precedent: "Watered Down" Commitments We have no confidence in the "policy compliant" assurances for BT1 because we have seen the Council fail to deliver on similar promises at Blackfriars. That development was sold as a "gold standard" of green, high-tech housing. However, documents show it faced an £8 million funding gap and underwent "redesign" to "better align with market demand" and "improve efficiencies" due to rising costs. If the flagship Blackfriars project had to be value-engineered due to market pressures, the high-quality, landscape-led masterplan promised for BT1 is likely to be similarly watered down once permission is granted.
Conclusion
This proposal expands development to 250 units on a Greenfield National Landscape site amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further.

I am writing to formally submit my objection to the proposed allocations of sites GYP1 & GYP2, but also BT1 & BT8. As a resident of Hastings Road, I have daily experience of the site conditions.

Hastings Road is a very busy main thoroughfare. Loose Farm Lane, which would be the only vehicle access for both sites, is a blind turning. Travellers use long vehicles that would pose a large risk of accidents when coming out of the lane. The lane is also not suitable for lots of additional traffic.