Sirs

As my address shows, I am a resident of Starrs Mead, behind which the Blackfriars/Tapestry development is now reaching its later stages.

I was staggered to learn that Rother District Council is now proposing yet MORE developments to the south of Battle Hill/Hastings Road, in such great numbers, including one of around 250 homes, with an entrance less than 200 metres from that of the Blackfriars/Tapestry development.

The close proximity of entrances to two highly populated developments on an already congested road seems madness, especially with the possibility of road widening, etc., seeming unlikely, suggesting that further congestion chaos is inevitable. This could have a serious impact on travel times but, more importantly, on pollution/health and on road safety itself.

My immediate reaction was one of shock. I appreciate that the Government has greatly increased the levels of development every local authority must accept – I am not blinkered to the bigger picture – but we are talking about GREENFIELD sites within the HIGH WEALD NATIONAL LANDSCAPE which is designated an AREA OF OUTSTANDING NATURAL BEAUTY.

If that weren’t enough, the Rother Draft Local Plan 2025-42 is in stark contrast to the Battle Neighbourhood Plan which suggested 15 homes for the area. I appreciate that neither is writ in stone, but to go from 15 to 250 dwellings is, you must at admit not so much a U-turn as a complete disregard - a trampling upon – existing proposals which makes a mockery of the wishes of town planning/local councils.

In addition to all of the above there is, of course, the strain on the town of Battle itself. It’s hard enough to get a GP or dentist’s appointment, to park in town and all these will be first stretched by such a dramatic increase in population, not to mention on the schools.

And, finally, there is the environmental impact of the new developments – quite apart for the additional road pollution – with not only the immediate loss of wildlife habitats but the knock-on effect of the inevitable and dramatic increase in surface water which will flow downhill, increasing the risk of flooding of properties in these areas.

I strongly object to these proposals in the strongest of terms for the reasons outlined. I appreciate that additional housing may be necessary/demanded by Government but urge you to consider sites and housing density:

NOT in the High Weald National Landscape
NOT in a designated Area of Outstanding Natural Beauty
NOT on greenfield sites
NOT impacting to such an extent on the habitat of countryside wildlife
NOT feeding into an overstretched road system and the dangers this entails
NOT increasing the likelihood of additional localised flooding
NOT in such complete contrast to the existing Battle Neighbourhood Plan
NOT putting such a strain on local services/infrastructure
I should stress that I am not a ‘NIMBY’ having raised no objections to the Blackfriars/Tapestry development which is very much in my own ‘back yard’ and been an active part in positive public consultations. It is simply that these latest proposals are madness and need serious reconsideration.

Thank you.

[Covering email note] Please find attached my objections to this planned development. I live in Starrs Mead and I already am starting to see how the additional development called Tapestry is impacting my life. Any further developments near me or Glengorse is going to put a huge strain on traffic, schools and GP surgery’s.

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)
23rd March 2026
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.

Dear Planning Policy Team,

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.

Dear Planning Policy Team,

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.

I wish to add my comments to the above consultation. I found it virtually impossible to use the "comment"ing as you go section on the whole of your Land Plan document sadly. Way too big a document to view easily in one go especially for busy people!

I am against - BT1 - way too big and very visual especially as it is too close to the Blackfriars site which make ingress and access difficult. It is against the Battle Neighbourhood Plans recommendations of small Sites

• BT10 - for exactly the same reasons as above but also in such a dense number of houses, surrounded by large and ancient oaks and next to an Ancient Woodland, it will impact this and also stop a wildlife corridor that exists currently

I support Site BT8 because:

It will improve access from Hastings Road to the care-home, provide a useful pull-in point on a narrow section of lane, help with parking pressures, and address drainage problems that have affected this location for some time. The possible inclusion of live-work units is another positive feature, giving flexibility for small businesses and home working. Just as importantly, the site has been kept to a very modest scale. Around five dwellings is well below the numbers suggested in the Battle Neighbourhood Plan, and that lower density shows a welcome commitment to a sensitive form of development rather than overdevelopment.

I support Site BT8 because it is a modest, well-screened and discreet site with 5 work/dwelling well-thought out development proposal, that would provide housing while also delivering wider community benefits. The site accommodates a limited development without appearing out of character, and is closely related to existing developments and is naturally well screened by nearby houses, the care home, and mature hedgerows. This means that a small residential scheme here could be integrated into the area in a way that respects local character and avoids unnecessary visual intrusion. It will be set back from the main boundary hedge in a circular form and the provision of the work/home buildings would be ideal in promoting a visual pleasing (in the local style recommended by BNP)

It will enhance the lives of others living around it as there will be better drainage (with permission already granted from the road owner to do this). The owners will also be laying all current overground cables underneath the road at their expense which will result in less power cuts for the end of land houses and also high speed cabling for high speed interconnection for every house, something that has not yet reached this neighbourhood

There are also strong practical reasons to support the site. The lane nearby often experiences congestion and limited passing space, and this development offers an opportunity to create a proper pull-in area and which will improve day-to-day access for residents along a long and narrow part of the lane that can cause problems for access. Additional parking provision and better drainage would also be important local gains when considering the overspill from parking at the Care Home, which hasn't been adequately resolved. The possibility of including live-work units adds further value by supporting more flexible living and employment patterns. Above all, I support the fact that the site has not been overdeveloped. The proposed number of homes is well below the numbers suggested in the Battle Neighbourhood Plan, which demonstrates a restrained and responsible approach. For that reason, I believe BT8 is a suitable and beneficial site for inclusion.

I do imagine that people in the immediate locality will throw everything they can at stopping this site, but they really should have come to find out exactly what is being offered here [end of sentence redacted]. This site is certainly not the overdevelopment of cramming in as many houses as is feasible for monetary gain. The houses/workshops will also be as compliant with renewable energy, water storage/water havesting, ground source systems and the likes. I understand that roof tiles that are also solar panels would also be used so no ugly large solar panels that blight the countryside I'd like to move into one myself being totally honest!

I also support the inclusion of Gypsy and Traveller Site 1 at High Views. [Information on site occupiers redacted].

I wish to add my comments to the above consultation. I found it virtually impossible to use the "comment"ing as you go section on the whole of your Land Plan document sadly. Way too big a document to view easily in one go especially for busy people!

I am against - BT1 - way too big and very visual especially as it is too close to the Blackfriars site which make ingress and access difficult. It is against the Battle Neighbourhood Plans recommendations of small Sites

• BT10 - for exactly the same reasons as above but also in such a dense number of houses, surrounded by large and ancient oaks and next to an Ancient Woodland, it will impact this and also stop a wildlife corridor that exists currently

I support Site BT8 because:

It will improve access from Hastings Road to the care-home, provide a useful pull-in point on a narrow section of lane, help with parking pressures, and address drainage problems that have affected this location for some time. The possible inclusion of live-work units is another positive feature, giving flexibility for small businesses and home working. Just as importantly, the site has been kept to a very modest scale. Around five dwellings is well below the numbers suggested in the Battle Neighbourhood Plan, and that lower density shows a welcome commitment to a sensitive form of development rather than overdevelopment.

I support Site BT8 because it is a modest, well-screened and discreet site with 5 work/dwelling well-thought out development proposal, that would provide housing while also delivering wider community benefits. The site accommodates a limited development without appearing out of character, and is closely related to existing developments and is naturally well screened by nearby houses, the care home, and mature hedgerows. This means that a small residential scheme here could be integrated into the area in a way that respects local character and avoids unnecessary visual intrusion. It will be set back from the main boundary hedge in a circular form and the provision of the work/home buildings would be ideal in promoting a visual pleasing (in the local style recommended by BNP)

It will enhance the lives of others living around it as there will be better drainage (with permission already granted from the road owner to do this). The owners will also be laying all current overground cables underneath the road at their expense which will result in less power cuts for the end of land houses and also high speed cabling for high speed interconnection for every house, something that has not yet reached this neighbourhood

There are also strong practical reasons to support the site. The lane nearby often experiences congestion and limited passing space, and this development offers an opportunity to create a proper pull-in area and which will improve day-to-day access for residents along a long and narrow part of the lane that can cause problems for access. Additional parking provision and better drainage would also be important local gains when considering the overspill from parking at the Care Home, which hasn't been adequately resolved. The possibility of including live-work units adds further value by supporting more flexible living and employment patterns. Above all, I support the fact that the site has not been overdeveloped. The proposed number of homes is well below the numbers suggested in the Battle Neighbourhood Plan, which demonstrates a restrained and responsible approach. For that reason, I believe BT8 is a suitable and beneficial site for inclusion.

I do imagine that people in the immediate locality will throw everything they can at stopping this site, but they really should have come to find out exactly what is being offered here [end of sentence redacted]. This site is certainly not the overdevelopment of cramming in as many houses as is feasible for monetary gain. The houses/workshops will also be as compliant with renewable energy, water storage/water havesting, ground source systems and the likes. I understand that roof tiles that are also solar panels would also be used so no ugly large solar panels that blight the countryside I'd like to move into one myself being totally honest!

I also support the inclusion of Gypsy and Traveller Site 1 at High Views. [Information on site occupiers redacted].

Re: Objection to Proposed Allocation Policy BT6 (Land north of Sunny Rise, Battle) and BT7 (Land at Almonry Farm, Battle) – Draft Rother Local Plan (2025-2042)

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


1. Traffic Congestion and Safety on North Trade Road
North Trade Road is already at breaking point. Traffic is backed up every morning and afternoon, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of new 10 dwellings in BT6 and 80 dwellings in BT7. The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding major junctions to this existing chaos without significant infrastructure upgrades is negligent.

Junction Interference and "Staggered" Conflict: At a distance of around 600 metres, these two major junctions will interfere with one another and North Trade Road would inevitably be blocked by "tailback" traffic exiting or entering BT7 (80 dwellings), especially considering that in between BT6 and BT7 is Claverham College which causes considerable additional congestion in North Trade Road at drop-off and pick-up times. All this creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.

The 30mph to 40mph Transition Danger: The site (BT6) sits at a critical transition point where the speed limit increases / decreases from 30mph to 40mph.
• Acceleration Risk: Vehicles traveling outbound (west bound on North Trade Road) are accelerating where the BT6 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from west on North Trade Road (inbound) often carry higher speeds before decelerating.

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


2. Environmental Impact and Air Quality

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

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

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


3. Infrastructure Deficits

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.


Conclusion

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

As the residents property management company for the 30 freehold properties within Frederick Thatcher Place, we wish to comment on the proposed 10 property expansion north of Sunny Rise, Battle under your reference BT6 and on the proposed Almonry Place development under BT7.

Traffic Congestion and Safety on North Trade Road
North Trade Road is already at breaking point. Traffic is backed up every morning and afternoon, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of new 10 dwellings in BT6 and 80 dwellings in BT7. The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding extra volumes without significant infrastructure upgrades is negligent.

Junction Interference and "Staggered" Conflict: At a distance of around 600 metres, these two major junctions will interfere with one another and North Trade Road would inevitably be blocked by "tailback" traffic exiting or entering BT7 (80 dwellings), especially considering that in between BT6 and BT7, Claverham College is located with around 1,150 students being dropped off in the morning and picked up in the afternoon – both of which already causing congestion on North Trade Road, especially with indiscriminate parking on pavements. All this creates a high risk of collisions and accidents as drivers attempt to navigate traffic in such a short span.

The 30mph to 40mph Transition Danger: The site (BT6) sits at a critical point where the speed limit increases / decreases from 30mph to 40mph. This particulary affects the two Frederick Thatcher Place entrances/exits. We have highlighted this problem in previous planning application objections (RR/2020/1875P and RR/2019/2845P).

Adding to volumes in this 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 Greenfield Land and the National Landscape (AONB)
Greenfield Loss: BT6 and BT7 propose building on 0.58 and 4.80 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
National Landscape (AONB) Impact: The sites are within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 35 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major developments should only occur in exceptional circumstances (NPPF Paragraph 189).

Heritage Constraints, Ancient Woodland and Deciduous Woodland Priority Habitat:
Frederick Thatcher Place (FTP), which is Grade 2* listed, is not mentioned within the RDC policy text. A serious omission! The BT6 plans negatively impact Grade 2* listed buildings. The Sunny Rise development was designed to blend-in with FTP, as much as possible.
Both the BT6 and the BT7 proposals also threaten and affect Ancient Woodland and Deciduous Woodland Priority Habitat located adjacent to the sites. Wildlife corridors, mature trees and hedging, as well as ancient woodland would be severed by them. The BT7 proposal would have an impact on Grade 2* listed property as well as it's proximity to heritage assets including the Registered Battlefield where the 1066 Battle of Hastings was fought and Battle Conservation Area.

Flooding Risk and Surface Water (NPPF Paragraph 170): The policy texts for BT6 explicitly acknowledge that parts of the site are at risk of surface water flooding. Replacing natural drainage with impermeable surfaces (housing/roads) on land already identified as a flood risk is reckless planning that endangers existing properties, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests. The proposed expansion onto a downward sloping area does not make any sense; Kelk Wood and Beech Estate land would also be affected. FTP already suffers from North Trade Road water run-off, due to a policy of only checking and emptying A271 drainage every 6 months. Thatcher Place Estate Company already faces extra expenditure to try and stop water run-off from North Trade Road.

BT7 land would also be affected with any such development.

Conclusion

These proposals to expand development at BT6 and also BT7, with up to 90 properties on a Greenfield National Landscape site, both with Grade 2* listed buildings, risks of surface water flooding and threatening ancient buildings are unsound. They ignore statutory environmental considerations and local experience. We urge Rother District Council to remove development pressure from this area before progressing the plans further.

Basically I support BT8 (Loose Farm) but I am against BT1 (too big and affecting an historic and important ecological site and BT10 (again way too big and in an important wildlife corridor and backing onto Ancient Woodland)

Although BT8 is not itself a made Neighbourhood Plan allocation, its inclusion in the draft Local Plan is plainly capable of sitting in conformity with the Battle Civil Parish Neighbourhood Plan 2019–2028, which forms part of the statutory Development Plan for the parish. The made Plan’s policy framework is not limited to its named allocations in Policy HD2; it also establishes a wider set of criteria around integration, traffic, infrastructure, parking, pedestrian safety and landscape protection that are directly relevant when considering whether a small additional site such as BT8 is appropriate in Battle.

In that respect, BT8 aligns well with the structure of the Neighbourhood Plan. The draft Local Plan identifies BT8 as a small suburban site of about 0.17ha, with built development on about 0.11ha, for some 5 dwellings that could include live-work units. The supporting text expressly acknowledges that the site lies on the southern edge of Battle within the High Weald National Landscape, but also concludes that, having regard to the existing residential development on Hastings Road, a small-scale residential development can be accepted subject to sensitive design. That conclusion fits comfortably with the Neighbourhood Plan’s preference for development that is restrained in scale and responsive to local character rather than simply maximising yield.

The strongest policy cross-over is with Policy HD6, which requires new housing to be visually integrated with its surroundings; Policy IN1, which requires traffic-generating development to demonstrate mitigation; Policy IN2, which supports new and improved infrastructure to meet parish needs; Policy IN4, which requires safe pedestrian links to existing networks and key services; and Policy EN3, which requires development in the High Weald AONB to conserve and enhance natural beauty, restore the natural function of watercourses where relevant, and conserve hedgerows and field patterns. Taken together, those policies do not point away from BT8; they point toward exactly the type of carefully designed, heavily screened, access-conscious and drainage-aware small site now being proposed.

There is also a proportionality point that deserves weight. The made Neighbourhood Plan already allocates BA11 Blackfriars at approximately 220 dwellings, and elsewhere recognises that Battle’s linear form already results in traffic bottlenecks. Against that background, a further small site of around five homes, particularly one that can improve a constrained lane and be visually contained by existing development and boundary planting, is plainly a different planning proposition from strategic-scale expansion. On any fair reading, BT8 is a modest, policy-compatible and locally responsive option that can be included without undermining the Battle Neighbourhood Plan’s wider objectives.

Basically I support BT8 (Loose Farm) but I am against BT1 (too big and affecting an historic and important ecological site and BT10 (again way too big and in an important wildlife corridor and backing onto Ancient Woodland)

Although BT8 is not itself a made Neighbourhood Plan allocation, its inclusion in the draft Local Plan is plainly capable of sitting in conformity with the Battle Civil Parish Neighbourhood Plan 2019–2028, which forms part of the statutory Development Plan for the parish. The made Plan’s policy framework is not limited to its named allocations in Policy HD2; it also establishes a wider set of criteria around integration, traffic, infrastructure, parking, pedestrian safety and landscape protection that are directly relevant when considering whether a small additional site such as BT8 is appropriate in Battle.

In that respect, BT8 aligns well with the structure of the Neighbourhood Plan. The draft Local Plan identifies BT8 as a small suburban site of about 0.17ha, with built development on about 0.11ha, for some 5 dwellings that could include live-work units. The supporting text expressly acknowledges that the site lies on the southern edge of Battle within the High Weald National Landscape, but also concludes that, having regard to the existing residential development on Hastings Road, a small-scale residential development can be accepted subject to sensitive design. That conclusion fits comfortably with the Neighbourhood Plan’s preference for development that is restrained in scale and responsive to local character rather than simply maximising yield.

The strongest policy cross-over is with Policy HD6, which requires new housing to be visually integrated with its surroundings; Policy IN1, which requires traffic-generating development to demonstrate mitigation; Policy IN2, which supports new and improved infrastructure to meet parish needs; Policy IN4, which requires safe pedestrian links to existing networks and key services; and Policy EN3, which requires development in the High Weald AONB to conserve and enhance natural beauty, restore the natural function of watercourses where relevant, and conserve hedgerows and field patterns. Taken together, those policies do not point away from BT8; they point toward exactly the type of carefully designed, heavily screened, access-conscious and drainage-aware small site now being proposed.

There is also a proportionality point that deserves weight. The made Neighbourhood Plan already allocates BA11 Blackfriars at approximately 220 dwellings, and elsewhere recognises that Battle’s linear form already results in traffic bottlenecks. Against that background, a further small site of around five homes, particularly one that can improve a constrained lane and be visually contained by existing development and boundary planting, is plainly a different planning proposition from strategic-scale expansion. On any fair reading, BT8 is a modest, policy-compatible and locally responsive option that can be included without undermining the Battle Neighbourhood Plan’s wider objectives.

Objection to Proposed Allocation Policy BT10 Draft Rother Local Plan (2025-2042)

I am writing to formally submit my objection to the proposed allocation of site BT10 within the Draft Rother Local Plan for Battle and Surrounding area. As a resident of Hastings Road and a resident of Battle since birth I have direct, daily experience of the area surrounding this proposed site (BT10) and quite frankly am astounded that this site is deemed acceptable to be included in this plan.

This development is unsupportable based on many aspects including 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). This site has been rejected in the past on three occasions, so it is unfathomable as to why it is now deemed as a suitable site.

I list below my objections and reasoning below:

1. Misleading and deceiving information included in the Draft Rother Local Plan

On review of the Draft Rother Local Plan online and at the recent meeting held at Battle Memorial hall meeting I noticed that the map included in the Draft Rother Local Plan does not include the already built Blackfriars development.

To anyone resident in the local area Blackfriars development is a significant housing project providing 200 new homes, covering 16 hectares of our town. The Rother District Council website itself has maps of the Blackfriars development and detailed information about the development yet it is not included in the very important Rother Draft Plan. This is deceiving and dishonest.

To any lay person or government decision maker who views the Draft Rother Local Plan this lack of clarity and honesty is deceiving and could lead to decisions being made on factually incorrect information. This development already provides over 200 homes and is already adding to the burden faced by local residents in terms of infrastructure and local amenities.

The Draft Rother Local Plan should not have been published with this inaccurate map as it does not show the current level of development in our historic town that has already taken place and the difficulties already being faced by current residents in terms of additional housing, inadequate infrastructure and stretched services.

I have raised this concern to our local MP. It is hoped he will raise this further in upcoming meetings to be the voice of his constituents where I have raised this as a concern.

2. Traffic Congestion and Safety on Hastings Road

Hastings Road (A2100) is already at breaking point. Traffic is horrendous throughout the day. Regular tail backs during peak hours that create bottlenecks that simply cannot accommodate any additional vehicle movements that would be generated by this proposed development site. The Battle Neighbourhood Plan (Battle NP) explicitly identified traffic congestion is a critical weakness of the parish, and this has not changed in recent times. Adding additional vehicles (a suggested minimum of 65 dwellings could swell to over 100 additional vehicles if not more) and new busy junctions (there appears to be two access points to BT10) to this existing chaos without significant infrastructure upgrades is pure negligence. It is also a dangerous road with frequent speeding cars. The proposed site of BT10 is just off a straight section of the road where vehicles often speed and overtake dangerously. The access points of this proposed development could pose a risk to life.

40mph Danger The site of BT10 sits at a critical point where the speed limit on the road is already 40mph. This makes entry onto the road already extremely dangerous for current residents, without the addition of 65 dwellings from BT10 and the number of vehicles that would be added to the surrounding area if this development was to be agreed and built. All infrastructure suggestions within BT10 are fundamentally unsafe and “safe and suitable access to the site cannot be achieved for all users” (NPPF Paragraph 115). This is not just for new residents of site BT10 but also dangerous for all current residents along this stretch of road.

Cycle path and improvements to pedestrian infrastructure If any member of Rother District Council has walked along Hastings Road (A2100) in recent times they will notice the narrow nature of the existing pavements and the road itself. How improvements could be made to the pavement including a cycle path gives me great cause for concern. Local residents currently have to walk single file at some points along this road whilst on the pavement due to the narrow path and overgrown hedges. Cars speed along the road at times perilously close to pedestrians and dangerously overtake along this section of road. In addition to this, there is also detail in the plan suggesting improved or creating cycle links. Where this cycle path would fit along the A2100 in a safe and sustainable way is beyond me. As a local resident who walks along this road frequently it is a hazard and not a safe area. There must be other sites that would already have space for cycle paths, better links or already be closer to amenities.

Crossing BT10 proposes to “include a crossing point” along Hastings Road. This is quite frankly a ludicrous suggestion and one that could cause major issues for vehicles and pedestrians alike. As mentioned above this is a 40mph stretch of road and is quite unsuitable for any proposed installation of this kind. The suggestion of including a crossing at this point on the A2100 in line with this proposed development could pose a risk to life.

3. Environmental Impact

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

Greenfield Loss: BT10 proposes building on 5.75 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 – much like that of a national park so why is this location even included in the plan? In addition, the suggestion of 30 dwellings per hectare is surely urban in nature, not rural, and is entirely out of keeping with the character of the High Weald and the local surroundings. Major development should only occur in exceptional circumstances and this proposal is not exceptional.

Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 65 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises. It is also interesting to note that there is much wildlife in this area including bats, deer, foxes, hedgehogs and other small mammals. We cannot afford for natural habitats in a rural setting to be destroyed.

Ancient woodland BT10 is edged by ancient woodland and hedgerows that would be destroyed with any building on this land despite promises made. Ancient woodland should remain. Battle is a historic town and we have a right now and for future generations to protect our green areas.

Flood Risk and Surface Water (NPPF Paragraph 170) The policy text for BT10 explicitly acknowledges this as an “area at risk of surface water flooding". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on hectares of land already identified as a flood risk is reckless planning that endangers existing land and homes. On this particular site there is a central natural stream and underground water table. This is heard underfoot at all times of year and poses a significant risk to any potential development on this site. The topography of this piece of land is sloping and not suitable for building.

3. Infrastructure Deficits and Delivery Failures

Critical Lack of Infrastructure (GP, Dentistry, Schools) Our historic town lacks the capacity to support this population increase which would be inevitable with the level of proposed sites in Battle and the surrounding area. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management). None of which have been documented in detail in this plan.

Hospitals: Local NHS Organisations are at breaking point with demand far exceeding capacity. I work in the local NHS Trust and have for over 20 years. I have first-hand experience of the difficulties faced in terms of demand on the services and lacking capacity to care for our local population as it currently stands, not withstanding any influx of people moving into our historic town and using local facilities.

Schools: The Council’s own supporting text for BT10 does not even broach the significant distance from our towns primary schools and secondary schools BT10 as a development site is located. This implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions along Hastings Road. The site is location over 1.5 miles away from any local amenities therefore requiring substantial investment to be made in pavements, cycle lanes, improved transport links and better roads which are just not suitable when there are other sites in the town that are closer to amenities and already have been placed links for the residents.

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.

Transport links: BT10 is also “some distance from Battle train station”. There are sites much closer to our local schools and with better transport links. A bus stop is documented as being close to the entrance of the site of BT10. This bus service is far from frequent and does not provide wide links to the surrounding area. It is also an extremely limited service. With increased traffic in the area this will not be a suitable solution for any prosed additional population.

Further concerns about the proposal for site BT10 is the suggestion of “limiting development to the north-eastern section (closest to existing ribbon development) will serve to limit the effect on the settlement pattern”. This will involve building along the eye line of current homes which is not in keeping with this area and surely a concern for planners. This is more of an issue when you consider how this development site can be seen from other roads in the area, including Telham Lane. Most houses along this stretch of the A2100 are built since 1930 onwards and any development on BT10 would be most out of keeping and not subtle to the local area or home owners along this road, who take great pride in their homes and gardens.

BT10 presents me with further grave concerns that larger scale identified locations within Battle and surrounding areas may not proceed, but a ‘smaller’ development like the one proposed for BT10 would then be given the green light to proceed, as smaller in scale and decision makers would suggest less impact. For all the reasons stated above this is not the case and the impact of 65 houses on this small agricultural field would be huge from all aspects that I have mentioned in this correspondence.

Summary of objection:

This proposal expands development on a Greenfield National Landscape site amidst an infrastructure crisis.

There are other sites outside of our historic town of Battle that would be much more suitable with better access to existing infrastructure and sites that would have less environmental impact on the surrounding areas. There are even areas that should be considered outside of Battle and the surrounding area that would be suitable to East Sussex residents rather than ruining our beautiful historic town for us and future generations.

The Draft Rother Local Plan is unsound as it ignores statutory environmental duties and residents lived experience. I urge the Council to remove development pressure from the plan specifically BT10 before progressing the plans any further.

Please see attached representation on Q36 regarding the proposed allocation at Almonry Farm, Battle in support of a larger development of some 180 dwellings in comparison with the 80 dwellings as per draft Polcy BT7.

Attached representation also includes Appendices 1-5.

NETWORK RAIL RESPONSE TO ROTHER LOCAL PLAN 2025 – 2042 – DEVELOPMENT STRATEGY AND
SITE ALLOCATIONS

These representations are submitted to Rother District Council (‘the Council’) by Network Rail
Infrastructure Limited (‘Network Rail’), in respect of the Regulation 18 consultation on the
Development Strategy and Site Allocations (‘the Strategy’).

It is important that opportunities to promote the use of the railway as a more sustainable modes of
transport are identified and taken forward. The railway network is a vital element of the country’s
economy and a key component in the drive to deliver the Government’s sustainable agenda. Rother
benefits from several railway stations benefiting current and future residents, employees and others.
These stations are also likely to need investment to ensure they remain fit to service future growth
and we would encourage the Council to work with the railway to secure this investment where it is
needed.

NR is the statutory undertaker for maintaining and operating railway infrastructure of England,
Scotland, and Wales. As statutory undertaker, NR is under license from the Department for Transport
(DfT) and Transport Scotland (TS) and regulated by the Office of Rail and Road (ORR) to maintain and
enhance the operational railway and its assets, ensuring the provision of a safe operational railway.
As a matter of course, proponents of sites which are close to the railway boundary or sites which
could affect the railway asset directly are required to engage with our Asset Protection and
Optimisation team (ASPRO).

On the path towards Great British Railways (GBR), Network Rail (NR) and Southeastern Railway have
formed the South Eastern Railway (SER) which operates services through in Rother. Further services
are also operated by Southern Railway In producing these representations, NR has consulted with SER
and Southern Railway and this should be considered a joint railway response.

Representations

This section sets out the areas for which comments have been made in relation to the Regulation 18
consultation.

Vision, Overall Priorities and Strategic Objectives

NR supports the proposed changes to the Strategic Spatial Objectives (SSO). In relation to the newly
added point 11 within the SSO, NR would encourage specific reference to the Government’s proposals
to provide a presumption in favour of development round railway stations, subject to other
considerations. This provides the opportunity for densities to be maximised, an increase in the use of
stations and investment into improving the rail network to cater for the new users. NR suggests the
following amendment (in italics):

Deliver sustainable development by making the optimal use of land, especially around railway stations,
including by prioritising the use of brownfield land and ensuring all new development is designed and
built to appropriate densities, having regard to local context and character.

Infrastructure needs

NR has reviewed the most recently published Infrastructure Delivery Plan (IDP) in January 2026 to
support the Strategy. One aspect missing is the opportunity for a new station entrance at Bexhill
railway station. This will allow for improved passenger flows and extra capacity within the entrance
hall at the station, benefitting current and future users of the station.

Battle station has received central government funding to progress the proposed access for all (AFA)
scheme, to provide step free access between both platforms, to detailed design. Further funding will
be required to deliver the full works at the station. NR will provide further updates for the Regulation
19 consultation if any additional work or needs are identified.

Further, NR supports the Council’s intent to secure the timely delivery of infrastructure and we would
encourage the Council to refer to the use of planning conditions and obligations to ensure this
infrastructure is secured in a timely manner.

Preparing the Development Strategy

NR supports the changes proposed in figure 9 which seeks to deliver higher density development
around Bexhill, Battle and Rye stations. As previously noted, opportunities exist to provide additional
capacity and improved accessibility at Bexhill station and there are proposals to deliver an AfA
scheme at Battle station. Rye station has some step free access to platorms however it should be
noted that there is a level crossing at Ferry Road to the west of the station. To safely deliver higher
densities around Rye, a solution to the level crossing safety issues is needed. NR will work with the
Council to identify suitable options to deal with this matter.

Vision for Bexhill

NR welcomes the inclusion within the vision of reference to improving station capacity. This reflects
NR’s earlier comments. Increasing density in Bexhill given its connections would be considered to a
sustainable development strategy. Where possible, sites close to Bexhill station should be maximised
to enable future occupiers to benefit from the proximity to the station.

Vision for Battle and Surrounding Settlements

Battle station is proposed to benefit from AFA which will deliver step free access between both
platforms. Given this scheme will enable those with mobility issues and other means of being
encumbered to sue the station should open opportunities for better connections with existing and
future housing sites. We would welcome the Council’s consideration on how the AfA scheme at
battle station could support this. Reference should be made to supporting proposed improvements
at Battle station within the Vision.

Vision for Rye and the Eastern Settlements Cluster

NR notes the vision and proposals to increase growth in Rye. As previously noted, Rye station has
some step free access which could be further improved and consideration needs to be given to the
impact on the level crossing at Ferry Road.

Site allocations

Policy BX4 – Beeching Road Enhancement Area

NR believe the proposed site allocation should make a reasonable contribution towards improvements
at the station. This should be in terms of accessibility and supporting active travel through providing
sufficient cycle storage capacity at the station. This aligns with the proposed active travel
improvements within the draft Policy and ensures a connected link from site to station.

Policy BX5 – Land south-east of Beeching Road
NR supports the draft allocation and proposed financial contributions towards public transport as
within part v. This should specify the railway station as there are improvements that could be made.
Given its proximity to the station, the draft allocation should consider increasing the density to meet
the Government’s agenda of increasing development around railway stations.

Policy BX7 – Sainsbury’s, 1 Buckhurst Place

NR supports the draft site allocation at part v which includes providing improved public transport
infrastructure. The proximity to the railway means that a comprehensive masterplan should
consider how to improve access to the station. Given its proximity to the station, development here
should be maximised.

Policy BX9 – Land south of Terminus Road

NR notes the proximity of the railway to the south of the draft allocation. Suitable boundary fencing
and noise mitigation measures will be required to protect future occupiers. Additionally, some land
to the eastern boundary of the draft allocation is owned by the railway. It appears this land falls
within the red line of the draft site allocation. NR would be willing to discuss if this land is necessary
and how this could support the delivery of the allocation.

Policy BX10 – 30 Dorset Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. The red line of the draft allocation appears to be close to, and
incorporating, NR land. NR would be willing to discuss if this land is necessary and how this could
support the delivery of the allocation.

Policy BX12 – 2a Sackville Road

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required. There are current issues of a collapsing wall impacting on the railway at
the site. Engagement with NR from early in the process is essential.

Policy BX16 - Land west of Pages Lane, Bexhill

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX19 - Gorses Car Park and open space, The Gorses

The draft site allocation is near the railway and suitable boundary fencing and noise mitigation
measures will be required.

Policy BX23 - Land north of Rosewood Park

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX27 – Beeches Farm and land north of Barnhorn Road

The draft site allocation should explore opportunities to provide contribution towards improving
connectivity with the railway. The nearest station is Cooden however there is limited accessibility to
the station with no obvious prospect for bus services to drop off/pick up close to the station. There
is the potential for many occupiers to travel to Bexhill station which could put pressure on the
existing car park at the station. Consideration is needed to determine how this need could be met.

Policy BX29 - North Bexhill Growth Area – Infrastructure Policy

Consideration should be given as to how best to connect the Growth Area with the public transport
and the railway. The draft site allocations within the Growth Area should consider how they can
contribute, individually and cumulatively, to improving access to the railway.

Proposed Site Allocations for Battle and Surrounding Areas

Policy BT1 - Land south of Hastings Road, Battle

The proximity of the site to Battle railway station means a contribution should be sought to ensure
delivery of the AfA scheme at the station to support growth.

Proposed Site Allocations for Rye and the Eastern Settlements Cluster

Policy RY6 - Former Council Depot, Cyprus Place

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Policy RY9 - Former Lower School Site, off Ferry Road, Rye

The proximity of the site to the Ferry Road level crossing means the impact of pedestrian and car
movements need to be considered in respect of railway safety.

Conclusions

We welcome the Council’s approach to securing infrastructure and promoting the railway. We look
forward to continued collaboration as the Plan develops and seeking to make best use of the rail
network and the opportunities presented from this.
I trust the above is helpful and we hope our representations will be considered. We would welcome
a follow up meeting to expand on the points made.

Objection to Proposed Allocation Policy BT1, 8 &10 (land south of Hastings Road
Battle)

We are writing to formally submit our objections to the proposed allocations of site BT1 and adjacent sites. We are residents of Hastings Road and have direct experience of the site conditions. We consider this development to be completely unsuitable and unsupportable.

1. Traffic Congestion and Safety on Hastings Road
Hastings Road (A2100) is incredibly busy. Traffic is constantly gridlocked especially at peak times. It would be impossible to accommodate the additional traffic from the proposed 250 dwellings and the traffic coming from the new Blackfriars development. The two entrances to these developments are barely 200 metres apart. It’s increasingly difficult to pull out from driveways and almost impossible to cross the road on foot. The high street and listed properties are already suffering at present and with the much higher volume of traffic proposed will be in great danger.

2. Environmental and Ecological Impact
The proposed site is within the High Weald National Landscape AONB and is protected by law to conserve and enhance its natural beauty. BTI proposes building on 11.09 hectares of greenfield land.
The proposal threatens fields, paddocks and the High Weald Wild Flower Meadow Priority Habitat. The construction of at least 250 homes will obviously destroy wild life meadows and hedgerows. It will most certainly not enhance the natural beauty and the distinctive historic character of the area.

2.Flooding Risk and Surface Water
Replacing natural drainage ie fields with hard surfaces such as roads will inevitably lead to flooding further downhill as already acknowledged by the previous council sustainability appraisal.

3. Infrastructure
The town of Battle is not large enough to support such a large increase in population. There are not sufficient schools, doctors or dentists for this proposed new development, let alone the soon to be increased population from the Blackfriars development.

We are disappointed and feel that the council and councillors are not working in the interest of Battle residents.

Basically I support BT8 (Loose Farm) but I am against BT1 (too big and affecting an historic and important ecological site and BT10 (again way too big and in an important wildlife corridor and backing onto Ancient Woodland)

Although BT8 is not itself a made Neighbourhood Plan allocation, its inclusion in the draft Local Plan is plainly capable of sitting in conformity with the Battle Civil Parish Neighbourhood Plan 2019–2028, which forms part of the statutory Development Plan for the parish. The made Plan’s policy framework is not limited to its named allocations in Policy HD2; it also establishes a wider set of criteria around integration, traffic, infrastructure, parking, pedestrian safety and landscape protection that are directly relevant when considering whether a small additional site such as BT8 is appropriate in Battle.
In that respect, BT8 aligns well with the structure of the Neighbourhood Plan. The draft Local Plan identifies BT8 as a small suburban site of about 0.17ha, with built development on about 0.11ha, for some 5 dwellings that could include live-work units. The supporting text expressly acknowledges that the site lies on the southern edge of Battle within the High Weald National Landscape, but also concludes that, having regard to the existing residential development on Hastings Road, a small-scale residential development can be accepted subject to sensitive design. That conclusion fits comfortably with the Neighbourhood Plan’s preference for development that is restrained in scale and responsive to local character rather than simply maximising yield.
The strongest policy cross-over is with Policy HD6, which requires new housing to be visually integrated with its surroundings; Policy IN1, which requires traffic-generating development to demonstrate mitigation; Policy IN2, which supports new and improved infrastructure to meet parish needs; Policy IN4, which requires safe pedestrian links to existing networks and key services; and Policy EN3, which requires development in the High Weald AONB to conserve and enhance natural beauty, restore the natural function of watercourses where relevant, and conserve hedgerows and field patterns. Taken together, those policies do not point away from BT8; they point toward exactly the type of carefully designed, heavily screened, access-conscious and drainage-aware small site now being proposed.
There is also a proportionality point that deserves weight. The made Neighbourhood Plan already allocates BA11 Blackfriars at approximately 220 dwellings, and elsewhere recognises that Battle’s linear form already results in traffic bottlenecks. Against that background, a further small site of around five homes, particularly one that can improve a constrained lane and be visually contained by existing development and boundary planting, is plainly a different planning proposition from strategic-scale expansion. On any fair reading, BT8 is a modest, policy-compatible and locally responsive option that can be included without undermining the Battle Neighbourhood Plan’s wider objectives.

Objections to Draft Rother Local Plan (2025-2042): Battle sites

Thank you for the opportunity to comment on the Regulation 18 Consultation: Development Strategy and
Site Allocations. We are writing to formally object to the Local Plan proposals as outlined in this
document. As local residents of Battle – who has lived through the construction phase of the nearby illconceived local authority inspired Blackfriars development and foresee a further sharp deterioration in
the quality of life of this town as a result of these current proposals – our comments here relate to the
Battle sites in particular although we are critical of many aspects of this local plan document.

CONSULTATION PROCESS

We object to the use of digital response ‘submit your comments’ software on the Rother website. This,
presented in an unnecessarily complicated piecemeal format, will encourage duplication and, ultimately
we believe, will deter residents from commenting. Therefore, we have sent this coordinated objection to
the planning department by email.

We would note that, as the mapping information is of low definition, it is very difficult to pin-point the
location of the boundaries of some of the developments even with the aid of geo-mapping programs.

We also note that there is a discrepancy as to the end of the consultation period: the paper Response
Form states 17.00 today, whereas the website 23.59 today.

STRATEGIC OBJECTIVES AND VISION

The Local Plan process was designed to provide a valuable opportunity to help shape the future of a
community. RDC’s vision outlined for Battle and Surrounding Settlements, highlights retention of
historical character and preservation of local distinctiveness in its High Weald setting. However, this
aspiration is proven to be meaningless and contradictory given the relatively large scale of residential
development proposed - without an explanation for its strategic necessity. It will in fact dilute the
character of the town, and as building mainly on greenfield sites will encroach on the very High Weald
setting that the vision promotes, such proposals are very cynical. The sustainability code (Fig 21) is
considered by RDC to be green (good sustainability) but no evidence for that is given. In fact, the explanatory text highlights the constraints to development, such as road congestion etc. The high level of
development proposed is not at ‘sensitive’ levels and ignores the additional pressure on the Town’s
infrastructure from the many households waiting to be installed at Blackfriars. These proposals reach a
new low in local government planning ‘doublethink’ as, in truth, central government has imposed targets
on local authorities and RDC has cynically shoehorned these allocations in presumably in response to
demand from local developers.

SITE ALLOCATIONS

Employment

As a general comment the intensification of existing employment sites is worthwhile. Existing
employment space, particularly B1 industrial in the Battle area is poor quality and enhanced employment
opportunities for local residents would be welcomed. However, it seems unlikely that this will be built
out now, any more than the huge floorspace allocations in the Core Strategy were brought forward and
Battle residents, swelled by the large numbers of households to be created by Blackfriars, will be forced
to commute as before. We support the proposed 8 new units at Beech Farm (BT3).

Residential

• In principle we would support infill and some limited brownfield development in Battle and
reclaiming empty houses.
• We object to all the large multi-dwelling residential developments proposed here, Policies B1-11
as being unsustainable. These are unsupportable based on material planning considerations, the
democratically adopted Battle Neighbourhood Plan, and the National Planning Policy Framework
(NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making
Policies).
• There are further technical reasons on Hastings Road why these sites cannot be brought forward
as detailed below:

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 additional vehicle movements. 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 sideswipe accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.

The 30mph to 40mph Transition Danger

These 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.

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 nearly 700 new 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.

Infrastructure deficits and delivery failures

In addition, there are infrastructure issues as listed below and will be exacerbated when Blackfriars is
occupied.

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. It is known that, for example, Martin Oak surgery
has inadequate facilities.

• 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.

• It is our understanding that both Claverham Community College and Battle & Langton
primary schools are oversubscribed.

Damning Blackfriars Precedent

We have no confidence in any assurances that the necessary infrastructure will be brought forwards
to support the town and we have seen the Council fail to deliver on similar promises at Blackfriars
despite warnings from residents.

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 council-controlled Blackfriars project had
to be value-engineered due to market pressures, a waste of tax-payers money, there is the risk that
the other sites will be similarly watered down once permission is granted.

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

Objections to Draft Rother Local Plan (2025-2042): Battle sites

Thank you for the opportunity to comment on the Regulation 18 Consultation: Development Strategy and
Site Allocations. We are writing to formally object to the Local Plan proposals as outlined in this
document. As local residents of Battle – who has lived through the construction phase of the nearby illconceived local authority inspired Blackfriars development and foresee a further sharp deterioration in
the quality of life of this town as a result of these current proposals – our comments here relate to the
Battle sites in particular although we are critical of many aspects of this local plan document.

CONSULTATION PROCESS

We object to the use of digital response ‘submit your comments’ software on the Rother website. This,
presented in an unnecessarily complicated piecemeal format, will encourage duplication and, ultimately
we believe, will deter residents from commenting. Therefore, we have sent this coordinated objection to
the planning department by email.

We would note that, as the mapping information is of low definition, it is very difficult to pin-point the
location of the boundaries of some of the developments even with the aid of geo-mapping programs.

We also note that there is a discrepancy as to the end of the consultation period: the paper Response
Form states 17.00 today, whereas the website 23.59 today.

STRATEGIC OBJECTIVES AND VISION

The Local Plan process was designed to provide a valuable opportunity to help shape the future of a
community. RDC’s vision outlined for Battle and Surrounding Settlements, highlights retention of
historical character and preservation of local distinctiveness in its High Weald setting. However, this
aspiration is proven to be meaningless and contradictory given the relatively large scale of residential
development proposed - without an explanation for its strategic necessity. It will in fact dilute the
character of the town, and as building mainly on greenfield sites will encroach on the very High Weald
setting that the vision promotes, such proposals are very cynical. The sustainability code (Fig 21) is
considered by RDC to be green (good sustainability) but no evidence for that is given. In fact, the explanatory text highlights the constraints to development, such as road congestion etc. The high level of
development proposed is not at ‘sensitive’ levels and ignores the additional pressure on the Town’s
infrastructure from the many households waiting to be installed at Blackfriars. These proposals reach a
new low in local government planning ‘doublethink’ as, in truth, central government has imposed targets
on local authorities and RDC has cynically shoehorned these allocations in presumably in response to
demand from local developers.

SITE ALLOCATIONS

Employment

As a general comment the intensification of existing employment sites is worthwhile. Existing
employment space, particularly B1 industrial in the Battle area is poor quality and enhanced employment
opportunities for local residents would be welcomed. However, it seems unlikely that this will be built
out now, any more than the huge floorspace allocations in the Core Strategy were brought forward and
Battle residents, swelled by the large numbers of households to be created by Blackfriars, will be forced
to commute as before. We support the proposed 8 new units at Beech Farm (BT3).

Residential

• In principle we would support infill and some limited brownfield development in Battle and
reclaiming empty houses.
• We object to all the large multi-dwelling residential developments proposed here, Policies B1-11
as being unsustainable. These are unsupportable based on material planning considerations, the
democratically adopted Battle Neighbourhood Plan, and the National Planning Policy Framework
(NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making
Policies).
• There are further technical reasons on Hastings Road why these sites cannot be brought forward
as detailed below:

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 additional vehicle movements. 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 sideswipe accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.

The 30mph to 40mph Transition Danger

These 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.

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 nearly 700 new 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.

Infrastructure deficits and delivery failures

In addition, there are infrastructure issues as listed below and will be exacerbated when Blackfriars is
occupied.

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. It is known that, for example, Martin Oak surgery
has inadequate facilities.

• 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.

• It is our understanding that both Claverham Community College and Battle & Langton
primary schools are oversubscribed.

Damning Blackfriars Precedent

We have no confidence in any assurances that the necessary infrastructure will be brought forwards
to support the town and we have seen the Council fail to deliver on similar promises at Blackfriars
despite warnings from residents.

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 council-controlled Blackfriars project had
to be value-engineered due to market pressures, a waste of tax-payers money, there is the risk that
the other sites will be similarly watered down once permission is granted.

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

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

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

1. Traffic Congestion and Safety on Hastings Road

Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites mentioned above). The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding a major junction to this existing chaos without significant infrastructure upgrades is negligent.
Junction Interference and "Staggered" Conflict At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (220 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 220 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises.
Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT1 explicitly acknowledges a "surface water flooding risk to the southern boundaries of the site". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on 11 hectares of land already identified as a flood risk is reckless planning that endangers existing properties downhill, contradicting NPPF Paragraph 170 and failing the current Climate Resilience tests.
3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management)
• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
• Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
• Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.
The Blackfriars Precedent: "Watered Down" Commitments We have no confidence in the "policy compliant" assurances for BT1 because we have seen the Council fail to deliver on similar promises at Blackfriars. That development was sold as a "gold standard" of green, high-tech housing. However, documents show it faced an £8 million funding gap and underwent "redesign" to "better align with market demand" and "improve efficiencies" due to rising costs. If the flagship Blackfriars project had to be value-engineered due to market pressures, the high-quality, landscape-led masterplan promised for BT1 is likely to be similarly watered down once permission is granted.
Conclusion
This proposal expands development to 250 units on a Greenfield National Landscape site amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further.
Yours faithfully,

Re: Concerns regarding the Rother District Council Local Plan Consultation

I am writing to submit my response to the draft Rother Local Plan and share some of the concerns raised with me by constituents, many of which I share. Far too often existing residents are asked to support more housing locally when they are not provided with the infrastructure that should come with it. Their access to public services like GP appointments is already challenging – they reasonably ask why they should welcome developments that will make it worse?

Given that the majority of constituents will have submitted their comments directly to Rother, I will not comment on each and every site which has been brought to my attention. As mentioned, the common concern is that current infrastructure – roads/transport, schools, access to primary healthcare and utilities – is already stretched across the district and cannot accommodate the scale and location of proposed development. Constituents are also concerned about the impact on the environment, flood risks and protection of the High Weald AONB and Pevensey from further development.

Infrastructure must be the starting point of any sustainable planning strategy. At present, residents feel that the proposed allocations are being driven by the Government’s housing targets, rather than a realistic assessment of what the area can safely and responsibly support. On that basis, I have written to the Housing Minister to highlight the challenges for Rother to deliver an unrealistic housing target within the tight constraints of available land given well over 80% is protected by AONB or SSSI status. I am also aware that as our housing targets are raised, the Government is lowering the targets for house building in London because they say they aren’t realistic. They aren’t realistic for our area either. There are specific concerns about the impact on the A259 of proposed housing development in West Bexhill. I share those concerns and I am supportive of any plans for a new road which would alleviate the volume of traffic in Little Common which is already a heavily used route and will be more so if further housing is delivered in this part of the town.

In Sidley, I share the community’s concerns about site BEX50 – Sidley Car Park, which has been identified for a possible 10 homes. Whilst I fully understand the need for quality housing in Sidley, I consider that losing parking spaces in this free car park would be bad for local businesses and would impact the hard work which has been done in recent years by East Sussex ounty Council and All Saints School to create
a road safety scheme. Parents are no longer permitted to drive into Saints Lane at school drop off and pick up times so use Sidley car park. The school also runs ‘walking bus’ from the car park to the school gates.

In addition to concerns raised about infrastructure, the following have also been noted:

1. Sites in Battle – proposed BT7 off North Trade Road would sit on flood zones. General concerns about further development in Battle include worsening of congestion on already heavily-used roads, consideration of ancient and historic woodland, Battle cannot support additional population pressure and traffic – its high street being regularly congested and heavy vehicles causing damage to ancient buildings.

2. North Bexhill (BA3) – overdevelopment of green space without supporting infrastructure.

3. Netherfield (GYP4) temporary sites being granted permanent status sets a precedent that people can purchase plots and commence development without planning permission I look forward to your response to the above concerns and how these will be taken forward in future versions of the Local Plan.