bt7 Primary Grounds for Objection:

Ecological Impact: Proximity to Ancient Woodland and Deciduous Woodland Priority Habitats poses a high risk to biodiversity. Surface water flooding issues further complicate the site's suitability.

Heritage Preservation: The site is dangerously close to the 1066 Battle of Hastings Registered Battlefield and a Grade II listed building. Development risks irreparably damaging the setting of these irreplaceable national assets.

Infrastructure Strain: Significant concerns remain regarding the capacity of the North Trade Road and A2100 roundabout, which require further assessment before any additional traffic is introduced.

Given these environmental, historical, and logistical hurdles, the site's preservation outweighs its suitability for residential expansion.

"Under the Draft Local Plan 2025-2042, specifically Policy HER1, the council must protect the setting of the 1066 Registered Battlefield. This site is not 'Grey Belt'; it is a core component of the historic landscape. Furthermore, NPPF Paragraph 11 (the 'Presumption in Favour of Sustainable Development') is disengaged here because the site affects protected Heritage Assets and Ancient Woodland. Therefore, the district's housing targets do not override the statutory duty to preserve this irreplaceable national site."

BT2

BT4 & BT7
"Under the Draft Local Plan 2025-2042, specifically Policy HER1, the council must protect the setting of the 1066 Registered Battlefield. This site is not 'Grey Belt'; it is a core component of the historic landscape. Furthermore, NPPF Paragraph 11 (the 'Presumption in Favour of Sustainable Development') is disengaged here because the site affects protected Heritage Assets and Ancient Woodland. Therefore, the district's housing targets do not override the statutory duty to preserve this irreplaceable national site."

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

1. Traffic Congestion and Safety on Hastings Road

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

Junction Interference and "Staggered" Conflict

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

The 30mph to 40mph Transition Danger

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

• Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.

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

2. Environmental Impact and Air Quality

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

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

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

3. Infrastructure Deficits and Delivery Failures

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

• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
• Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
• Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.

The Blackfriars Precedent: "Watered Down" Commitments

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

Conclusion

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

Market Square (BT11) - I support the idea of more retail units in the vicinity as the whole area is under-utilised despite it being close to a bus stop, having toilet facilities, good accessibility and adjacent to a car park. The parking however needs to be addressed as many drivers ignore the double-yellow restrictions on Market Road, and there is frequently pavement parking near the kebab shop; perhaps a few bays in the RDC car park can be allocated as "10 minute maximum"?
There is cycle-parking within market square, but it is of poor design and is therefore not used. Suggest that useable racks, e.g. Sheffield stands are installed near to shops, in a high visibility area for security. Green to the core!

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

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

1. Traffic Congestion and Safety on Hastings Road

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

Junction Interference and "Staggered" Conflict

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

The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
• Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.

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

Further, there are no plans to add extra facilities for the increased number of residents. And, as usual there is no consideration for the destruction of green spaces and valuable wildlife habitat. Battle and the surrounding areas are designated as AONB but the ‘outstanding natural beauty’ is being rapidly eroded by the continuous ‘developments’.

I am writing to formally submit my objection to the proposed allocations of site BT10, but also BT1 & BT8. As a resident of Hastings Road, I have daily experience of the site conditions. The BT10 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 3 major junctions to this existing chaos without significant infrastructure upgrades is negligent.

In the case of BT1, it will form a crossroads with the Blackfriars (210+ dwellings) development. Turning movements into BT1 (250 dwellings) will frequently be blocked by "tailback" traffic exiting or entering Blackfriars. 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 planned BT1 site also sits at a critical transition point where the speed limit increases from 30mph to 40mph and close to a blind bend on Hastings Road (A2100). 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.

In the case of BT8 & BT10, the proposed road access will create increased congestion and risk of vehicle collisions on what will effectively be street access with very limited visibility due to the existing housing along Hastings Road (A2100).

Hastings Road (A2100) also has poor existing street lighting which doesn't add to pedestrian or cyclist safety.

2. Environmental Impact and Air Quality

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. In the case of BT10 alone, a density of 30 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 across the 3 sites (BT1, BT8 & BT10) 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 BT10 & BT1 explicitly acknowledges surface water flooding risks to the southern boundaries of both sites. 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. Hastings Road (A2100) already suffers from excess surface water currently. New developments would add to that problem significantly.

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, BT8 & BT10 admits the sites are "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.

Public Transport: The Council's supporting text for BT10 points out there is a bus stop nearby. However, it seems little thought has been given about the frequency of services to or from Battle, Hastings & Bexhill along the Hastings Road (A2100). There is 1 bus service for Hastings & Tunbridge Wells (the 1066) and 1 service to Bexhill (the 95); neither of which are more frequent than on an hourly basis (sometimes less so). The train station is 1.2 miles away from the BT10 proposed site. Due to the narrowness of Hastings Road (A2100), the pavement only runs on one side (the opposite to the proposed BT1, BT8 & BT10 developments) which puts pedestrian safety at risk when trying to cross the road. Also, due to the narrowness of Hastings Road (A2100), there is no room for cycle lanes and cyclists are already at risk from heavy traffic, particularly HGVs.

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

Conclusion

This proposed BT1, BT8 & BT10 expand development to 250+ units on Greenfield National Landscape sites amidst an infrastructure crisis. The plans are unsound as they ignore statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further.

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

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

1. Traffic Congestion and Safety on Hastings Road

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

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

The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
- Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
- Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.

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

2. Environmental Impact and Air Quality

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

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

3. Infrastructure Deficits and Delivery Failures

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

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

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

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

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

1. Traffic Congestion and Safety on Hastings Road

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

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

The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
- Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
- Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.

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

2. Environmental Impact and Air Quality

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

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

3. Infrastructure Deficits and Delivery Failures

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

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

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

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

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


1. Traffic Congestion and Safety on Hastings Road

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

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

The 30mph to 40mph Transition Danger

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

• Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.

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

2. Environmental Impact and Air Quality

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

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

Flooding Risk and Surface Water (NPPF Paragraph 170)

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

3. Infrastructure Deficits and Delivery Failures

Critical Lack of Infrastructure (GP, Dentistry, Schools)

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

• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
• Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
• Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.

The Blackfriars Precedent: "Watered Down" Commitments

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

Conclusion

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

Michele Wigley
Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle)
As previous multiple comments stated from other objections!

Past and future developments given planning permission, should NOT be revised, and NOT to
Exclude affordable housing, or to increase the number of properties planning previously agreed!
(Developer’s are abusing the planning system and making a mockery of the current regulations!)
All future planning applications for the community must include onsite essential services within
Any agreed development, ie school, community hub with activities for events / minor clinics
Or recognised club organisations.

The sites shown will not only have an effect on the already struggling infrastructure of the town, but also, damages the intimacy of a once historic town. There seems to be no thought into how the town will cope with the additional housing when it comes to schools, Dr's and the sheer amount of traffic that we see streaming through on a daily basis. It also feels that some of these developments are purely to line the land owners pockets rather than benefit the town itself, specifically related to BT4. There has been some brutal removal of trees and shrubbery from proposed sites where there once used to be safe cover for wildlife.

I object to the proposed allocations of sites BT10, BT1 & BT8. As a Hastings Road homeowner I have first hand experience of daily conditions. The BT10 development is unsupportable based on material planning considerations. We're a rural town with limited infrastructure to support the current population eg: lack of dentists, GP's. The proposed sites show no care to the environment with the destruction of greenfield land, leading to loss of wildlife and hedgerow. Hastings Road is already heavily congested and dangerous with speeding HGVs and a pavement only on one side. There is no provision or space for a cycle lane and the bus routes are limited (one per hour, sometimes less). There are no suitable crossings for pedestrians and there are many blind corners, particularly where the marked entrances for the sites are. Hastings Road is prone to flooding and building on a flood plain is reckless.

Re: Objection to Proposed Allocation Policy BT1, BT8, BT10 (Land south of Hastings Road, Battle) Draft Rother Local Plan (2025-2042)
Date: 27 February 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.

The Battle NP explicitly refers to the problematic traffic conditions. It states that Battle’s increasing use as a ‘transport corridor’ has ‘generally increased the problems associated with additional transportation within the confines of our historic town, such as illegal parking and congestion. This has not improved the environment for those living, working or shopping along Battle High Street.’

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

One of the proposed exits for the new site is at Glengorse, a once-quiet residential cul-de-sac. Glengorse is affected by increased volume of traffic on the A2100, making entry and exit increasingly difficult. It is also affected by volume of parking and parking restrictions were recently introduced.

The Glengorse exit is within a short distance of the exit at The Spinney from The Tapestry Development (70 dwellings). The traffic and urban sprawl consequences of these developments would be severe.
The proposed development does not meet the Battle NP’s objective to ‘consider the wider implications and associated costs of traffic movements on the environment and local infrastructure with an overall aim of reduction in the impact of traffic movements’.

The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
• Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.
Placing two high-volume junctions in a high-speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that "safe and suitable access to the site can be achieved for all users." Given the topography and speed transition here, this requirement cannot be met.
2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT1 proposes building on 11.09 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
• The Battle NP states that the hamlet of Telham – which would be affected by the encroachment of this development - is ‘enclosed by agricultural land it services a small community and acts as a Green Gap in the fight against urban sprawl.’ The proposed development does not meet the Battle NP’s objective to recognise the separate identities of the areas making up the Parish and to ‘prevent urban sprawl’.
• National Landscape (AONB) Impact: The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 40 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major development should only occur in exceptional circumstances (NPPF Paragraph 189).
• Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 250 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises.
• The land around the Glengorse Estate was once defined as parkland. Although Telham Court, the property which sits on the Glengorse Estate, is proposed to be protected under the development, the land around it will not be protected. The development will create further light pollution.
• Due consideration cannot have been given to the historic nature of the town and surrounding area. Battle NP states that ‘Battle itself is of national and international importance’. Battle town centre is largely medieval and consists of one street, the road through which is typically in a very poor state of disrepair. It already struggles under the volume of traffic, which would be further increased by this development, and vehicles of the nature required for a major development would cause to the historic buildings.

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

The proposed development fails to meet the Battle NP’s objective that ‘To protect and enhance our existing and future open spaces, any new development proposal should conserve and enhance the environment, ecosystem and biodiversity, ensuring that it gives protection to heritage assets, habitats and provides appropriate movement corridors for wildlife.’

3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management)
• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
• Schools: The Council’s own supporting text for BT1 admits the site is "some distance from primary schools" and implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions.
• Transport: The Battle NP states that there is a ‘distinct lack of public transport within the Parish.’ Increasing housing stock without improving public transport is irresponsible, and would only increase reliance upon vehicular traffic. Among the ‘weaknesses’ identified in the Battle NP are traffic congestion, parking difficulties, lack of public transport and highway maintenance.
• Precedent: We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.

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

Previous proposal
The proposed development is situated on land owned by two absentee landowners, who both live abroad, as far as we know. These landowners, who are property developers, previously proposed a development in which Glengorse would form one entrance and Marylands (34 Hastings Road) the other. The Glengorse Estate, which sits behind the housing cul-de-sac, was purchased with the intention of development. The previous proposed development was subject to objection and was rejected on the grounds that it contravened the then-current policy on the strategic gap.

In 2019, the Battle NP’s inclusion of a site at Glengorse (original site ref BA31a) was amended in light of the proposed development at Blackfriars. The Battle NP stated that the likely development of Blackfriars rendered the Glengorse development ‘too large a development in a similar location’.

As the previous rejections proposed development does not meet the Battle NP’s objective that developments ‘should meet the needs and wishes of the community’.

Marylands is presently listed on Rightmove with SJD Tunbridge Wells (a development consultancy) as a development opportunity and is presently under offer. The listing states that the ‘land to the west of the site has recently been allocated so it is considered that this land may offer future potential subject to usual consents’.
[https://www.rightmove.co.uk/properties/166422503#/?channel=COM_BUY]

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.

Objection to proposed allocation policy BT1, BT8, BT10 (land South of HASTINGS Road, Battle)

I right to object to this Proposed policy on the grounds that the site is totally unsuited to this level of development :Primarily because the access to and from the site will feed onto an already congested Road which is not designed to take the level of traffic : Particularly in conjunction with the Blackfriars site which is yet to be opened.There will obviously be an increase in the level of pollution making it an even less attractive walk into the town centre than it already is.Trade in Battle town centre is unlikely to benefit as there is very little parking available.The schools and Doctors Practices serving Battle are already oversubscribed.

I am writing to object to the proposed allocation BT10 in the draft Rother Local Plan. BT10 is a greenfield site that contributes to the character and setting of Battle. Developing this land would result in the permanent loss of countryside, contrary to the Local Plan’s aim of prioritising brownfield development and protecting the High Weald AONB.

The site plays a crucial role in the semi-rural approach into Battle and the wider setting of the historic 1066 battlefield. Development here would erode the town’s distinctive character and diminish the sense of arrival central to Battle’s identity. As a greenfield location, BT10 supports established hedgerows, mature trees, and wildlife habitats. The ecological information provided does not demonstrate that biodiversity can be protected or that meaningful net gain can be achieved. The loss of habitat would be significant and irreversible.

There are also serious concerns regarding highways and access. The surrounding road network already experiences congestion and safety issues at peak times. Additional vehicle movements from this site would worsen these problems, and no robust mitigation strategy has been presented. The site’s topography raises questions about surface water runoff and downstream flood risk. It has not been demonstrated that sustainable drainage can be delivered without increasing risk elsewhere.

Local services—including healthcare, schools, and utilities—are already under pressure. The plan does not provide clear, deliverable commitments to expand capacity in line with the additional demand BT10 would generate. Finally, the Council must show that all reasonable alternatives have been assessed. There are other sites within the district that present fewer environmental and infrastructural constraints. BT10 has not been shown to be the most sustainable or appropriate option.

For these reasons, I believe BT10 is unsound, failing the tests of justification, effectiveness, and consistency with national policy. I respectfully request that it is removed from the Local Plan or fundamentally reassessed.

Thank you for considering my objections.

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).

Proposal for development of Almonry farm BT7

1. Would mean the permanent destruction of one of the more beautiful landscapes in this AONB, one that may well encroach on the site of the Battle of Hastings, the most important battle to take place on British soil.
Both fields are bordered by ancient woodland, one of which, Manser's Shaw, contains part of the Malfosse way, which is of historic importance as part of the Battle of Hastings, (See above) and both slope steeply down to wooded gullies, causing problems for builders, as already experienced at the Lilybank and Blackfriars developments.
2.Would mean the inevitable destruction of plant and wildlife habitat and
3. Cause flooding. Grassland of this type is able to absorb large quantitites of rainwater, but even so after heavy rain the ground is waterlogged. I can provide photographic evidence of this if required.
According to official figures, 40% of English gardens are under paving. This, in addition to the huge concrete footprint of 80 houses, would leave very little space for the absorption of rainwater.

The footpath that runs along the north border of these fields is used daily by, amongst many others, pupils going between Battle town centre and Claverham Community College as a safe alternative to the narrow pavements of the busy North Trade Rd. This path is already flooded in parts for six months of the year; if this development were allowed, the path would be almost permanently impassable.
4. if accepted would inevitably act as a bridgehead for the development of the whole of Almonry farm.
The resulting increase in population would permanently alter the character of this historic town.

5. The proposal envisages access to the North Trade road via Tollgates, a bungalow estate which is already accessed by the newish development next to Claverham way in addition to the existing estate traffic. The NT Rd is already extremely crowded especially twice a day during the school run to the adjacent Claverham College, with considerable pressure on the roundabout at the head of the High St. The High Street is lined with houses of historic interest, many of which are listed. It is narrow and unsuited to heavy traffic and is already frequently congested. Nevertheless, it would be the only practical access these new residents would have to Battle railway station and to Hastings. Adding to the number of cars would invite gridlock.
6. The UK is committed to the Cop 15, 30 by 30 project, which undertakes to conserve and protect 30% of its land by 2030. According to figures from 2025, the UK has managed so far to achieve just 6%. Destroying this beautiful greenfield site would be a backward step.
7. It is deeply ironic that this historic vandalism should be proposed at the time when Battle is preparing for 'The Year of the Norman', with a planned visit from Royalty and the national celebration of our heritage.

Dear Sirs

Re: Objection to Proposed Allocation Policy BT1, BT8, and BT10, Draft Rother Local Plan (2025-2042)

I am writing to object to the proposed allocations of sites BT1, BT8 and BT10. As a resident of Hastings Road I have direct, daily experience of local conditions relating to the proposed sites. These developments are contrary to the democratically adopted Battle Neighbourhood Plan (BNP), 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

All of these developments will increase traffic on a road that is always congested in the mornings and evenings, creating a bottleneck that often stretches back to my house. The A21 floods whenever there is heavy rain. This necessitates traffic being diverted down A2100 as it is the only viable route out of the Hastings area and adds to the existing high levels of traffic. The road cannot take another 580+ cars as a result of these plans to build 290 extra houses. This is on top of the 210 houses already being developed at Blackfriars which will add another 420 cars to the road, as the houses have yet to be sold. This makes a total of potentially 1,000 new cars on the A2100 from the current traffic conditions.

BT1 will involve the construction of a new junction on Hastings Road 200m to the east of Starrs Mead where the Blackfriars traffic will emerge. The Starrs Mead junction is on a bend and also where the speed limit changes from 30 to 40mph. The BT1 second exit will be at Glengorse 200m to the west of Starrs Mead, and also on a bend. The combination of three exits onto the Hastings Road within 400m of each other will dramatically increase the risk of accidents and traffic congestion. The NPPF Para 115 requires that 'safe and suitable access to the site can be achieved for all users', which cannot be achieved here.

2. Environmental Impact

Greenfield sites

All three sites, BT1, BT8, and BT10, are greenfield land. This directly contradicts BNP's vision to prioritise brownfield sites and protect the countryside. These sites are all within the High Weald National Landscape (HWNL) which means that Rother must give 'great weight to conserving and enhancing the natural beauty of the landscape'. The NPPF Para 190 makes this clear. A density of 40 dwellings per hectare is urban, not rural, and completely out of keeping with the HWNL designation.

Drainage

Ordinance Survey Explorer Map 124 shows a stream draining from BT10 into ancient Bushy Wood. This watercourse feeds into Powdermill Stream near the pumping station on Telham Lane. The pond in BT10 also appears to drain into this stream, and it has been noted that there is a surface water flooding risk here. Covering these fields in concrete will increase the rate and volume of water run-off into Powdermill Stream thereby increasing the risk of flooding in this area. Powdermill Lane was recently flooded making it impassable to traffic which use it to bypass Battle High Street. The Loose Farm and Telham areas are currently at a high risk of flooding according to a map produced by Friends of the Earth based on Environment Agency data.

Threatened Habitats

All three proposed sites threaten the fields and paddocks of HWNL where there is a duty on Rother to 'secure agriculturally productive use of fields'. The High Weald Wildflower Meadow Priority Habitat is directly affected by BT1. Wild flower meadows are extremely rare in the UK as most have vanished due to agricultural practices. It is therefore vital that this should not only be preserved but should not have its wildlife corridors severed by the development, as this will degrade its value to the High Weald National Landscape. Hedgerows must also be protected as they provide vital corridors for wild creatures to move from one place to another. Isolated groups of wild life do not have the resilience necessary to survive climate change. It is therefore essential that wild life areas remain interconnected at all times.

3. Infrastructure Impacts

Battle is already suffering from a critical lack of infrastructure. These three sites will provide housing for approximately 1160 people. Added to this are the 840 people who will be living in Blackfriars but have not yet arrived, totaling 2,000 people. Battle would therefore need to provide doctors and dentists for them, and school places for 1,000 new school children. All three proposed sites are too far for primary school children to walk. BT10 is two miles from Battle and its services. This will greatly increase school traffic on the A2100.

Martins Oak Surgery is at full capacity and already seeking larger premises. Battle Health Centre is also very busy.

Battle and Langton School has been at full capacity for a while so new arrivals are already having to go to Netherfield school. When this is full where do the children go?

The dentists do not have space for another 2,000 NHS patients.

For these reasons the proposed sites BT1, BT8 and BT10 are not suitable for development in the High Weald National Landscape and I strongly object to these sites being included in the Rother Local Plan.

Yours faithfully,

Elizabeth Hart

Please see attached for full representation:

- Full representation on Draft Rother District Local Plan 2025-2042 Consultation (including underlined text and hyperlinks that do not appear in text copied out below)
- Supporting document: Southern Water input to Rother District Council’s 2026 IDP review
- Supporting document: IDP feedback provided for the Regulation 18 consultation deadline 23rd July 2024

Q5 We attach our separate IDP response to Rother as part of our feedback to this Regulation 18 consultation on the Local Plan, requesting update of the IDP in accord with the information and explanations provided. This also includes our feedback from the previous 2024 Regulation 18 consultation, in addition to a full explanation of how Southern Water plans investment for adopted local plans. Included within this explanation are our key AMP8 (2025-2030) investment plans for the Rother district. Some plans extend into AMP9, but for the reasons we explain in our IDP response, most AMP9 schemes are not known at this time.

There is considerable investment planned for the district in this 2025-2030 AMP8 period, supported by a range of technical disciplines. This represents the latest investment information and therefore supersedes the DWMP content referred to (as this DWMP work was concluded in 2023).

Q8 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q9 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q10 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

Q17 Q17 - all BX sites.

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording to all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to critical assets running beneath sites.”

Southern Water’s initial checks indicate that a number of the new/changed sites (BX6, BX7, BX22, 23, 24, 27, 28, BX31, 34, 36, 37, 38, 39 and BX41) may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and all those we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site BX9 and may require easements or diversion. For this site, and any we’ve previously requested layout wording please include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Q19 For development to be sustainable, Southern Water believes that it must always deliver sustainable drainage. This will be particularly important in areas where higher housing densities are proposed.

Communities need planning policy to go further as climate change now demands we re-think and re-design communities. More resilient and efficient homes are essential – conserving both energy and water. However, we also need to ensure that housing design/delivery will not mean that rainwater continues to run off surfaces so fast that it causes flooding and storm discharges into rivers and seas. By controlling the rate and volume of surface water entering the combined sewer network, sustainable urban drainage systems (SuDS) can improve existing flood risk and water quality.

We need planning policy to encourage proactive, cross-sector collaboration, as well as requiring all development to adhere to the principles of integrated water management in line with the National Standards for Sustainable Drainage (June 2025).

The complexities and challenges of drainage need a collaborative approach between the responsible organisations, such as Local Authorities, Southern Water, the Environment Agency and community groups to adapt the urban environment to be more resilient to our changing weather patterns. Together, we need to separate rainwater from wastewater.

26 CR1 to CR3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

However, we note that for site CR2 in particular, there is no wording in the site allocation policy to address the site’s proximity to an operational wastewater treatment works. In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to site CR2 is within 500m of Battle wastewater treatment works and we therefore request the additional wording –
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

28 GU1 & GU2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for site GU2 at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –

“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Southern Water infrastructure crosses GU2 and may require easements or diversion.”

30 GU4 & 5

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –

“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site GU5 and may require easements or diversion. For GU5, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

31 GU6

Southern Water has identified no constraints for this site at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

32 IK1&2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site IK1 and may require easements or diversion. For IK1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

34 WS1 WS2, WS3 WS4 WS5

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water’s initial checks indicate that sites WS2 and WS3 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site WS3 and may require easements or diversion. For WS3, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

36 BT1 to BT11 (BT3, BT4, BT5, BT6)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to this site is within 500m of Battle wastewater treatment works and we therefore request the additional wording – The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.

Southern Water’s initial checks indicate that sites BT1, BT2, BT7, BT9, BT10 and BT11 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Also, Southern Water infrastructure crosses site BT11 and may require easements or diversion. For BT11, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

38 CT1 CT2 CT3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure may cross sites CT2 and CT3 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

39 NE1 & 2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

40 SD10 SD11 (SD1 to SD9)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to site SD11 (and as previously advised the for the existing site allocation SD7) is within 500m of Sedlescombe wastewater treatment works and we therefore request the following additional wording in these policies–
The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.

42 BC1 (BC2) BC3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site BC3 and may require easements or diversion. For BC3, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

43 (BR1) BR2 BR3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

44 CM1 to CM3

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

45 (ID1) ID2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site ID2 and may require easements or diversion. For ID2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

46 NR1 and NR2

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for this site (NR2) at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

Additional policy wording is needed for each site to address it’s proximity to operational wastewater treatment works. The proposed boundary of each site is within 500m of an operational wastewater treatment works (Mill Corner Northiam WTW, and Quickbourne Lane Northiam WTW) and we therefore request the additional wording for each site policy –
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Also, Southern Water infrastructure crosses site NR2 and may require easements or diversion. For NR2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

47 PE1, 2 & 3 (PE4 & PE5)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

49 (RY1 to RY1, RY7&8) RY5, RY6 & RY9

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water’s initial checks indicate that sites RY5 and RY9 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For these sites, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Southern Water infrastructure crosses sites RY5, RY6 and RY9 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

50 RH1

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

53 BW1 to 4

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water’s initial checks indicate that site BW1 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For this site, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:

Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Please note that Southern Water wastewater sewers cross all BW sites (BW1 to 4) and may require easements or diversion (so please note that whilst we agree that consultation with Southern Water will be required, it may not be necessary for the developer to deliver a package treatment plant as currently stated in part Xi of the policy. Were the developer to want to deliver such plant they will first need to consult with the Environment Agency). For these sites, and any we’ve previously requested layout wording please also include the following wording:
Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

54 BWC1 and 2

Southern Water has identified no constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

55 EC1 to 3

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site EC1 and may require easements or diversion. For EC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

56 (HG1&2) HG3 & 4

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water’s initial checks indicate that site HG4 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy. For this site, and any we’ve previously requested phasing wording (unless the detailed planning consultation responses we’ve provided indicate otherwise) please include the following wording:
Occupation of development will be phased to align with the delivery of sewerage infrastructure, in consultation with the service provider.

Southern Water infrastructure crosses site HG3 and may require easements or diversion. For HG3, and any sites we’ve previously requested layout wording please also include the following wording:
Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

57 RB1, RB3, RB4 (RB2, RB5) to RB6a & RB6b

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundary to sites R3 and R4 (and also as will have been previously advised the boundary to existing site allocation RB2) are all within 500m of Robertsbridge wastewater treatment works and we therefore request the following additional wording for these policies–
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Also, Southern Water infrastructure crosses sites RB3, and RB5 and may require easements or diversion. For these sites, and any we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

58 SC1 & 2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.

Southern Water infrastructure crosses site SC1 and may require easements or diversion. For SC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

59 FW1 to FW3

Southern Water’s initial checks indicate that site FW2 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water infrastructure crosses site FW2 and may require easements or diversion. For FW2, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

60 TC1 (or 2)

Please note that as we have already consulted on all existing allocated sites (in adding to offering LPA free consultations at planning application stage) we comment in this response on new/changed site allocation policies, where the site has not previously been allocated and planning applications have not yet been submitted.

Southern Water’s initial checks indicate that site TC1 may have limited local network capacity, and phasing of development may therefore be needed alongside network reinforcement prior to occupation of the total number of dwellings indicated in each policy.

In addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more detailed checks made closer to the timeline of expected development, Southern Water request the addition of the following wording for all sites –
“We also encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.”

Southern Water infrastructure also crosses site TC1 and may require easements or diversion. For TC1, and any sites we’ve previously requested layout wording please also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

62 SG1 or 2

Southern Water has identified no potential capacity constraints for these sites at this Local Plan stage. For completeness, in addition to Rother consulting us on planning applications (for which we are not statutory consultees) so that we can share the results of more checks made closer to the timeline of expected development, Southern Water request the addition of the following wording –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

The proposed boundaries to each site are within 500m of Stonegate wastewater treatment works and we therefore request the following additional wording for these policies–
“The layout of development for any site allocation with 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Southern Water infrastructure crosses these sites and may require easements or diversion. For these sites please therefore also include the following wording: Layout of the development must be planned to ensure future access to existing sewerage infrastructure for maintenance and upsizing purposes.

Q64 GYP1 to GYP6

Southern Water’s initial checks indicate that some of the GYP sites are proposed within 500m of operational wastewater treatment works. For example, the boundary to site GYP6 is within 500m of Robertsbridge WTW.

We therefore request Rother consult us on planning applications for all sites so that we can share the results of more detailed checks with the authority. Southern Water also request the addition of the following wording for all sites –
“We encourage early engagement by developers who can make use of Southern Water’s pre-planning service here – https://www.southernwater.co.uk/building-and-developing/planning-your-development/pre-planning-enquiries/.
Early engagement will be particularly important for the larger site proposals, or where constraints are indicated due to the close proximity to operational wastewater treatment works or where there are critical assets running beneath sites.”

And for each site proposed within 500m of operational wastewater treatment works (eg GYP6) please include the following additional wording;
“The layout of ‘sensitive residences’ for any site allocation within 500m of an operational wastewater treatment works should be informed by an odour assessment to be undertaken in consultation with statutory wastewater operator for the works.”

Q69 Any other issues or comments?

All site allocations should be proposed in locations where utilities can provide for the forecasted needs of the development without prejudicing existing or future utility provision necessary to support growth. Southern Water therefore requests the following additional policy wording in the Regulation 19 draft of the Local Plan:
The utility network should be protected and development proposals that would compromise existing utilities infrastructure, or encroach on future connections for utilities, will be refused. Opportunities should be sought to safeguard the provision of utilities wherever possible.

To Whom it may concern

We would like to raise our objection to the development of the Greenfield site in Battle.

We live on the Hastings Road and are already impacted by the amount of traffic. The noise and pollution it creates. The High Street is also a bottle neck and very polluted.

We think there has been enough building in Battle the Doctors Dentists and Schools are already under pressure. When the Blackfriars Estate was built Battle was promised a new School and Doctors but this has never happened. It was also supposed to be Eco but is not.

The Blackfriars Estate has already had a problem with flooding and now you want to build on more land which absorbs rain preventing houses being flooded wich back onto the site.

Environmentally another piece of land is disappearing with habitat loss. Nature is really up against it and yet again that doesn't seem to be a priority.

This goes against the Battle plan and we strongly object.


Regards

Elizabeth McCutcheon
Ian McCutcheon

Re BT7
I am worried that our very old house is at risk from the potential build on the field opposite. We have 3 chimneys, one of which is very old and very tall and the house has no foundations at all. I am concerned that the frequent passage of heavy traffic close to our property may destabilise it. We have a cellar that flooded regularly, but is now controlled with a pump. The water discharges into the field where building is proposed and this could affect water run off from our property.

This is in relation to BT7
The land covers a wide area of prime farmland and contains ancient hedgerows. It is also within an area that is part of the national landscape, is within proximity to ancient woodlands and sites of historical significance. The land is a natural habitat for trees, wildflowers and animals and is quite precious to us and those we share it with. Any development within this area would threaten this and be negative to the environment and to the feel of our neighbourhood. By its own assessment, the HELAA document and the plan details recognises this, and further shows us that any plans should be rejected.
It is a fact that further development will put a heavy burden on our current infrastructure. The surrounding roads are often congested, and extra demands placed by large numbers of extra vehicles will place further strain on our already suffering roads. We have heavy school traffic and constant through traffic that already significantly impacts us. Residents are also hugely concerned about the additional pollution from vehicles this will bring along with the additional congestion and extra traffic. Residents report that pollution is already becoming a health concern.
Access to the development area is unclear from the proposals however, it is likely that access will impinge on resident’s properties whose quality of life will be negatively affected
Battle is not served well with public transport. We have 2 main bus routes through Battle with infrequent services. We have a train station approximately 1.5 miles away and no local safe cycle routes, leaning on a demographic that will need cars within the household to function and gain access to the basics placing further demand.
Battle is a small town with services that are already under pressure to deliver a quality of life to residents. I am concerned about local services such as dentists, doctors and other health services being overburdened as there are no plans increase services within the town. We also have limited shops, supermarkets and local amenities in the town.
Our town has local service provisions that have been reduced and are under pressure, such as police, ambulance and Fire, so when considering the safety and wellbeing of our residents and the pressures of public services, I am concerned, especially when considering crime or antisocial behaviour. I am also concerned about pressures placed on local schools, sports facilities, vital services and provisions.
When considering the site impact assessment within the document, I also see that this proposal is a bad choice for development. The plan already recognises the risk of flooding and adverse effects of water runoff. The many references to the land’s historical significance and its environmental significance puts a huge emphasis on rejecting any development on this site. It is disappointing that development is justified by a previous development that pushed the boundaries into our national landscape.
This proposal also does not seem in keeping with RDC’s emphasis on being "green to the core". I am unclear how the developers and planners guarantee this requirement will be met Given that the land in question is Grade A farming land and never touched by development of any sort. How can any planning or development not only put back the same level of biodiversity let alone deliver 10% more than was there prior to building 80 homes, bringing in numerous new residents, numerous vehicles, and the additional infrastructure required including sewage, water, electricity and gas supplies, new roads and access points?
I am also unclear about supply of fresh water, foul water and sewage removal which are already under stress, or with the improvement of utilities to the area with extra capacity to deal with the demand.
If development were to go ahead, I am also concerned about the noise and dust created by development that would affect health and wellbeing. A number of residents with health conditions are very anxious about this and are of great concern.
A recent proposal (site) on the adjacent Almonry fields in the previous Draft local plan was rejected. this development had similar specifics on the site. Therefore if the previous plan faced rejection, so should this as it is just moving the issue around.
The description also stated resident led development. I have seen no evidence of additional infrastructure or improvements to local and public services, amenities or land set aside for play or recreation.

Whilst the need for sites to allow controlled expansion is accepted, I cannot see on any of the proposals how the local infrastructure, roads (in particular the high street),parking, schools and doctors surgeries are to be protected/enhanced to accommodate such growth.

Can the Council please explain how the above is to be controlled and protected, the current infrastructure is at breaking point and could not accommodate such growth. The local community also needs assurances that any conditionality placed on developers for approvals will be enforced. On recent developments like Blackfriars we have seen material changes and slippage from the sensible conditions implemented as part of the original approval....how will this be prevented from happening again? Developers will no doubt take advantage once they are in place and started work so this should be expected and planned for with robust conditions from the start and that developers are held to them.

PLANNING APPLICATION - OBJECTION TO THE PROPOSED ALLOCATION POLICY BT1, BT8 and BT10 (Land South of Battle adjoining the Hastings Road, A2100) DRAFT ROTHER LOCAL PLAN 2025-2042

Dear Councillors

I WISH TO OBJECT TO THIS PROPOSED HOUSING DEVELOPMENT ON THE HASTINGS ROAD (A2100)

I list the criteria for my objection as follows:

1) TRAFFIC CONGESTION ON THE HASTINGS ROAD (A2100) The objective from the previous Planning policy, Battle Neighbourhood Plan (BNP) "To require that Transport Assessments are undertaken for all development proposals within the Civil Parish in order to consider the wider implications and associated costs of traffic movements on the environment and local infrastructure with an overall aim of reduction in the impact of traffic movements and improvements for sustainable travel modes."

This objective is further detailed in Policy 7.2 Ambition 1 - "Battle and the hamlet of Telham: To reduce road traffic congestion both local and through traffic, especially at peak times"

THIS PROPOSAL FAILS TO COMPLY. THE HASTINGS ROAD IS A HEAVILY USED, OFTEN CONGESTED AND POLLUTING ROUTE INTO AND OUT OF BATTLE. NO ADDITIONAL DEVELOPMENT WHICH CONTRIBUTES TO THIS USAGE SHOULD BE AGREED TO.

2) THE HASTINGS ROAD (A2100) IS NOT SUITABLE FOR ANY INCREASE IN USAGE. It suffers from speeding traffic outside of the peak congestion Periods with vehicles and motorcyclists repeatedly exceeding the 40 mph limit. There are numerous accidents along this stretch of road.

3) ANY DEVELOPMENTS SHOULD MEET THE NEEDS AND WISHES OF THE COMMUNITY. The statement in the previous BNP "Development objectives must reflect the wishes of the community as evidenced from survey results and demonstrable needs identified through forums and exhibitions together with comments received through letters, emails, monthly articles in the local newspaper and Battle Town Council newsletter and meetings with various stakeholders within the Parish of Battle." These planned development sites are not welcomed by the local community.

4) The Protection of Open Spaces and the Countryside: The previous BNP started "Plans must restrict the use of land for development which is primarily already outside of the development boundaries and has been designated as AONB. In addition, information that has been gathered by the Group on a number of identifiable green spaces which have yet to be afforded protected status, but would be lost for the purposes of sport, leisure and agricultural uses if policy decisions were to change within the RDC Strategic Aims, must also be given that protection. To protect and enhance our existing and future open spaces, any new development proposal should conserve and enhance the environment, ecosystem and biodiversity, ensuring that it gives protection to heritage assets, habitats and provides appropriate movement corridors for wildlife."

THIS PROPOSAL CHANGES THE USE, AND DESTROYS, OPEN AGRICULTURAL LAND. This High Weald AONB land "MUST BE GIVEN PROTECTION" from unwanted development in accordance with the primary objectives of the previous BCPNP.

5) THE LOCAL INFRASTRUCTURE IS NOT ABLE TO ACCOMMODATE FURTHER INCREASES

Battle town currently has a facility deficit. Schooling, Policing, Medical, Dentistry facilities are unable to accommodate further increases in demand.

CONCLUSION

This proposal is not compliant with environmental commitments, ignores local opposition, and notable increases the risk of serious accidents along an already heavily used and accident prone stretch of the Hastings Road (A2100) I urge the Council to reconsider their proposals.

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

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

1. Traffic Congestion and Safety on Hastings Road

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

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

The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
- Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
- Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.

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

2. Environmental Impact and Air Quality

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

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

3. Infrastructure Deficits and Delivery Failures

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

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

Conclusion

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

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

Having lived near Hastings Road for many years, I have seen lots of changes and confirm that this area around Battle is now totally swamped with traffic which has resulted in some nasty accidents. The infrastructure is broken. The hospitals, GP Surgeries and schools are full and this area cannot accommodate any more housing.

I list below my formal reasons for objecting to the Plan:-

1. Traffic Congestion on Hastings Road (A2100). As mentioned above this road is already at breaking point. The heavy traffic queues evening morning and evening. The new Plan would create a bottleneck generated by the minimum of 250 new houses with entrances close together. The Battle Neighbourhood Plan (BNP) explicitly outlines traffic congestion as a critical weakness of the parish. Adding another major junction is madness. Vehicles are prone to exceeding the 30mph and 40mph speed limits.

2. Air Quality and Environment. The Plan would harm the AONB and Greenfield land The Plan directly contradicts the Battle NP’s vision to prioritise brownfield sites and protect the countryside. A density of 40 houses per hectare is urban not rural and quite out of keeping. The constructions of a minimum of 250 homes will sever wildlife corridors and destroy the landscape irrespective of “buffer zone” promises. There is also an issue regarding the risk of flooding etc. Look at what happened with the Blackfriars development. No doubt those houses will have issues in the future as some have been built on a natural spring! BT1 is a known flooding risk.

3. Infrastructure. As mentioned above, there is a lack of infrastructure (the Conquest Hospital is bursting at the seams; GP Surgeries and Schools here are full). Battle used to have a Cottage Hospital. Ideally this needs to be reinstated. Again, the Blackfriars Development was approved with promises of infrastructure with no action. As we have seen before promises will be watered down if permission is granted.

Conclusion
This proposal is not compliant with environmental commitments and does not take into consideration local opposition or indeed the serious risk of accidents along the already heavily used and accident-prone stretch of Hastings Road (A2100).

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

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

1. Traffic Congestion and Safety on Hastings Road

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

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

The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
- Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
- Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.

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

2. Environmental Impact and Air Quality

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

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

3. Infrastructure Deficits and Delivery Failures

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

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

Conclusion

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

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

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

1. Traffic Congestion and Safety on Hastings Road

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

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

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

2. Environmental Impact and Air Quality

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

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

3. Infrastructure Deficits and Delivery Failures

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

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

Conclusion

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

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.