I strongly object to the proposed plan to build eighty houses on this proposed site, for the following reasons:
The impact it would have on the historic setting of Battle Abbey and the 1066 Battlefield.
The loss of greenfield land within the High Weald National landscape would be terrible The impact it would have on the ancient woodland and protected species. Also the effect it would have on all wild life including birds. It would be devastating. Battle slowly but surely is being ruined. We do not have the infrastructure for all these people. The Doctors surgeries are being stretched to the limit as it is - they have neither new surgeries or medical staff. The schools also are stretched to their limit.
The safety of all pedestrians including the Claverham pupils could not be guaranteed. The exit via Tollgates on to North Trade Road would be gridlocked- it is bad enough already.
There would also be a risk of flooding due to surface water and nowhere for it to go I am very sad that Battle is going to lose its identity. We should be preserving it for future generations.

I am writing to formally object to the proposed allocation of ‘Land at Almonry Farm (Policy BT7)’ for residential development of approximately 80 houses.

I am of the opinion 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 of 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 near 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 site 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 lies 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 of this site 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 – 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 of this site 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 land 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.

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 therefore would like to request that Policy BT7 – Land at Almonry Farm – be removed from the next iteration of the Draft Local Plan.

Re: Draft Rother Local Plan (2025–2042) – Regulation 18 Consultation
Policy BT7 – Land at Almonry Farm, Battle

I am writing to register a strong and formal objection to the proposed allocation of Land at Almonry Farm (Policy BT7) for approximately 80 dwellings. On review of the available evidence and the requirements of the National Planning Policy Framework (NPPF), it is clear that this allocation fails the key tests of soundness. It is not justified, not effective, and conflicts directly with national policy regarding protected landscapes, heritage assets, biodiversity and infrastructure readiness.

1. Impact on the High Weald National Landscape
The site lies wholly within the High Weald National Landscape, where the Council has a statutory duty—under Section 85 of the Countryside and Rights of Way Act 2000—to conserve and enhance natural beauty. The land forms part of an intact historic field system, defined by established hedgerows and mature trees typical of the High Weald. Developing at a density of 35 dwellings per hectare would introduce intrusive suburban form into a sensitive rural environment, causing irreversible harm. There is no evidence of exceptional circumstances nor overriding public interest that would justify such harm.

2. Heritage Significance and Setting
The site lies in close proximity to nationally significant heritage assets, including the Registered 1066 Battlefield, the Battle Abbey Gatehouse Scheduled Monument, Battle Conservation Area and the Grade II listed Lower Almonry Farmhouse. The landscape forms part of the historic agricultural setting of Battle Abbey and contributes to the broader battlefield context. The NPPF requires great weight to be given to the conservation of heritage assets and their settings. Furthermore, local historical interpretation suggests nearby Manser’s Shaw may relate to the “Malfosse” incident of the 1066 battle, reinforcing the area’s archaeological sensitivity. Allocation in advance of proper archaeological assessment is premature and contrary to national guidance.

3. Ancient Woodland and Biodiversity
Ancient Woodland and Priority Habitat immediately adjoin the eastern boundary. While a 15 metre buffer has been suggested, national guidance commonly recommends considerably larger buffers to avoid degradation caused by recreation, light pollution, domestic pets and altered drainage patterns. The site supports wildlife including deer, bats and other protected species. The cumulative ecological impact of development has not been demonstrated, and there is no adequate evidence that the scheme could deliver biodiversity net gain, as required by national policy.

4. Surface Water and Flood Risk
Parts of the site are known to be at risk of surface water flooding. Substituting permeable greenfield land with hard surfaces will inevitably increase runoff and may heighten flood risk to neighbouring properties and downstream areas. Until the flood mitigation strategy is fully understood, tested and proven deliverable, allocating this site is not appropriate.

5. Highway Safety and Infrastructure Capacity
The proposed access via Tollgates would affect North Trade Road and the A2100—areas already experiencing congestion. The Plan itself states that further junction capacity modelling is needed. Without such modelling, the allocation cannot be considered justified. The proximity to Claverham Community College also raises significant concerns regarding pupil safety and increased conflict between vehicles and pedestrians. Additionally, Battle’s healthcare, education and community services are already under pressure, with no clearly secured, deliverable infrastructure improvements to support the proposed growth.

6. Cumulative and Precedent Effects
Almonry Farm currently contributes to the rural character of Battle’s southern edge. Allocating this site risks creating a precedent for further encroachment into surrounding farmland, leading to incremental suburbanisation. The cumulative impact of multiple developments around Battle has not been properly assessed and risks diminishing the character and historic significance of the town.
Summary of Key Objection Points
· The allocation fails NPPF soundness tests: unjustified, ineffective, and inconsistent with national policy.
· Development would harm the High Weald National Landscape with no exceptional justification.
· Significant adverse impact on heritage assets including the 1066 Battlefield and Battle Abbey.
· Archaeological potential not assessed—allocation premature.
· Risks to Ancient Woodland, Priority Habitat, and protected species; biodiversity net gain not demonstrated.
· Surface water flood risk likely to increase due to loss of greenfield land.
· Highway capacity, congestion and pedestrian safety concerns remain unresolved.
· Local healthcare, school capacity and services already overstretched.
· Cumulative effects risk long term suburbanisation of historic Battle.

Conclusion
For all the reasons outlined above, Policy BT7 should be considered unsound. It is unsupported by robust evidence, fails to protect nationally designated landscape and heritage assets, and does not adequately address infrastructure or environmental constraints. I respectfully request that Policy BT7 – Land at Almonry Farm – be removed from the next iteration of the Draft Local Plan.

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 Glengorse, 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.

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.
There are developments that have recently been built, where properties are still not sold, some of there properties do not have access to gas and others in nearby villages did not have a water source.
Rother need to consider the global issues that are causing economic problems at the present and will put the cost of housing and materials up. It is unadvisable for the proposals to go forward.
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.

Proposed Housing at Almonry Farm (BT7)

I would like to submit the following as objections to the above item in the Draft Local Plan.

I am doing so via email as the option to submit via the Rother District Council document is very difficult to access and is not user friendly.

Objections are as follows.

1. Infrastructure - before any proposals for further housing in the Battle area a credible infrastructure plan must be drawn up and implemented. The town has not yet felt the impact of the Blackfriars development and pressures are already being felt with GP surgeries, schools and local services already being stretched. I work for a local GP and we have outgrown our current premises and have been looking to find new premises with nothing suitable being available.

We have just come out of a prolonged hosepipe ban which has lasted for many months. Water supply is another part of the infrastructure that needs addressing before any further proposed development.

2. Heritage and Landscape - this proposed development forms part of the historic setting of Battle Abbey and the 1066 battlefield. Development here would su urbanise part of one of the most important historic landscapes in Britain. The site lies within nationally protected countryside and once greenfield land is built on it is gone forever.

3. Traffic and Safety - access via Tollgates would add significant traffic to North Trade Road and the A2100. These roads already are gridlocked most days during school start and finish times as the roads service both schools in Battle. There would also be a significant rise in children on pavements during these peak times with the associated risks this would bring. There’s would also be an increased impact on our historic high street this would need to be considered.

4. Ancient Woodland & Wildlife - ancient woodland borders this site. The area supports a wide range of wildlife including, newts, foxes and hedgehogs. This development risks irreversible habitat loss and long-term environmental harm.

5. Flood Risk - parts this proposed site are identified as being at risk from surface water flooding. Building on greenfield land increased run-off and could impact neighbouring areas.

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.

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)
Date: 26 February 2026
I am writing to formally submit my objection to the proposed allocations of site BT1 and adjacent sites. As a resident of Glengorse, I 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.
The Battle NP explicitly refers to the problematic traffic conditions. It states that Battle’s increasing use as a ‘transport corridor’ has ‘generally increased the problems associated with additional transportation within the confines of our historic town, such as illegal parking and congestion. This has not improved the environment for those living, working or shopping along Battle High Street.’
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.
One of the proposed exits for the new site is at Glengorse, a once-quiet residential cul-de-sac. Glengorse is affected by increased volume of traffic on the A2100, making entry and exit increasingly difficult. It is also affected by volume of parking and parking restrictions were recently introduced.
The Glengorse exit is within a short distance of the exit at The Spinney from The Tapestry Development (70 dwellings). The traffic and urban sprawl consequences of these developments would be severe.
The proposed development does not meet the Battle NP’s objective to ‘consider the wider implications and associated costs of traffic movements on the environment and local infrastructure with an overall aim of reduction in the impact of traffic movements’.
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.
• The Battle NP states that the hamlet of Telham – which would be affected by the encroachment of this development - is ‘enclosed by agricultural land it services a small community and acts as a Strategic Green Gap in the fight against urban sprawl.’ The proposed development does not meet the Battle NP’s objective to recognise the separate identities of the areas making up the Parish and to ‘prevent urban sprawl’.
• 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.
• The land around the Glengorse Estate was once defined as parkland. Although Telham Court, the property which sits on the Glengorse Estate, is proposed to be protected under the development, the land around it will not be protected. The development will create further light pollution.
• Due consideration cannot have been given to the historic nature of the town and surrounding area. Battle NP states that ‘Battle itself is of national and international importance’. Battle town centre is largely medieval and consists of one street, the road through which is typically in a very poor state of disrepair. It already struggles under the volume of traffic, which would be further increased by this development, and vehicles of the nature required for a major development would cause to the historic buildings.
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.
The proposed development fails to meet the Battle NP’s objective that ‘To protect and enhance our existing and future open spaces, any new development proposal should conserve and enhance the environment, ecosystem and biodiversity, ensuring that it gives protection to heritage assets, habitats and provides appropriate movement corridors for wildlife.’
3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (eg 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.
• Transport: The Battle NP states that there is a ‘distinct lack of public transport within the Parish.’ Increasing housing stock without improving public transport is irresponsible, and would only increase reliance upon vehicular traffic. Among the ‘weaknesses’ identified in the Battle NP are traffic congestion, parking difficulties, lack of public transport and highway maintenance.
• 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.
Previous proposal
The proposed development is situated on land owned by two absentee landowners, who both live abroad, as far as we know. These landowners, who are property developers, previously proposed a development in which Glengorse would form one entrance and Marylands (34 Hastings Road) the other. The Glengorse Estate, which sits behind the housing cul-de-sac, was purchased with the intention of development. The previous proposed development was subject to objection and was rejected on the grounds that it contravened the then-current policy on the ‘strategic gap’.
In 2019, the Battle NP’s inclusion of a site at Glengorse (original site ref BA31a) was amended in light of the proposed development at Blackfriars. The Battle NP stated that the likely development of Blackfriars rendered the Glengorse development ‘too large a development in a similar location’.
As the previous rejections proposed development does not meet the Battle NP’s objective that developments ‘should meet the needs and wishes of the community’.
Marylands is presently listed on Rightmove with SJD Tunbridge Wells (a development consultancy) as a development opportunity and is presently under offer. The listing states that the ‘land to the west of the site has recently been allocated so it is considered that this land may offer future potential subject to usual consents’.
[https://www.rightmove.co.uk/properties/166422503#/?channel=COM_BUY]
Degradation of an environment of national historical importance
The current housing developments together with the proposed further developments in Battle represent a very real threat to the safeguarding of this site of great historical significance.
Battle’s whole structure as a small town reflects its medieval origins. The very essence of the composition of and distance between settlements, dating back to its foundation, reflects what once was a common pattern across the country; in short, it represents something of national importance which merits particular respect and due attention to conservation. The very act of expanding beyond measure what was once a small town characterised by its historical roots is an act of cultural destruction which must not go unchallenged.
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)
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)
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.

Dear Sir/Madam,

Re: Draft Rother Local Plan 2025–2042 – Proposed Housing Allocations BT1, BT8 and BT10

I am writing to formally object to the proposed housing allocations BT1, BT8, and BT10 in the Draft Rother Local Plan (2025–2042), which would deliver a minimum of 250 new dwellings on greenfield land south of Hastings Road, adjacent to Loose Farm, Glengorse, and close to the Blackfriars development.

Having reviewed the draft policy and the associated site proposals, I strongly oppose these allocations for the reasons set out below.
________________________________________

1. Severe Traffic, Road Safety, and Highways Impact
The proposed access point to BT1 is only 191.8 metres from the Blackfriars development entrance, creating a hazardous conflict zone along the already congested A2100 (Hastings Road).

This area already experiences:
● High peak-time congestion
● Queueing at junctions on steep gradients
● Limited overtaking opportunities
● Restricted visibility

Adding traffic from over 250 additional dwellings would significantly worsen:
● Collision risk
● Emergency vehicle delays
● Congestion for local and through-traffic
● Air quality impacts

The A2100 simply cannot safely absorb the projected traffic levels associated with these developments. An independent and comprehensive highways assessment is essential.
________________________________________

2. Harm to High Weald National Landscape (AONB)
The proposed sites sit within the High Weald National Landscape (Area of Outstanding Natural Beauty), a nationally protected landscape with the highest level of planning protection under the National Planning Policy Framework (NPPF).

Key concerns include:
● Irreversible loss of tranquillity and rural character
● Urbanisation of valued open countryside
● Visual harm from massed housing on elevated land
● Erosion of the historic landscape pattern

The Battle Neighbourhood Plan originally suggested just 15 homes for this general area, acknowledging its high sensitivity. The current proposal for 250+ homes represents a dramatic and unjustified departure from adopted local evidence.

Under national policy, major development in an AONB should be refused unless exceptional circumstances can be clearly demonstrated—something this proposal does not achieve.
________________________________________

3. Lack of Infrastructure Capacity (GPs, Dentists, Schools, Emergency Services)
Local services are already overstretched:
● GP surgeries report severe appointment shortages.
● Dental practices are at capacity, many not accepting new NHS patients.
● Local schools operate close to or at maximum pupil numbers.
● Hospital and urgent care services already experience delays and long waiting times.

The Draft Plan offers no firm or funded commitments to expand these essential services.

Without guaranteed, timely infrastructure provision, the development would place unsustainable pressure on already overstretched facilities.
________________________________________

4. Environmental and Wildlife Impacts
The site contains ecologically valuable greenfield land that provides:
● Wildlife corridors
● Hedgerow and tree habitats
● Foraging grounds
● Natural drainage

Loss of these habitats would negatively affect local species such as bats, [protected species], birds, and other protected or priority wildlife.

Additionally:
● The area is known to experience surface water run-off from higher ground.
● Hard landscaping and soil compaction would increase downstream flood risk to existing properties.

Proper ecological surveys must be carried out in appropriate seasons, not based solely on developers’ desk-based assessments.
________________________________________

5. Flooding, Drainage and Sewage Concerns
Properties downhill from the proposed sites are already vulnerable to:
● Surface water flooding
● Drainage overload
● Overflow from nearby systems during heavy rainfall

The introduction of roads, rooftops, and impermeable surfaces would worsen surface water flow and increase the risk of flooding.

There is also no clear evidence that the local sewage and wastewater network has capacity for several hundred additional homes.
________________________________________

6. Settlement Pattern and Overdevelopment
The proposals would create a high-density urban extension that sits:
● Outside the existing settlement boundary
● At odds with the character of the surrounding rural environment
● In conflict with the pattern of development set out in the Battle Neighbourhood Plan

The scale and massing proposed are inappropriate for this sensitive landscape and are not supported by local plan evidence.
________________________________________

7. Lack of Sustainable Transport and Increased Car Dependence
The site is poorly served by:
● Frequent public transport
● Safe cycling infrastructure
● Continuous pavements

Residents would be entirely car-dependent, contradicting sustainability requirements within the NPPF.
________________________________________

Conclusion
For the reasons outlined above—traffic and highway safety risks, AONB harm, lack of infrastructure capacity, environmental damage, drainage concerns, and conflict with the Battle Neighbourhood Plan—I strongly object to the proposed allocations BT1, BT8, and BT10 in their current form.

I urge Rother District Council to remove these sites from the Draft Local Plan and to reconsider development locations that are sustainable, safe, landscape-appropriate, and aligned with community-supported planning evidence.

Thank you for considering my representation.

Yours faithfully,

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)
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.

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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.

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