See attachments.

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 very strongly against BT1 and BT10; far too big as housing sites that will destroy ecological important sites.

I did chat to the couple offering up site BT8 and they explained their reasoning behind their proposal ie we need more places where we can live and have room to work as well. Improve drainage in that area (they have permission from the road owner). They plan to lay underground cables for both power and HI-SPEED TELECOMMICATIONS which has passed Loose Farm thus far too. Amyway I'll stop wittering on and here are my main points as to why this site works: Why BT8 works
BT8 is a small and practical proposal that feels capable of fitting here without looking overdone. The draft Local Plan describes it as some 5 new dwellings with access from Hastings Road, pedestrian and cycle links, and strong boundary hedging, and it specifically says a small-scale residential development can be accepted subject to sensitive design.
It is also a site that could bring wider local benefits. A scheme of this size could help with the existing congestion on the lane, allow for a useful pull-in space, help ease parking pressure, and give an opportunity to improve drainage, while still being screened by existing houses, the care home and mature hedges.
Why scale matters
The small scale of BT8 is one of its biggest strengths. The made Battle Neighbourhood Plan already includes BA11 Blackfriars at approximately 220 dwellings, and the same Plan notes that Battle’s linear form already results in traffic bottlenecks.
Against that background, around 5 homes at BT8 is a much more proportionate and manageable form of growth. It feels restrained rather than speculative, and far easier to absorb than another large site that would add much greater pressure to local roads.
Why this fits the Battle Neighbourhood Plan
BT8 is not a Neighbourhood Plan allocation itself, but it fits well with the Plan’s policy approach. The made Plan requires new housing to be visually integrated with its surroundings under Policy HD6, traffic impacts to be mitigated under Policy IN1, infrastructure improvements under Policy IN2, safe pedestrian access under Policy IN4, and development in the High Weald AONB to conserve and enhance natural beauty under Policy EN3.
That is why BT8 makes sense in consultation terms. It is small, capable of strong screening, linked to access improvements, and much more consistent with a sensitive, landscape-aware approach than a large estate-style proposal.
Here’s an even shorter version if the consultation box is very tight:
BT8 is a sensible small-scale site that could fit into this part of Battle without looking overdeveloped. It offers the chance to improve access, reduce lane congestion, help with parking pressure and address drainage, while being well screened by existing houses, the care home and mature hedges. The Battle Neighbourhood Plan already recognises major growth at Blackfriars and existing traffic bottlenecks, so a restrained proposal of around 5 homes at BT8 is a far more proportionate option and fits well with policies on integration, traffic mitigation, infrastructure, pedestrian safety and AONB-sensitive design.

I am very strongly against BT1 and BT10; far too big as housing sites that will destroy ecological important sites.

I did chat to the couple offering up site BT8 and they explained their reasoning behind their proposal ie we need more places where we can live and have room to work as well. Improve drainage in that area (they have permission from the road owner). They plan to lay underground cables for both power and HI-SPEED TELECOMMICATIONS which has passed Loose Farm thus far too. Amyway I'll stop wittering on and here are my main points as to why this site works: Why BT8 works
BT8 is a small and practical proposal that feels capable of fitting here without looking overdone. The draft Local Plan describes it as some 5 new dwellings with access from Hastings Road, pedestrian and cycle links, and strong boundary hedging, and it specifically says a small-scale residential development can be accepted subject to sensitive design.
It is also a site that could bring wider local benefits. A scheme of this size could help with the existing congestion on the lane, allow for a useful pull-in space, help ease parking pressure, and give an opportunity to improve drainage, while still being screened by existing houses, the care home and mature hedges.
Why scale matters
The small scale of BT8 is one of its biggest strengths. The made Battle Neighbourhood Plan already includes BA11 Blackfriars at approximately 220 dwellings, and the same Plan notes that Battle’s linear form already results in traffic bottlenecks.
Against that background, around 5 homes at BT8 is a much more proportionate and manageable form of growth. It feels restrained rather than speculative, and far easier to absorb than another large site that would add much greater pressure to local roads.
Why this fits the Battle Neighbourhood Plan
BT8 is not a Neighbourhood Plan allocation itself, but it fits well with the Plan’s policy approach. The made Plan requires new housing to be visually integrated with its surroundings under Policy HD6, traffic impacts to be mitigated under Policy IN1, infrastructure improvements under Policy IN2, safe pedestrian access under Policy IN4, and development in the High Weald AONB to conserve and enhance natural beauty under Policy EN3.
That is why BT8 makes sense in consultation terms. It is small, capable of strong screening, linked to access improvements, and much more consistent with a sensitive, landscape-aware approach than a large estate-style proposal.
Here’s an even shorter version if the consultation box is very tight:
BT8 is a sensible small-scale site that could fit into this part of Battle without looking overdeveloped. It offers the chance to improve access, reduce lane congestion, help with parking pressure and address drainage, while being well screened by existing houses, the care home and mature hedges. The Battle Neighbourhood Plan already recognises major growth at Blackfriars and existing traffic bottlenecks, so a restrained proposal of around 5 homes at BT8 is a far more proportionate option and fits well with policies on integration, traffic mitigation, infrastructure, pedestrian safety and AONB-sensitive design.

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.

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.

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.

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.

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.

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.

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.

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.

We are writing to object to the planned build on the land South of Hastings Road (BT1).

Whilst we appreciate that the whole of the UK needs more homes, particularly starter and affordable homes it doesn't make any sense to build on this greenfield site.

We are objecting for the following reasons:

Hastings Road and Battle High street are already very busy. This will put even more pressure on these busy roads particularly with Blackfriars opening imminently almost opposite this development.

It is a greenfield site and AONB. With so many empty shops and buildings in local towns (not to mention the thousands of AirBnB and holiday homes) why are we building new homes on greenfield sites?

The Dr's and schools are already extremely busy with the existing population - and we have got 200+ homes being added to the mix with Blackfriars and other building already taking place across the town. How will the town cope with all these additional residents?

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:

I am writing to formally submit our objection to the proposed allocations of site BT1 and adjacent sites.

As residents of Glengorse we are reminded daily of the amount of wildlife this area has and regularly find frogs, slow worms, grass snakes, newts, toads, as well as many larger mammals in our garden. When we moved to our current home, as an “ever after home” for our family, we completed all the necessary searches and were given great reassurance in the fact that our house was not only over looking the fields for the battle of 1066 but the fact that these field, currently being used for equestrian purposes, were of great archeological importance. The old swimming pool for the Glengorse Estate is also a site dedicated for wildlife and rare water lilies, etc.

If this development goes ahead, as sadly I am to understand that “Cooper’s Estates/Developers” (a company which states it is expert in or at the very least renowned for procuring and securing Green Belt fields for residential and commercial development) seem to believe it will. The fact that developers believe things are moving ahead is a cause of great distress and strain any confidence we have in local authority and democratic processes. I also have to reiterate objections already voiced in as much as we also 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:22/03/26

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: 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.
Yours faithfully,

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 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.

I am writing to object to the proposed plan to build around 80 houses on site BT7 in the High Weald National Landscape. This land forms part of the historic setting of Battle Abbey, there has already been significant building in this area and what is a rural location will become suburban. The park, the houses and the footpath on the North side of the site all look out on this beautiful landscape of green fields and woodlands all the way to the coast in the distance. 80 houses crammed into the space will remove this view and all we will see is a housing estate. The footpath through Mansers Shaw will no longer be a countryside footpath as it will run alongside a housing estate. This landscape is supposed to be nationally protected. The Ancient Woodlands will become strewn with rubbish, dumped garden waste and flytipping. These fields and woodlands support an array of wildlife, [protected species], [protected species], frogs, snakes, deer, many species of birds, fungi and wildflowers. The sky will no longer be dark on the South side of Battle as 80 more homes with their lighting will change the sky for all the residents North of the site.
Tollgates has already got increased traffic, 80 more homes will increase the load to the point that it is no longer a quiet side street, the whole rural character of the area will be changed. 80 more vehicles queuing to get onto the North Trade Road, through the school kids walking to school, 80 more vehicles queuing to get down the North Trade Road. Congestion and traffic safety are already local concerns.
The local infrastructure is already under strain, sewage, water, drainage, GP surgeries and schools, another 80 residents? And still no 6th form? The council cannot even keep the roads in good repair with current usage. I actually think the Government targets are insane and extremely destructive for Rother. None of these proposed houses will have a decent garden, most of them will be 3/4/5 bedrooms and multiple bathrooms, as previously built, and nobody who actually lives in Battle would want to live in one. It would be interesting to know just how many of the recent new builds are bought by people who actually live here.

Dear Planning Policy Team,

We object to the proposed allocation of Land at Almonry Farm (Policy BT7) for residential development.

My primary concerns relate to the clear and immediate impacts on local congestion, loss of valued landscape, and pressure on already overstretched infrastructure.

1. Traffic and Congestion

Tollgate Drive already experiences significant congestion, particularly at peak times. It is not designed to accommodate the level of additional traffic that a development of this scale would generate.

North Trade Road is similarly congested, especially during school and commuter hours. Any increase in traffic will worsen delays, reduce safety, and impact the day-to-day functioning of the area.

The proposal acknowledges that further assessment is required, which highlights that the allocation is premature without clear, deliverable solutions.

2. Loss of Landscape and Residential Amenity

The site currently provides open views across fields which are an important part of the area’s character. These views were a key factor in our recent property purchase and contribute significantly to residential amenity.

Development would replace this open countryside with housing, resulting in a clear and permanent loss of natural outlook and encroachment on the rural setting.

3. Pressure on Local Services

Local infrastructure is already under strain. Schools such as Claverham Community College are oversubscribed, and GP surgeries and dental services are difficult to access.

This development would add further pressure without any clear or guaranteed provision to support the increased demand.

Conclusion

Given the existing congestion, loss of valued landscape, and lack of infrastructure capacity, this allocation is not justified and should not proceed.

We respectfully request that Policy BT7 - Land at Almonry Farm and surrounding farming lands - be removed from the Draft Local Plan.
Yours faithfully,

Policy Reference BT7

We write to voice our concerns and objections to the above proposed development.
We reside in Asten Fields, Battle, in close proximity to the proposed site. Our concerns are as follows.

1. Impact on Ancient Woodland and protected species.

2. Loss of local greenfield land.

3. Traffic and pedestrian safety via Tollgates, plus increased traffic on the North Trade Road. This is already a junction and area which is dangerously congested at peak times……i.e. drop off & pick up not only at school times, but also with Claverham Community College being attended by many students in the evenings and at weekends.
How will the additional traffic be managed to ensure pedestrian safety??

4. Pressure on already overflowing G P surgeries and schools. Also infrastructure…..
i.e. Fresh water. Sewage disposal etc.

(Should this development, unfortunately, go ahead regardless of objections, it is imperative that all adequate infrastructure should be in place before commencement!
We also consider in no way should there be any pedestrian access from the proposed site through Asten Fields.)

5. Surface water flooding risks, impacting neighbouring areas.

6. Impact on the setting of Battle Abbey, and the 1066 Battlefield.
Surely this proposed site connects the Battlefield site to Tent Hill site, which has historical value in itself.

We hope you will seriously consider our concerns, which we know are shared by many.

Subject: Objection to Proposed Allocation/Development of Site BT1 – Land South of Hastings Road, Battle

I am writing to formally object to the proposed allocation and potential development of Site BT1 – Land south of Hastings Road, Battle, on the grounds of flood risk and other key planning concerns.

We have recently seen evidence of Flood Risk from the Council
The Sustainability Appraisal supporting the emerging Local Plan (Rother District Council, Interim SA Report, January 2026) explicitly assessed Site BT1 under the flood risk objective (SA5). The appraisal reports the following scoring for the site:
• SA5a – Flood risk to people and property: 0 (Neutral)
• SA5b – Impact of development on flood risk elsewhere: –– (Significant Negative)
• SA5c – Opportunities to reduce flood risk: + (Minor Positive)

The significant negative (––) under SA5b demonstrates that development of this site is likely to increase flood risk elsewhere, by reducing natural drainage capacity, displacing floodwater, and increasing surface water runoff. The site currently functions as part of the natural floodplain south of Hastings Road, which plays a critical role in managing water flows and protecting existing homes and infrastructure.

National planning guidance requires that development should avoid increasing flood risk elsewhere, and where evidence suggests that impacts are significant, the precautionary principle should apply. The Council’s own assessment confirms that Site BT1 fails this test. Allocating or developing this land would therefore be inconsistent with both local and national flood-risk policy.

We would like to also add, the following list of additional planning concerns
1. Loss of Green Infrastructure and Landscape Character
Site BT1 contributes to the rural setting and visual character of southern Battle. Development would erode open countryside, reducing green corridors and harming the local landscape, which is valued by residents and recognised in local planning guidance. There is just too much construction and development planned for the Battle area to be considered sustainable. There are areas which could support this kind of development, but Battle is not one of them. This amount of building will change Battle forever and ruin the tourism which the area relies upon. You cannot have things all ways.
2. Cumulative Impact on Flood Risk and Drainage
Beyond the site itself, cumulative development in Battle and surrounding floodplain areas would amplify flood risk to existing homes, businesses, and transport routes. Relying on mitigation measures such as SuDS alone may be insufficient.
3. Conflict with the Council’s Own Evidence Base
Allocating Site BT1 would directly contradict the Sustainability Appraisal’s own assessment, which explicitly identifies significant negative flood risk impacts

Conclusion
The evidence clearly indicates that Site BT1 is unsuitable for development. The Council’s own assessment identifies significant negative impacts on flood risk elsewhere, which is a strong statutory and planning consideration. Combined with concerns over landscape, highway safety, infrastructure capacity, and cumulative flood impacts, the site fails multiple key planning tests.

I therefore strongly urge Rother District Council to remove Site BT1 from the proposed allocations.

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 sites 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 the vast amount of extra housing proposed. 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.

Regarding the BT10 site proposal, the site is on a side of the road with no pavement and the pavement that is in place on the opposite side of the road is extremely narrow and unsafe in parts, only allowing single file. It would not accommodate push chairs safely or allow children to walk safely into town or school. Plus, it is nearly 2 miles to walk to town or the nearest amenities. The site entrance is on a 40mph straight where vehicles regularly speed. To have an extra 65 dwellings and potentially 200-300 extra cars on the road is unsafe and the infrastructure is simply not suitable to accommodate this extra volume. It can take up to 15 minutes to cross the road to get to the footpath- it can be very dangerous. The road would need widening and appropriate footpaths added on the side of the proposed development or it is negligent if you are expecting people to access the town safely.

We know of at least 4 fatalities along this section of road over the years, surely this is unacceptable and you can see that the road is dangerous and busy enough at the moment without adding so many extra cars to it and increasing risk and hazards.

2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT10 proposes building on 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: BT10 has an area of ancient woodland to the south of the site and a tree lined boundary of ancient oak trees to the west of the site. This proposal directly threatens the environment and surrounding wildlife which is home to bats, slow worms, and other ‘protected species’ which we have witnessed in our field which borders the site.
• Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT10 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 BT10 and BT8 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 and extremely narrow, unsafe footpaths.

As a previous teacher at Battle and Langton Primary School, I have seen firsthand the pressures of oversubscribed classes. The school is simply not able to accommodate a potential huge demand for extra places. Claverham Community College will face similar issues. North Trade Road, the high street and surrounding roads all face huge delays already in the school drop off and pick up times.

I urge you to consider the safety our children. Councils have previously encouraged children to walk to school, this will simply not be possible to do so safely from sites BT10 and BT8. Footpaths are inadequate and on the wrong side of the road. This also fails to give disabled residents the opportunity to safely access the shops or local amenities.

Conclusion
These proposals would have a huge and damaging impact on the area with an increase in noise and disturbance from the extra traffic as well as major safety and environmental concerns. I urge the Council to remove development pressure from BT10 and BT8 and BT1 areas 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 sites 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 the vast amount of extra housing proposed. 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.

Regarding the BT10 site proposal, the site is on a side of the road with no pavement. The pavement that is in place on the opposite side of the road is extremely narrow and unsafe in parts, only allowing single file. It would not accommodate push chairs safely or allow children to walk safely into town or school. As I regularly walk the route I have to either wait in driveways to briefly walk in the road to pass other footpath users. Furthermore the street lighting along this stretch is far from adequate, in the winter months I have to use a torch!

The site entrance is on a 40mph straight where vehicles regularly speed. To have an extra 65 dwellings and potentially 200-300 extra cars on the road is unsafe and the infrastructure is simply not suitable to accommodate this extra volume. It can take up to 15 minutes to cross the road to get to the footpath- it can be very dangerous. We have recently experienced the road with additional traffic when the work was being carried out on Hastings which meant a large increase in traffic using Battle to get to the A21. You only need to drive down the road to see what impact increased traffic has had to the road! The road would need widening and appropriate footpaths added both sides of the road.

We know of at least 4 fatalities along this section of road over the years, surely this is unacceptable and you can see that the road is dangerous and busy enough at the moment without adding so many extra cars to it and increasing risk and hazards. You should be looking at reducing the road speed down to 30mph rather than adding more traffic.

BT10 is nearly a 2 mile to walk to town where the nearest amenities. This is far from ideal and does not fit with Active Travel England’s Standing Advice Note about sustainable development that states that when planning new developments they should be built close to local service and facilities and not to rely on cars.

2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT10 proposes building on 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: BT10 has an area of ancient woodland to the south of the site and a tree lined boundary of ancient oak trees to the west of the site. This proposal directly threatens the environment and surrounding wildlife which is home to bats, slow worms, other ‘protected species’ which we have witnessed in our field which borders the site.
• Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT10 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 BT10 and BT8 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 and extremely narrow, unsafe footpaths.

As a previous governor at Battle and Langton Primary School, I have seen firsthand the pressures of oversubscribed classes. The school is simply not able to accommodate a potential huge demand for extra places. Claverham Community College will face similar issues. North Trade Road, the high street and surrounding roads all face huge delays already in the school drop off and pick up times.

I urge you to consider the safety our children. Councils have previously encouraged children to walk to school, this will simply not be possible to do so safely from sites BT10 and BT8. Footpaths are inadequate and on the wrong side of the road. This also fails to give disabled residents the opportunity to walk safely to the shops or local amenities.

Conclusion
These proposals would have a huge and damaging impact on the area with an increase in noise and disturbance from the extra traffic as well as major safety and environmental concerns. I urge the Council to remove development pressure from BT10 and BT8 and BT1 areas before progressing the plan further.

I would like to comment on the proposed Draft Rother Local Plan 2025 – 2042

Firstly, I would like to register a complaint about the consultation process, as I consider it inaccessible in the online form to the majority of residents. I had registered, and had specific points to make on the plan, but the length of the document, the difficulty in navigating to where to place the comments and to which proposal, made it an incredibly difficult task, if not impossible to the majority of residents including myself.

In email, I am specifically referring to the allocations in Policy BT1, BT8 and BT10 on the greenfield land south of Hastings Road, and I object to these proposals. My comments are as follows:

1. TrafficChaos. The A2100 on Hastings Road is already congested, and set to increase with the Blackfriers development. To propose an additional 200-250 houses on the road will only contribute to the chaos. The vast majority of the residents in the proposed developments will be reliant on cars, and the majority of these will have children requiring transport to either the primary or secondary schools, which are the other side of Battle in which there is only one road connection through town Already, during rush hours and school runs, the traffic is often at standstill, and often backed up as far as my house over a mile from Battle. Children do not walk to the school along Hastings Road because it is so busy and dangerous. This proposal does not seem to consider where the schools are positioned in Battle. Would it not make sense to position any new housing developments in easier reach to the schools, around North Trade Road area. To propose developments BT 10 BT1 BT8, at the opposite side of Battle to the schools would only increase traffic chaos and pollution and the draft plan must consider where the main traffic would come from to the main sites in Battle, which are the schools
2. Environmental Impact. In choosing a total green field site, clearly the proposal is deciding that the loss of wildlife habitats is not important in an area of ANOB. With the council now having permitted development with the Blackfriers devopment around Starsmead, resulting in a huge future impact on the environment and on wildlife on the other side of Hastings Road, the proposed BT1 BT8 and BT10 now represents a further urbanization of the land and loss of the environment between Battle and Hastings area. When does Battle area stop becoming an ANOB. How is the council reconciling this draft plan with its environmental agenda and responsibilities?
3. Infrastructure. Having lived in Battle for 25 years, I used to be able to get a Doctors appointment in 1 or 2 days, now it is up to 3 weeks. I am unable to get on the local NHS dentist registration. So before more residences are added to the Battle area, the plan needs to address how local residents are adequately served. What commitments are the council offering for new services to accommodate the influx of new residents, and what commitments are made to maintain, or repair the roads,
4. Heath and Safety. The proposed developments BT 1 BT8 and BT10 will only add to the traffic chaos and therefore pollution on Hastings Road. There are very few people who currently walk or cycle to Battle along Hastings Road due to the speed of the cars and trucks when the traffic is moving, or the pollution from cars and trucks when the traffic is stationary. There is no pavement on the side of the road where BT11 and BT8 are proposed to be located, and the pavement on the other side of Hastings Road is too narrow for safety.

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.

I live in Starrs Mead and the congestion at the top of my road since stopping the building works and houses going up for sale has made the road unsafe for my young family to walk to Battle. The traffic has increased exponentially

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 should like to register my objection to the current proposal to build domestic properties on the site of the farmland in Battle to the south of Asten Fields as part of the proposal outlined in https://rother.oc2.uk/document/184



The land itself is unsuitable, the impact on local animal and plant life would be devastating and the location would mean a poor quality of life for those in residence as well as the lowered quality of living for those in neighbouring properties.



· The land on which the proposed development would be made is of too high a water content for solid and sustainable construction, especially during wetter seasons such as Spring and Autumn when it is prone to flooding. It is however perfect for seasonal and annual farming, for which it is currently allocated and for which it could be used if it were resold to an owner with such an interest.

· Development in this space would disrupt key local wildlife such as the current thriving hedgehog community (which are a protected species under the Wildlife and Countryside Act of 1981) and which are currently residing in the extensive hedgerow spanning the length of the public easement on the boundary of this land which would be irrevocably and irreparably damaged by such a development.

· Development in this space would also require the modification of the composition of the ground in order to lay suitable foundations for any domestic property. Such modification of the soil chemistry would deplete resource for the neighbouring trees and plant life of Manser’s Shaw which is part of the High Weald and which is an Area of Outstanding Natural Beauty.

· Owing to the points given above, any domestic properties built in this space would be subject to regular flooding as well as holding a high risk of natural damage to the properties which would have a detrimental impact on the lives and well-being of any residents therein.

· Additionally, the destruction and damage of this Area of Outstanding Natural Beauty would consequentially severely reduce the quality of life of those residents in neighbouring properties as well as the many tourists who visit this area.



In summary, the area proposed is wholly unsuitable for domestic properties.



It is, however, ideal for farmland and should remain as such.



Land in this area is frequently marshy and prone to flooding, it is for this very reason that the roads have followed such historic paths along the ridgeways and have held their same route even as far back as the conquest, where their unique position afforded a safe path for both the English and the Norman armies, leading to their meeting in Battle. Land too far away from these ridges is poor for use as a foundation of building or for traffic but is ideal for farming and woodland.



Rather than looking to extend the town to its north and south into these areas, you would be well advised to seek to fulfil the governmental requirement for increased housing by extending Battle and its neighbours along the roads and ridgeways already in use for traffic and with much space on either side to build narrow lines of well-founded houses that would be both accessible via the roadway as well as ideally placed for solid and long-lasting living that would allow continuing generations to benefit for many years to come.

Objection to additional residential development in Battle.

I object to additional Residential development in Battle on the following grounds
1 The town of Battle is overpopulated with one through road which is always congested impacting journey times through Battle. The Safety of road users, pedestrians, inconvenience to users of Battle crossing roads and pollution.
2 The amenities are inefficient for the population resulting in residents are inadequately provided meaning long delays for doctors, dentists and schools are over subscribed resulting in long waits
3 The additional volume of traffic in North Trade Road will add to congestion and deterioration of the recently improvements to the road surface and will impact on residents access to their property and increase the impact on congestion in the town
4 Tollgates is totally unsuitable for the entrance to a major housing development . It is narrow , used by parents dropping off and collecting pupils at Claverham, already has a recent residential development which has already caused problems for accessing North Trade Road which caused difficult access for residents due to large construction traffic
5 The freedom to enjoy walking in the countryside which is benefits health and wellbeing
6 The loss of a significant historical environment and the impact on wildlife plants and protected species.

Proposed policy BT1, BT8 and BT10

I am writing to object to the proposals for the above developments.

I understand the instructions from government but locally elected councillors should not allow this to ruin the lives of inhabitants of Battle and override the democratically agreed neighbourhood plan.

The proposed increased developments with access from Hastings Road will add a large amount of extra traffic to an already busy road which will make its use very difficult especially at busy times. With between 250 and 300 extra units proposed the level of extra traffic will create significant delays and bottlenecks. The extra fumes discharged will adversely affect any existing properties bordering the road.

The proposals talk of pedestrian and cycle access from the sites to Hastings Road but this is irrelevant because it is already dangerous to cycle in Hastings Road due to the heavy traffic and narrowness of the road.

I used to walk down to Battle instead of taking my car but no longer do this because of the current level of traffic in the road. Only one side of the road has a footpath. The fumes emitted make this walk unpleasant and narrow paths and large lorries make walking along this road feel both unsafe and unhealthy. These developments will only make this worse. There will be much extra traffic which will be moving much slower and thus creating more pollution and risk to health for those in vehicles but also more importantly for those who have properties near to the road.

Large vehicles delivering goods to properties in Hastings Road currently stop half on the pavements which adds to the danger for pedestrians and creates bottlenecks for traffic. Much more traffic on the road passing these parked vehicles will cause significantly more delay than at present.

I am a resident of Battle and I wish to make my comments known as follows:

1) Balanced
BT8 feels like the sort of modest, workable site that should be included in this consultation. It is a small proposal, closely related to existing development, and capable of being designed in a way that is well screened by the existing houses, the care home and mature boundary hedges. It could also bring wider local benefits by helping with access, congestion on the lane, parking pressure and drainage. That seems a far more proportionate form of growth for this part of Battle than a much larger estate-style scheme.

2) Traffic and passing-place
One of the strongest points in favour of BT8 is that it offers a realistic opportunity to improve a lane that already suffers from congestion and blockage. A small development here could help provide a proper pull-in space and improve vehicle movements in a way that benefits existing residents as well as future occupiers. That sits well with the Battle Neighbourhood Plan’s emphasis on traffic mitigation and reducing the impact of development on local infrastructure.

3) Parking and local pressure
BT8 is attractive because it could help address a real day-to-day problem rather than simply add more housing. Parking pressure already affects this part of the lane, and a small amount of additional parking provision linked to the site would be a practical benefit for existing residents. That is consistent with the Battle Neighbourhood Plan’s approach to parking and infrastructure, which expects development to respond to local needs rather than ignore them.

4) Landscape and screening
Although the site is in the High Weald National Landscape, BT8 appears to be one of the more contained options because it is read against existing ribbon development on Hastings Road, the nearby care home and established hedgerows. With sensitive design and strong boundary planting, a very small scheme here could be visually integrated into its surroundings. That reflects the Battle Neighbourhood Plan’s focus on conserving landscape character while allowing carefully judged development that fits its setting.

5) Scale and restraint
What makes BT8 persuasive is its restraint. At around five dwellings, it is plainly not an attempt to cram in the maximum possible number of homes. That modest scale is important in Battle, where the made Neighbourhood Plan already accepts substantial growth pressures and allocates Blackfriars at around 220 dwellings. In that context, BT8 reads as a small, proportionate and more easily absorbed addition rather than a major expansion.

6) Better than larger options
BT8 seems much easier to justify than the much larger options in and around Battle, especially the sites BT1 and BT10. A site of around five homes, with strong screening and local access improvements, is a very different proposition from a large scheme that would inevitably place much more pressure on already sensitive roads. The Battle Neighbourhood Plan itself notes that Battle’s linear form already results in traffic bottlenecks, which makes the case for preferring smaller, better-contained opportunities even stronger.

7) Live-work and flexibility
Another positive feature of BT8 is the possibility of live-work units. That gives the site a flexibility that goes beyond standard housing and could support small-scale local employment as well as homes. On a site of this size, that kind of mixed and adaptable approach feels more in keeping with Battle than a conventional high-yield scheme, especially when combined with improved access and strong landscaping.

8) Drainage and infrastructure
BT8 should be looked at not just as a housing site, but as an opportunity to improve local conditions. If development here helps resolve drainage issues and secures better access arrangements, that would be a genuine infrastructure gain for the area. That fits well with the Battle Neighbourhood Plan’s support for new and improved infrastructure where it meets identified local needs without causing significant harm.

Dear Sir/Madam

It has been pointed out to me that you intend to commit sacrilege at Land at Almonry Farm (Policy BT7) to build eighty houses.

I strongly object on the grounds that you would be destroying Our Heritage.

Traffic and floods would follow such a fallacy,

Please abandon this crazy idea.

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.

Good morning,
On behalf of our client, Rurban Estates Limited, please find enclosed a representation on the Regulation 18 Draft Local Plan, which has principally been submitted to support the strategic growth identified for Battle and the proposed allocation of ‘Land adjoining Little Brans’ (Draft Policy BT10). Comments on the draft policies more generally are also enclosed, together with supporting appendices.
I would be grateful for confirmation of receipt. Thank you.
Kind regards,
Hannah

Good morning,
On behalf of our client, Rurban Estates Limited, please find enclosed a representation on the Regulation 18 Draft Local Plan, which has principally been submitted to support the strategic growth identified for Battle and the proposed allocation of ‘Land adjoining Little Brans’ (Draft Policy BT10). Comments on the draft policies more generally are also enclosed, together with supporting appendices.
I would be grateful for confirmation of receipt. Thank you.
Kind regards,
Hannah

I object to both BT1 and BT10 as they are too big for Battle. I support B8 and list my comments on it below: Why BT8 works
BT8 is a modest, well-contained proposal in a location already influenced by existing development. Rother’s draft plan identifies the site as Land adjacent to 1 Loose Farm Cottages, Battle, with an allocation of some 5 new dwellings that will include live-work units on a 0.17ha suburban site. The draft policy already requires a new vehicular access from Hastings Road, new pedestrian and cycle links, and a strong boundary hedge to the southern and western edges. The supporting text also accepts that, although the site lies within the High Weald National Landscape, a small-scale residential development can be accepted subject to a sensitive design because of the existing ribbon development on Hastings Road and nearby built form. It is well hidden by mature hedging and the access part into the small field will also provide a pull in for vehicles trying to pass each other in a long narrow section of the lane. I also know that the plan is also to build a small "green" car parking area for the overspill when there is limited parking at the bottom end of the lane. We need more places for work/living spaces in Battle which would reduce parking and travelling. The site is very walkable to the station also
That is why BT8 feels like a practical and proportionate option for Battle. It is small enough to be designed carefully, screened properly and integrated with what is already there, while also offering the chance to improve local access arrangements and strengthen pedestrian links. The fact that the draft policy specifically requires boundary hedging and links to Hastings Road shows that this is intended to be a contained and mitigated scheme, not an overblown estate-style extension.
Why scale matters
Scale is one of the strongest arguments in favour of BT8. The made Battle Civil Parish Neighbourhood Plan acknowledges that Battle and the hamlet of Telham were expected to accommodate at least 475 dwellings, and its Policy HD2 allocates BA11 Blackfriars at approximately 220 dwellings. The same Plan also notes that Battle’s linear development results in traffic bottlenecks. Against that background, a site of around 5 dwellings at BT8 is plainly a much more restrained proposition and far easier to absorb than a large, traffic-intensive scheme.
That restraint matters. BT8 has not been pushed to maximise numbers. It is a low-key, small-site response that matches the reality that Battle already has to take significant growth while also dealing with known traffic and movement constraints. In consultation terms, that makes BT8 easier to justify as a sensible addition: it offers a limited number of homes, potential live-work flexibility, and a scale that is much more likely to sit comfortably within the southern edge of Battle.
Why this fits the Battle Neighbourhood Plan
Although BT8 is not itself a site allocated in the made Neighbourhood Plan, its inclusion is capable of fitting well with the Plan’s policy framework. Policy HD6 says that new housing must be “visually integrated with their surroundings.” Policy IN1 requires traffic-generating development to demonstrate mitigation. Policy IN2 supports new and improved infrastructure where it meets identified needs without causing significant harm. Policy IN4 requires safe pedestrian access linking to existing footway networks and key services. Policy EN3 says development in the High Weald AONB will only be supported where it conserves and enhances natural beauty and, where relevant, restores watercourses, reflects settlement pattern, relates well to routeways, and conserves fields, trees and hedgerows.
BT8 maps onto those policies surprisingly well. The draft allocation already builds in the things the Neighbourhood Plan asks for: a small number of homes, access from Hastings Road, pedestrian and cycle links, and a strong hedge buffer. The site is also described by Rother as acceptable only as small-scale development with sensitive design, which is exactly the kind of controlled, landscape-aware approach the Neighbourhood Plan points toward. For consultation purposes, it is therefore entirely reasonable to say that BT8 is consistent with the Battle Neighbourhood Plan’s emphasis on integration, traffic mitigation, infrastructure improvement, pedestrian safety and AONB-sensitive design.

I object to both BT1 and BT10 as they are too big for Battle. I support B8 and list my comments on it below: Why BT8 works
BT8 is a modest, well-contained proposal in a location already influenced by existing development. Rother’s draft plan identifies the site as Land adjacent to 1 Loose Farm Cottages, Battle, with an allocation of some 5 new dwellings that will include live-work units on a 0.17ha suburban site. The draft policy already requires a new vehicular access from Hastings Road, new pedestrian and cycle links, and a strong boundary hedge to the southern and western edges. The supporting text also accepts that, although the site lies within the High Weald National Landscape, a small-scale residential development can be accepted subject to a sensitive design because of the existing ribbon development on Hastings Road and nearby built form. It is well hidden by mature hedging and the access part into the small field will also provide a pull in for vehicles trying to pass each other in a long narrow section of the lane. I also know that the plan is also to build a small "green" car parking area for the overspill when there is limited parking at the bottom end of the lane. We need more places for work/living spaces in Battle which would reduce parking and travelling. The site is very walkable to the station also
That is why BT8 feels like a practical and proportionate option for Battle. It is small enough to be designed carefully, screened properly and integrated with what is already there, while also offering the chance to improve local access arrangements and strengthen pedestrian links. The fact that the draft policy specifically requires boundary hedging and links to Hastings Road shows that this is intended to be a contained and mitigated scheme, not an overblown estate-style extension.
Why scale matters
Scale is one of the strongest arguments in favour of BT8. The made Battle Civil Parish Neighbourhood Plan acknowledges that Battle and the hamlet of Telham were expected to accommodate at least 475 dwellings, and its Policy HD2 allocates BA11 Blackfriars at approximately 220 dwellings. The same Plan also notes that Battle’s linear development results in traffic bottlenecks. Against that background, a site of around 5 dwellings at BT8 is plainly a much more restrained proposition and far easier to absorb than a large, traffic-intensive scheme.
That restraint matters. BT8 has not been pushed to maximise numbers. It is a low-key, small-site response that matches the reality that Battle already has to take significant growth while also dealing with known traffic and movement constraints. In consultation terms, that makes BT8 easier to justify as a sensible addition: it offers a limited number of homes, potential live-work flexibility, and a scale that is much more likely to sit comfortably within the southern edge of Battle.
Why this fits the Battle Neighbourhood Plan
Although BT8 is not itself a site allocated in the made Neighbourhood Plan, its inclusion is capable of fitting well with the Plan’s policy framework. Policy HD6 says that new housing must be “visually integrated with their surroundings.” Policy IN1 requires traffic-generating development to demonstrate mitigation. Policy IN2 supports new and improved infrastructure where it meets identified needs without causing significant harm. Policy IN4 requires safe pedestrian access linking to existing footway networks and key services. Policy EN3 says development in the High Weald AONB will only be supported where it conserves and enhances natural beauty and, where relevant, restores watercourses, reflects settlement pattern, relates well to routeways, and conserves fields, trees and hedgerows.
BT8 maps onto those policies surprisingly well. The draft allocation already builds in the things the Neighbourhood Plan asks for: a small number of homes, access from Hastings Road, pedestrian and cycle links, and a strong hedge buffer. The site is also described by Rother as acceptable only as small-scale development with sensitive design, which is exactly the kind of controlled, landscape-aware approach the Neighbourhood Plan points toward. For consultation purposes, it is therefore entirely reasonable to say that BT8 is consistent with the Battle Neighbourhood Plan’s emphasis on integration, traffic mitigation, infrastructure improvement, pedestrian safety and AONB-sensitive design.

Monday 23rd March 2025

Objection to the Draft Rother Local Plan (2025 – 2042) Land at Almonry Farm (policy BT7) on behalf of residents of Asten Fields, from the Asten Fields Residents Association.

Dear Rother District Council,

On behalf of the Residents of Asten Fields, I am writing to you to formally object to the above proposals. As Chair of the Residents Association, it is upon me to write to you and express this objection.

Out of the 78 properties within Asten Fields, I have met and spoke directly with 60 households to encourage responses to the consultation process. Each and every household has expressed clear objection to the plan. There have been many concerns raised by residents, though they do follow similar headings as described below:
Infrastructure concerns:
Residents have not been assured by the plan that Battle has sufficient infrastructure for the 80 or so houses proposed for the plot. Concerns raised centred around:
• Heavy demand placed upon local roads and the roads in the area becoming more clogged with local traffic on roads which are already struggling.
• Lack of regular public transport and pressure placed on existing ones,
• Insufficient utilities, including water and sewage provisions to deal with the demands,
• Surface water run off leading to the increased demands on the local shaw, fields and lowlands,
• Demand on local services, such as doctor’s surgeries, dentists, health services, Schools and amenities.
Residents were concerned about the effects on the Environment this vast development will have these included:
• The loss of natural habitats for insects, birds, mammals and reptiles as the land has a number of know species of animals present that support the local ecosystem.
• The loss of habitat for plants, trees and flowers.
• The effects and impingement on to ancient woodland, such as Manser’s Shaw and impingement onto ancient hedgerows as the development runs up close to these areas.
• The hydrology of the area, considering this to be a zone 2 & 3 flood zone and the effects development would have on the shaw and drainage of the land,
• Increase pollution from more vehicles on the traffic clogged roads, especially at schooltime and during the day,
• The loss of farmland to development as rother has defined this considered prime farmland,
• The encroachment onto our national landscape with the walk and view from the footpath being obstructed by the development,
• The removal or the re-direction of the footpath away from its original path,
• The change of the aesthetics for the local area.

Effects on our local Heritage:
Residents expressed many concerns about the loss of Heritage and the general feel of the town. Many residents had objections due to the nature of our town, it being one of the most important towns in England. Encroachment onto potential Battlefields and the general aesthetics of heavy development would ruin the town and its appeal. Many people visit not only for its historical importance, but to enjoy Battles surrounding wildness, walks and countryside. Once this is gone, residents feel it will be lost forever.

Residents who live in Asten Fields, who follow the walks, woods and use the countryside and, enjoy living in the town are deeply worried about the plan. What this and other developments means is loss of the open spaces that we all treasure. A deep sense of loss is felt as the environment around us is lost to development.

Within the local plan, the residents see no commitment to improvements of the local neighbourhood, infrastructure and services. Many services in place are already under pressure, roads crumbling with potholes and for the population already here, it is a busy and full town.

Kindest regards,