Dear Planning Policy Team,
Re: Draft Rother Local Plan (2025–2042) – Regulation 18 Consultation
Policy BT7 – Land at Almonry Farm, Battle
I write to formally object to the proposed allocation of Land at Almonry Farm (Policy BT7) for residential development of approximately 80 dwellings.
In my view, this allocation fails the tests of soundness set out in the National Planning Policy Framework (NPPF). It is not justified, not effective, and is not consistent with national policy relating to protected landscapes, heritage assets, biodiversity and infrastructure.
Impact on the High Weald National Landscape
The site lies wholly within the High Weald National Landscape. Under Section 85 of the Countryside and Rights of Way Act 2000, the Council has a statutory duty to conserve and enhance the natural beauty of this nationally protected landscape.
The site comprises undeveloped greenfield land forming part of an intact historic field system defined by mature hedgerows and trees — characteristic features of the High Weald. The proposed suburban development at approximately 35 dwellings per hectare would introduce urban form into a sensitive rural landscape, resulting in permanent harm.
The allocation does not demonstrate exceptional circumstances or overriding public interest sufficient to justify development within this protected landscape.
Heritage Significance and Setting
The site lies in close proximity to nationally significant heritage assets, including:
• The Registered Battlefield (1066 Battle of Hastings)
• Battle Abbey Gatehouse Scheduled Monument
• Battle Conservation Area
• Grade II listed Lower Almonry Farmhouse
The land forms part of the historic agricultural setting associated with Battle Abbey and contributes to the wider battlefield landscape. Even where development does not directly affect designated assets, the NPPF requires great weight to be given to the conservation of their setting.
There is also recognised archaeological potential in this area, with local historical evidence suggesting nearby Manser’s Shaw may correspond to the “Malfosse” episode of the 1066 battle. Allocation at this stage, prior to comprehensive archaeological assessment, is premature.
Development would suburbanise part of the Abbey’s wider landscape context and erode the rural character that contributes to the significance of these nationally important assets.
Ancient Woodland and Biodiversity
Ancient Woodland and Priority Habitat lie immediately adjacent to the eastern boundary of the site.
While a 15-metre buffer is proposed, national guidance often recommends greater separation to prevent long-term degradation caused by light spill, recreational pressure, domestic pets and hydrological change.
The site supports wildlife including deer, bats and other protected species. The cumulative ecological impact of development in this sensitive location has not been adequately demonstrated at plan-making stage.
The allocation therefore risks conflict with national policy requiring protection of irreplaceable habitats and delivery of genuine biodiversity net gain.
Surface Water and Flood Risk
The supporting text acknowledges that parts of the site are at risk of surface water flooding. Development of greenfield land increases hard surfacing and run-off, potentially exacerbating flood risk to neighbouring properties and downstream systems.
The Local Plan should not allocate sites where flood risk mitigation remains uncertain.
Highway Safety and Infrastructure Capacity
Vehicular access is proposed via Tollgates, with impacts on North Trade Road and the A2100. The Plan itself acknowledges that further junction capacity assessments are required.
Given existing congestion and the proximity to Claverham Community College, there are legitimate concerns regarding pedestrian safety and traffic conflict. Allocation prior to confirmed modelling and mitigation measures renders the proposal unjustified and potentially ineffective.
In addition, Battle’s healthcare provision, school capacity and local services are already under pressure. The allocation does not secure clear, deliverable infrastructure improvements aligned with the scale of growth proposed.
Cumulative and Precedent Effects
Almonry Farm currently contributes to the rural character of the southern edge of Battle. Allocation of this parcel risks incremental erosion of the wider landscape and may create pressure for further development across remaining farmland.
The cumulative impact of multiple allocations around Battle must be properly assessed to avoid gradual suburbanisation of a town of exceptional historic importance.
Conclusion
For the reasons outlined above, Policy BT7 is not justified by robust evidence, fails to give appropriate weight to nationally protected landscape and heritage assets, and does not adequately address infrastructure and environmental constraints.
I respectfully request that Policy BT7 – Land at Almonry Farm – be removed from the next iteration of the Draft Local Plan.
Yours faithfully,
Mr David Wadeson

In my view, this allocation fails the tests of soundness set out in the National Planning Policy Framework (NPPF). It is not justified, not effective, and is not consistent with national policy relating to protected landscapes, heritage assets, biodiversity and infrastructure.
Impact on the High Weald National Landscape
The site lies wholly within the High Weald National Landscape. Under Section 85 of the Countryside and Rights of Way Act 2000, the Council has a statutory duty to conserve and enhance the natural beauty of this nationally protected landscape.
The site comprises undeveloped greenfield land forming part of an intact historic field system defined by mature hedgerows and trees — characteristic features of the High Weald. The proposed suburban development at approximately 35 dwellings per hectare would introduce urban form into a sensitive rural landscape, resulting in permanent harm.
The allocation does not demonstrate exceptional circumstances or overriding public interest sufficient to justify development within this protected landscape.
Heritage Significance and Setting
The site lies in close proximity to nationally significant heritage assets, including:
• The Registered Battlefield (1066 Battle of Hastings)
• Battle Abbey Gatehouse Scheduled Monument
• Battle Conservation Area
• Grade II listed Lower Almonry Farmhouse
The land forms part of the historic agricultural setting associated with Battle Abbey and contributes to the wider battlefield landscape. Even where development does not directly affect designated assets, the NPPF requires great weight to be given to the conservation of their setting.
There is also recognised archaeological potential in this area, with local historical evidence suggesting nearby Manser’s Shaw may correspond to the “Malfosse” episode of the 1066 battle. Allocation at this stage, prior to comprehensive archaeological assessment, is premature.
Development would suburbanise part of the Abbey’s wider landscape context and erode the rural character that contributes to the significance of these nationally important assets.
Ancient Woodland and Biodiversity
Ancient Woodland and Priority Habitat lie immediately adjacent to the eastern boundary of the site.
While a 15-metre buffer is proposed, national guidance often recommends greater separation to prevent long-term degradation caused by light spill, recreational pressure, domestic pets and hydrological change.
The site supports wildlife including deer, bats and other protected species. The cumulative ecological impact of development in this sensitive location has not been adequately demonstrated at plan-making stage.
The allocation therefore risks conflict with national policy requiring protection of irreplaceable habitats and delivery of genuine biodiversity net gain.
Surface Water and Flood Risk
The supporting text acknowledges that parts of the site are at risk of surface water flooding. Development of greenfield land increases hard surfacing and run-off, potentially exacerbating flood risk to neighbouring properties and downstream systems.
The Local Plan should not allocate sites where flood risk mitigation remains uncertain.
Highway Safety and Infrastructure Capacity
Vehicular access is proposed via Tollgates, with impacts on North Trade Road and the A2100. The Plan itself acknowledges that further junction capacity assessments are required.
Given existing congestion and the proximity to Claverham Community College, there are legitimate concerns regarding pedestrian safety and traffic conflict. Allocation prior to confirmed modelling and mitigation measures renders the proposal unjustified and potentially ineffective.
In addition, Battle’s healthcare provision, school capacity and local services are already under pressure. The allocation does not secure clear, deliverable infrastructure improvements aligned with the scale of growth proposed.
Cumulative and Precedent Effects
Almonry Farm currently contributes to the rural character of the southern edge of Battle. Allocation of this parcel risks incremental erosion of the wider landscape and may create pressure for further development across remaining farmland.
The cumulative impact of multiple allocations around Battle must be properly assessed to avoid gradual suburbanisation of a town of exceptional historic importance.
Conclusion
For the reasons outlined above, Policy BT7 is not justified by robust evidence, fails to give appropriate weight to nationally protected landscape and heritage assets, and does not adequately address infrastructure and environmental constraints.
I respectfully request that Policy BT7 – Land at Almonry Farm – be removed from the next iteration of the Draft Local Plan.

I am writing to formally object to the proposed allocation of Site BT10. This allocation raises serious concerns regarding highway safety, access suitability, traffic impact, landscape harm, infrastructure capacity, and overall sustainability.

1. Highway Safety and Traffic Impact

Hastings Road (A2100) already experiences regular congestion, particularly during morning and evening peak periods, creating a bottleneck that cannot safely accommodate additional vehicle movements generated by new development.

The proposed access arrangements for BT10 would introduce additional turning movements onto a busy stretch of road where traffic conditions are already constrained. The nearby transition between the 30mph and 40mph speed limits creates further hazards, with outbound traffic accelerating and inbound traffic decelerating in the vicinity of the proposed junction.

Introducing additional vehicle movements in these conditions increases the risk of rear-end and turning collisions and has not been demonstrated to provide safe and suitable access, contrary to National Planning Policy Framework (NPPF) Paragraphs 111 and 115.

2. Access Suitability and Emergency Access

The site proposes access via a narrow existing lane that is unsuitable for the level of traffic that would be generated by residential development. The lane has several significant limitations:

It is effectively single-track in places, with limited opportunities for vehicles to pass.

Visibility at the junction between the lane and Hastings Road is restricted.

The lane is shared by pedestrians, horse riders, and existing vehicles.

It also provides the route used for access to Cedarwood Care Home.

Intensifying the use of this route would increase the likelihood of vehicle conflict, create safety risks for vulnerable users, and potentially delay emergency access. This fails to provide a safe and suitable access arrangement in accordance with NPPF Paragraph 115 and Rother Core Strategy Policy TR3.

3. Impact on the High Weald National Landscape and Greenfield Loss

The site lies within the High Weald National Landscape. Under Section 85 of the Countryside and Rights of Way Act 2000 and NPPF Paragraph 176, great weight must be given to conserving and enhancing the landscape and scenic beauty of these areas.

Development at BT10 would result in the loss of greenfield land and would introduce suburban housing density into a rural landscape setting that contributes to the character of the High Weald. This risks eroding the landscape character, tranquillity, and historic field patterns that define the area.

Hedgerows and ecological corridors that contribute to local biodiversity could also be disrupted by development and associated access works.

4. Infrastructure Capacity

Battle’s infrastructure is already under considerable pressure, and the additional population generated by development at BT10 would increase demand on local services.

Healthcare provision is already strained, with well-documented difficulties accessing NHS dentistry across East Sussex and increasing pressure on GP services. Educational provision and other community infrastructure are also limited, and the plan does not clearly demonstrate how these pressures would be addressed in a timely manner.

5. Unsustainable Location

The location of BT10 is not well suited to sustainable development.

Residents would be highly dependent on private vehicles to access employment, schools, and services. Public transport options are limited, and pedestrian and cycling connections to the town centre and key facilities are constrained by distance, road conditions, and safety concerns.

This conflicts with the principles of sustainable development set out in NPPF Paragraph 105 and with Core Strategy Policies OSS1 and OSS4, which aim to focus growth in accessible and sustainable locations.

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.

I wish to register my objection to the proposed housing allocation in Battle. BT1,BT8, BT10.

The land around Maryland was previously submitted for development. It was turned down due to objections from ESCC because the road from the houses comes out close to Blackfriars and was considered too dangerous. The only thing that has changed is that this is plans for many more houses so even more reason for ESCC to object.

The Council is ignoring the fact that the development sits within the ANOB for the High Weald and the Battle Neighbourhood plan suggested 15 homes not 250.

Paula Foord

Subject: Objection to Proposed Site Allocation BT10 – Draft Rother Local Plan 2025–2042

Dear Sir/Madam,

I write to formally object to the proposed allocation of Site BT10 for residential development
within the Draft Rother Local Plan 2025–2042 Development Strategy and Site Allocations
document.

The proposed allocation of approximately 25 dwellings at this location raises significant
concerns in relation to highway safety, landscape impact, loss of green space, infrastructure
pressure and harm to neighboring residential amenity.

1. Highway Safety and Access

The proposed site would require access onto a road with a 40mph speed limit. The creation
of a new junction serving a residential development on a road of this nature raises significant
concerns regarding highway safety.

Introducing additional turning movements, slowing vehicles and residential traffic accessing
the development could create conflict points with fast-moving traffic. This increases the risk
of collisions and may pose dangers to both motorists and pedestrians.

This issue appears inconsistent with the principles of safe and suitable access required by
national planning policy, including the need for developments to provide safe and
appropriate access arrangements.

2. Impact on the High Weald National Landscape (AONB)

Battle and the surrounding countryside are entirely located within the High Weald National
Landscape. The landscape is nationally designated for its natural beauty and historic
character.

The draft Local Plan itself recognises that Battle sits in a visually exposed ridge-top
landscape within the High Weald National Landscape and that growth is constrained by
these environmental sensitivities.

Development of currently open land would urbanise a rural landscape that contributes to the
character and setting of Battle. The introduction of housing, roads, lighting and associated
infrastructure would harm the rural character and tranquillity of the landscape.

National planning policy gives great weight to conserving and enhancing landscape and
scenic beauty in designated landscapes such as National Landscapes (formerly AONBs).
Allocating additional greenfield development within this sensitive landscape risks
undermining this national policy objective.

3. Loss of Green Space and Countryside

The site currently forms part of the open countryside which contributes positively to the
character of the area and provides an important green buffer within the landscape.

Development of this land would result in the permanent loss of green space and contribute
to the gradual erosion of countryside surrounding Battle. Incremental development of
greenfield land can cumulatively damage the character of rural settlements and lead to
suburbanisation of the countryside.

The protection of countryside and landscape character should remain a key priority when
considering site allocations within the Local Plan.

4. Pressure on Local Infrastructure and Services

Battle is a historic town with existing infrastructure constraints. Additional residential
development will place further pressure on local roads, schools, healthcare services and
other community facilities.

The draft Local Plan itself acknowledges that accessibility and infrastructure limitations
constrain growth within Battle. Allocating additional housing sites without clear evidence
that infrastructure improvements will accompany development risks creating unsustainable
development patterns.

5. Loss of Privacy and Harm to Residential Amenity

Development on this site has the potential to overlook neighbouring properties, particularly
where existing homes currently enjoy open outlooks across the site.

The construction of new dwellings overlooking neighbouring properties could significantly
reduce privacy and residential amenity for existing residents. Such impacts should be
carefully considered when allocating sites for housing within close proximity to established
residential areas.

6. Overall Suitability of the Site

Given the combination of constraints affecting this location – including its position within the
High Weald National Landscape, highway safety concerns, infrastructure limitations and
impacts on neighbouring amenity – the suitability of Site BT10 for residential development is
highly questionable.

7. Flood Risk and Surface Water Flooding

The Council’s own evidence identifies flood risk as a constraint affecting Site BT10 (Land
adjoining Little Brans). Within the Interim Sustainability Appraisal (January 2026), the site is
scored “–” (significant adverse effect) against Sustainability Appraisal indicator SA5b
(surface water flood risk). This classification indicates that the site contains land identified
as being at high surface water flood risk, defined within the appraisal methodology as areas
with a greater than 3.3% annual probability of flooding from surface water runoff.

This finding is concerning because surface water flooding typically results from intense
rainfall events, overland flow routes, and drainage exceedance, and such risks are likely to
increase with climate change. Development on land affected by surface water flooding can
interrupt natural drainage patterns and increase runoff, potentially exacerbating flood risk
both within the site and in surrounding areas.

Given the increasing importance of climate resilience and the requirements of national
planning policy to direct development away from areas at risk of flooding where reasonably
possible, the identification of high surface water flood risk within Site BT10 raises serious
questions about the suitability of the site for residential development. The Sustainability
Appraisal itself therefore highlights a clear environmental constraint that should be given
significant weight when considering the allocation of this site within the Local Plan.

Conclusion

For the reasons set out above, the proposed allocation of Site BT10 for residential
development is not considered appropriate or sustainable.

The development would introduce highway safety concerns, harm the character and
appearance of the High Weald National Landscape, result in the loss of valuable green
space, increase pressure on already constrained local infrastructure and negatively affect
the amenity of neighbouring residents.

I therefore respectfully request that Rother District Council reconsider the allocation of Site
BT10 and remove the site from the Draft Rother Local Plan.

To all it concerns, I would like to briefly point out why myself , my family and friends object in the strongest capacity to this proposal.

Firstly there are numerous places in the Rother area which are more suitable to build on, without obliterating this haven for wildlife and beauty, and why cause such environmental harm when it is not necessary? Why suburbanise part of one of Britain's most important historic landscapes?

We not not have the infrastructure in this area to support all this additional housing. The safety of the access via Tollgates would add signicant traffic to the already overstretched North Trade Road and the A2100.
Parts of this site have been identified as being at risk from surface water flooding. Building on greenfield land causes surface run off and this could impact neighbouring properties.

Yours Sincerely George Edward Lipscombe

I would like to express serious concerns about the Council's proposal to build more new housing in Battle.

Huge numbers of houses have already been planned, some built, some under construction. Progress has been very slow and the public right of way through the proposed Blackfriars estate has been completely closed for much too long, the estate being neither fully occupied nor finished at this time.

There has been no apparent increase in supportive infrastructure such as doctors, schools and road access to the area.

In addition I understand from the national news that water supplies are insufficient for the buildings already planned in the South East water region and clearly this problem will become worse if additional homes are built. It also seems unlikely that there will be jobs in the immediate area for the residents of the properties already under construction.

Battle is in danger of becoming confluent with the South Coast urban area and losing its attractive character as a small semi-rural town with considerable attraction for tourists; making it difficult for local businesses to make ends meet. Once destroyed the character of the town will never return!

If this proposed housing is really needed it can be reconsidered after the other properties are occupied, but hopefully not without full consultation with local residents, amenities and businesses.

I would like to strongly urge you, the council, to support the survival of our community.

All proposed sites:
The vast majority of the proposed sites are greenfield despite a climate emergency and an abundance of brownfield sites in John’s Cross, around The Exchange and in the currently disused business parks on Marley Lane. The claim that the empty commercial sites are suitable for employment but not residential due to poor transport links is absurd – people don’t teleport to work - and there are numerous potential routes for cyclepaths and bridleways. Those sites are either appropriate for transport or they’re not. Remaining a disused blot on the landscape is not a good option.

The proposed sites in Battle are mainly large-scale developments. Admittedly, these are best for housebuilders profit margins but unfortunately they are very difficult to live in or around. Smaller developments (subdivision of existing housing, annexes or garden infill) of fewer than 10 homes allow more organic growth in population and are invariably better quality housing than those constructed en-masse by the likes of Wates etc. Mass-produced cookie-cutter houses ignore the existing setting, use cheap labour bussed in and inferior quality materials. Small spec-built developments design each house to accommodate the terrain and setting, employ local tradespeople and don’t have the incentives to cut corners. I've lived in a new build development and collapsing stairs, leaks, forgotten safety features and wobbly walls are the norm. We need QUALITY homes. The difference is plain to see and the mass-produced houses are still sold at the same price as those properly built ones!

Battle doesn’t have the services and infrastructure to cope.

The water companies are failing to deliver – seven out of the last twelve months were under hosepipe bans, so severe that even the exemptions were removed! If they’re unable to meet demand now, there will be a crisis when the new homes are built. EWSC has identified this area as one of severe water scarcity. The mere fact that they've announced support for the plan when they're failing to deliver on existing promises, raises serious questions about their assessment of any situation and their leadership team overall.

The roads are unable to cope with the extra congestion. Models may well show they can just about cope but of course the roads around Battle are particularly vulnerable to closure for fallen trees, landslips, flooding, repairs, railway works, accidents etc – so you need to consider that capacity is always at about 70% of what it should be.

The police don’t bother to investigate violent crimes and don’t have the budget to process evidence. Law and order hangs by a thread in Battle, sudden increases in population will break it.

The doctors and dentists are also at capacity. The primary schools are full.

There is a huge amount of investment needed to address all of these problems before there is capacity for anything other than very gradual growth in the area.


Proposed Site BT7:

While 6.6 of this proposal permits the decimation of National Landscape if it's cheaper (aka more profitable) to build there, I believe the need for two roads, the major flooding issues and terrain of the site means that it would not meet this test. In addition, there are several other reasons this site is entirely unsuitable:

Loss of Character: The proposed development would significantly alter the open character and natural beauty of the High Weald AONB and National Landscape, replacing historic fields with a large-scale housing estate. This would irrevocably damage the scenic value of this protected area, which is cherished for its rural charm and tranquility.

Harm to Landscape Setting: The development would encroach upon and disrupt the existing landscape setting, particularly the delicate balance between the built environment of Battle and the surrounding countryside. The introduction of a large number of dwellings would visually overwhelm the site and erode its natural appeal. The development would undoubtedly impact views from surrounding hills and trails, diminishing the overall aesthetic quality of the High Weald and decimating any remaining tourism we have left.

Ancient Woodland Destruction: The proposed development would directly abut an area of ancient woodland, a rare and irreplaceable habitat that supports a wide range of flora and fauna. Construction and associated activities would inevitably cause disturbance, fragmentation, and potential loss of this critical ecosystem.

Habitat Loss and Degradation: The network of historic fields, mature trees, hedges, and pond within the site provide valuable habitats for various wildlife species including bats, deer and various birds. Development would lead to the destruction or degradation of these habitats, resulting in the displacement or loss of local biodiversity. The proposed access points both have a multitude of mature trees that will be felled or suffer severely damaged roots as a result of the proposed roads.
A single mature oak (such as the one already felled on North Trade Rd in Battle coincidentally at the junction of one of the proposed access points for BT7) produces hundreds of thousands of litres of oxygen per year and supports thousands of species of birds, insects, lichen and fungus. They also prevent flooding and - being on clay soil - prevent heave from destroying our homes. They cannot be replaced by planting a few saplings - we'll have no planet left by the time they reach maturity and have even half the environmental benefit of those felled.

Proximity to Battle Conservation Area and Registered Battlefield: The site's proximity to these nationally important heritage assets raises concerns about the potential visual impact of the development. The large-scale nature of the proposal could detract from the historic significance and setting of these areas, compromising their cultural and historical value.

Impact on Grade II Listed Building: The construction of a vehicular access via Tollgates, as suggested in the plan, would directly affect the setting and visual integrity of the adjoining Grade II listed building (Lower Almonry Farmhouse) and the corresponding oasthouse. This could significantly diminish the historic value of the building and compromise its architectural integrity. Furthermore, the proximity of the proposed roads to the listed building, as well as the highly likely flooding from the removal of trees on the lane, may well cause irreversible structural damage to Lower Almonry Farmhouse.

Surface Water Flooding: The site is already identified as being at risk of surface water flooding. Developing on this land would exacerbate this risk, leading to flooding of the development itself and causing problems for existing neighbouring properties. A large ancient oak at the top of the track (one of the proposed access routes) was removed a few weeks ago in readiness for this plan and more will need to be felled, creating further risks of flooding and heave to the local properties.

Strain on Infrastructure: A development of this size would place significant additional strain on local infrastructure, including the congested North Trade Road, London Rd and High St. The Tollgates / North Trade Rd junction is already dangerous before and after school as students cross there and parents pull into Tollgates to drop off. Additional traffic is an accident waiting to happen.

Visual Dominance: The scale of the development would overwhelm the surrounding landscape, creating an imposing and incongruous feature that would detract from the rural character of the area.

Loss of amenity: the path way adjoining the plot along with Manser Shaw on the Western boundary and Saxonwood to the South are all regularly used by locals and tourists alike for rambling, dog walking and accessing the Abbey / High St. The proposed development will affect the enjoyment and amenity of the open space and will be detrimental to the physical and mental health of the residents.


Proposed Site BT1:
This area has just endured the Blackfriars debacle and is now facing another 220-250 houses! The surrounding roads are already gridlocked, Hastings Rd is at breaking point and the location of the site will put substantially more pressure on the High St as a through-route, creating yet more traffic chaos and serious risk to pedestrians.

I am writing to submit a formal objection to Development Potential Area BT2: Land at Breadsell, as set out in the Rother Local Plan - Draft Plan Proposed policies (Regulation 18), 2026. My objection is based on significant and well-evidenced concerns relating to biodiversity and protected habitats; environmental and landscape impacts; hydrological and hydrogeological risks; disruption to ecological networks; unsustainable transport patterns; construction-phase impacts; and adverse effects on residential amenity. 1. Impact on Biodiversity and Protected Habitats. My property directly borders the woodland immediately east of the proposed development area. This woodland provides essential habitat for species including badgers, foxes, fallow deer, bats, owls, buzzards, and a wide range of birdlife, many of which are legally protected. The area was previously designated a Biodiversity Action Plan (BAP) Priority Habitat, reflecting its ecological importance, and lies adjacent to the Marline Valley Woods/Combe Valley SSSI-one of the most ecologically sensitive sites in the borough. The National Planning Policy Framework (NPPF) requires planning policies to: · Protect and enhance valued landscapes and biodiversity (para. 174). · Safeguard ecological networks and maintain habitat connectivity (para. 174d). · Minimise impacts on biodiversity and secure measurable Biodiversity Net Gain (BNG) (para. 180). · Refuse development where significant harm cannot be avoided, mitigated, or compensated. A pair of buzzards has successfully nested in this woodland for several years. Development would destroy their nesting areas and most of their hunting territory, leading to the likely loss of this species locally. Fallow Deer have been breeding in these woodlands and pastures for many years. Their numbers and management is controlled by the Deer Act, 1991. Badgers-an iconic, national wild mammal and fully protected under the Protection of Badgers Act 1992-would be severely impacted through the destruction of setts and commuting routes. These effects are incompatible with national law and local biodiversity policies and would cause irreversible ecological harm. 2. Hydrological and Hydrogeological Risks to the SSSI. The Rigare Hydrological and Hydrogeological Assessment (2009) identified that changes in surface water run-off, infiltration, and pollution from development at Breadsell pose direct risks to the rare bryophyte assemblages within the adjacent SSSI. Paragraph 4.1.4 confirms that the Marline Valley Stream is already contaminated by discharge from the housing estate east of the proposed Breadsell site. Bryophytes are highly sensitive to changes in water quality, infiltration patterns, groundwater discharge and contaminants. 3. Landscape Sensitivity, Rural Character and Settlement Coalescence The Hastings Landscape Sensitivity Study (2024) identifies the Breadsell landscape as highly sensitive to both medium- and high-density residential development. 4. Loss of Green Infrastructure and Ecological Connectivity The woodland corridor on the eastern boundary provides a critical ecological linkage. 5. Transport, Accessibility and Sustainability The existing neighbouring development is highly car-dependent due to no shops, no schools and poor public transport. 6. Construction Phase Impacts Significant detrimental impacts are expected without strict controls. 7. Conclusion and Requested Actions I request the site be removed from the allocation and that full biodiversity duties are upheld. Thank you for considering my objection.

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. The proposed suburban
development at approximately 35 dwellings per hectare would introduce urban form into a
sensitive rural landscape, resulting in permanent harm.
2. Heritage Significance and Setting
The site is close to nationally significant heritage assets including the Registered Battlefield,
Battle Abbey Gatehouse, Battle Conservation Area and Grade II listed Lower Almonry
Farmhouse. Development would harm their setting.
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.
National guidance recommends greater separation than the proposed 15m buffer.
The site supports wildlife including deer, bats and protected species. Cumulative ecological
impact has not been adequately assessed. The allocation risks conflict with national policy
requiring protection of irreplaceable habitats and delivery of Biodiversity Net Gain.
4. Surface Water and Flood Risk
Parts of the site are at risk of surface water flooding. Development would increase hard
surfacing and runoff, exacerbating flood risk. The Local Plan should not allocate sites where
mitigation is uncertain.
5. Highway Safety and Infrastructure Capacity
Vehicular access via Tollgates will impact North Trade Road and the A2100. Junction capacity
assessments are required. Existing congestion, proximity to Claverham Community College,
and pressure on school and healthcare capacity raise serious concerns.
6. Cumulative and Precedent Effects
Almonry Farm contributes to the rural character of the southern edge of Battle. Allocation
risks erosion of the wider landscape and may create pressure for further development.
Conclusion
Policy BT7 is not justified by evidence, fails to give weight to protected landscape and heritage
assets and does not address infrastructure or environmental constraints.
I respectfully request that Policy BT7 be removed from the next iteration of the Draft Local
Plan.

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.
Recently the local water company has stated that it does not yet have the capacity to meet the requirements of the number of proposed new developments in the area so it would seem to be sensible to wait until the water companies have the capacity rather than just going ahead with this uncertainty.
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.

Subject: Formal Objection to Rother Local Plan (Regulation 18/19 Consultation)

To the Rother District Council Planning Department,

As a resident of Battle, I am writing to formally submit my objection to the proposed Rother Local Plan 2025 through 2042. While I recognize the need for a coherent development strategy, the current proposals for Battle are unsustainable and threaten the unique heritage, delicate ecology, and overstretched infrastructure of our historic town.

Q2: Comments on Housing Targets
I strongly object to the proposed housing target of 8,427 dwellings over the plan period. This represents a disproportionate level of growth that Battle’s infrastructure simply cannot accommodate. Our local GP surgeries, schools, and road networks are already operating at or beyond capacity. The plan fails to provide concrete infrastructure delivery to match this surge in population. The target fails to account for the unique, heavily constrained nature of our district, where 83 percent of the land is protected High Weald National Landscape.

Q8: Comments on Overall Development Strategy
The strategy’s reliance on greenfield development within National Landscapes is unjustified. National planning policy dictates that major development in such protected areas should only occur in exceptional circumstances. The Council has not adequately demonstrated that it has explored all brownfield alternatives across the wider district before targeting Battle’s peripheral green fields. Prioritizing urban intensification in non protected areas should be the absolute mandate.

Q36: Comments on Specific Site Allocations (Battle)

Site BT7: Land at Almonry Farm
I am diametrically opposed to the development of Site BT7. This site is of immense historical significance as it adjoins the Registered Battlefield of the 1066 Battle of Hastings. Development here would cause irreparable harm to the setting of the Battle Abbey Gatehouse Scheduled Monument and the Grade II Listed Lower Almonry Farmhouse. Furthermore, the site contains High Weald features, ancient woodland, and deciduous woodland priority habitats that are vital for local biodiversity. The identified surface water flooding risks on this site make it entirely unsuitable for the proposed 80 dwellings.

Site BT1: Land south of Hastings Road
I strongly object to the allocation of Site BT1 for 220 dwellings. The proposed density of 40 dwellings per hectare is an urban imposition that is wholly inappropriate for the character of the High Weald National Landscape. This development would create dangerous levels of traffic congestion on the A2100 Hastings Road, which is a route already plagued by peak time delays. The transition from derestricted speeds to residential access points poses a severe safety risk. The loss of wildflower meadow priority habitats and the encroachment on ancient woodland buffers further underscore the environmental unsuitability of this site.

In conclusion, these sites should be removed from the Local Plan in their entirety to preserve the historic integrity and natural beauty of Battle for future generations.

Yours faithfully,

Richard Wade
25 Tollgates
Battle
TN33 0JA

Draft Rother Local Plan 2025–2042 – Development Strategy and Site Allocations: Public Consultation under Regulation 18 of The Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended)

Thank you for your consultation on the above draft Local Plan.

We have a number of significant concerns with the quantum and scale of site allocations proposed in the draft Local Plan, in terms of impacts on the nationally designated High Weald National Landscape, such that we would consider the plan to conflict with paragraphs 189 and 190 of the NPPF, and thereby unsound in its present form. We would make the following comments:

Development Strategy

Notwithstanding the references in paras 3.9 and 3.21 of the draft plan regarding the protection of National Landscapes, and the ability to reduce housing requirements accordingly, we are extremely concerned by the proposed Development Strategy set out in section 5 of the draft plan, and the quantum of development proposed within the High Weald National Landscape.

Paragraph 189 of the NPPF sets out that ‘great weight’ should be given to conserving and enhancing landscape and scenic beauty in National Landscapes, which (along with National Parks & the Broads) ‘have the highest status of protection in relation to these issues’. It also sets out that ‘the scale and extent of development within these designated areas should be limited’ and that ‘development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.’

The proposed 2,055 number of new dwellings on sites within the High Weald National Landscape (over and above existing allocations in the 2019 DaSA) could in no way be described as ‘limited in extent’, nor could the fact that 23 of the site allocations are proposed for 30+ dwellings, (and 11 of those sites proposed for 60+ dwellings) be descried as ‘limited in scale’. At the broadest level, and notwithstanding the large area of Rother District that lies within the High Weald National Landscape, we therefore consider the allocations strategy at the broadest level would fail to comply with para 189 of the NPPF.

You will see from the Site Allocations comments later in this response, and our site-specific comments appended in table form to this response, that we consider a large number of the proposed site allocations would be harmful to the natural beauty of the High Weald National Landscape, and would fail to comply with para 189 of the NPPF, and, in a number of instances, para 190 too. We therefore consider that a number of the proposed site allocations should be deleted from the draft Local Plan, and the proposed number of dwellings in the housing requirement reduced accordingly.

We appreciate that the 2024 changes to the standard method for calculating objectively assed need has resulted in a larger OAN for Rother DC (described in paras 3.1-3.4 of the draft plan). However, importantly, the NPPF allows for strategic policies in Local Plans to provide for less than the housing need in certain circumstances, while the NPPG clarifies that Local housing need (calculated using the standard method as amended in December 2024) is not necessarily the same as the housing requirement that goes forward in a Local Plan.
This was confirmed by the Government in their published Government response to the proposed reforms to the NPPF (Government response for Questions 1 and 2) published 20th July 2024, which states:

“The standard method identifies the minimum number of homes needed and local planning authorities are expected to plan to meet their housing needs in full. However it is recognised that there may be local constraints on land and delivery that could justify a lower housing requirement figure.” (N.B. Underlining added for emphasis).

Accordingly, para 69 of the NPPF sets out that strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need can be met over the plan period. (N.B. bold added for emphasis)
That Government response also clarified that the NPPG had been updated accordingly. The NPPG (Housing and Economic Needs Assessment) confirms that:

“The standard method set out below identifies a minimum annual housing need figure, … It does not produce a housing requirement figure.” (Paragraph: 002 Reference ID: 2a-002-20241212)

and explains the difference between local housing need and housing requirement, and clarifying that:

“The housing requirement is the minimum number of homes that a plan seeks to provide during the plan period. Once local housing need has been assessed, as set out in this guidance, authorities should then make an assessment of the amount of new homes that can be provided in their area. This should be justified by evidence on land availability, constraints on development and any other relevant matters.” (Paragraph: 040 Reference ID: 2a-040-20241212)

Paragraph 11 (b) (i) of the NPPF sets out that local planning authorities should provide for objectively assessed needs for housing and other uses, as well as any unmet needs from neighbouring areas, unless “the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area”. The assets referred to are listed in footnote 7 and include National Landscapes, the relevant policies for which in the Framework being 189 and 190.

Accordingly, the NPPG (natural Environment) clarifies that, with regard to National Landscapes:

“The National Planning Policy Framework makes clear that the scale and extent of development in these areas should be limited, in view of the importance of conserving and enhancing their landscapes and scenic beauty. Its policies for protecting these areas may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process, and they are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas…” (Paragraph: 041 Reference ID: 8-041-20190721.) (bold text added for emphasis)

Whilst we acknowledge the intention to seek to meet as far as possible the OAN, this must be carried out in the context of the limited scale and extent of development in National Landscapes required by the NPPF, and within the context of the ‘great weight’ to be given to conserving and enhancing their landscape and scenic beauty.
Further, this must be carried out in a way which is compliant with the High Weald AONB Management Plan 2024-2029 This statutory document is adopted by all the relevant local authorities with land in the High Weald National Landscape, including Rother District Council, as their policy for the management of the area and for the carrying out of their functions in relation to it, and is a material consideration for planning applications affecting the HWNL.

With particular regard to the High Weald National Landscape, Management Plan Settlement Action ‘h’ sets out that partners will “Pursue landscape-led positive planning approaches to settlement planning and housing delivery in the AONB, seeking to prioritise the delivery of new housing primarily through small-scale development consistent with AONB character, recognising the potential for harm through the cumulative effects of separate developments on the designated landscape”

Rother District Council has had considerable success over the last couple of years, including since the publishing of the new standard methodology for OAN, in defending housing development appeals in the HWNL, with Inspectors agreeing with the Council’s assessment of harms of specific proposals on the landscape character and natural beauty of the HWNL, and that such harms meant that policies of the Framework provide a strong reason for refusing the development proposed. The same logic can and should therefore confidently be applied to the consideration of proposed sites under NPPF para 11(d)(i).

Major Development

With regard to the subject of major development in the HWNL in site allocations, we are particularly concerned by para 6.6. of the ‘Draft Development Stategy for Rother’, which, while recognising that the NPPF confirms that major development in National Landscapes should only be permitted in exceptional circumstances and where it can be demonstrated that the development is in the public interest, states ”The need for housing, including affordable housing, in sustainable locations within the district could potentially be an exceptional circumstance that could allow for a major development within the HWNL.”.

To justify major development on the basis of meeting objectively assessed housing needs for the local planning authority area is a circular argument at plan-making stage, because the impact of the scale and distribution of development on the National Landscape should be taken into account in deciding the level of housing provision (NPPF paras 69 and 11(d)(i)). If such housing levels can only be achieved by allocating major development in the NL, which by definition will have “a significant adverse impact on the purposes for which the area has been designated” then this is a good indicator that the impact on the National Landscape provides “a strong reason for restricting the overall scale, type or distribution of development in the plan area” as provided for in NPPF paragraph 11.

Paragraph 190 of the NPPF sets out that within National Landscapes, planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.

Whilst paragraph 190 specifically refers to planning permissions, it has also been considered relevant by Local Plan Inspectors to allocations within Local Plans.1 Legal advice provided to the South Downs National Park Authority by Landmark Chambers also concluded that “it would arguably amount to an error of law to fail to consider paragraph 116 (now 190) at the site allocations stage of plan making for the National Park. The consequence of doing so would be to risk allocating land for major development that was undeliverable because it was incapable of meeting the major development test in the NPPF”2.

We would consider a large number (some 16) of the site allocations proposed in the draft plan to constitute major development under the NPPF definition in footnote 64 of paragraph 190. As such, there would be a presumption against the allocation of these sites for development, and they are considered in more detail in the individual site comments below and appended table. In summary it is considered that the inclusion of the majority of these major sites would render the current plan unsound, as it would conflict with the NPPF.

Proposed draft Site Allocations

We are extremely concerned that sites with the HWNL have been proposed in this draft local plan prior to the carrying out of any detailed Landscape Capacity Studies, Landscape Sensitivity Studies or Landscape Visual Assessments, as part of the evidence base. We consider any proposed site allocations to be premature in the absence of such work.

We note that some sites have been considered in the HELAA Landscape Sensitivity Assessment (September 2022), however, this work is very brief, just one or two paragraphs per site plus a table, and we do not consider this is a sufficiently robust or detailed assessment of the impacts of the sites; the Site Assessment Table doesn’t assess the sensitivity of the sites in the HWNL against the AONB Management Plan key character components of natural beauty, and includes no map or photographic based assessment. Also, along with sensitivity assessments, those sheets also assign a range of ‘value’ to each site, including those within the HWNL (high, high/medium/medium etc) – whereas as designated NLs they have already been assigned the highest level of value by government (see Landscape Institute’s GLVIA3 Notes & Clarifications 5(7). Furthermore, in some instances the cautionary conclusions of the HELAA LSA do not seem to have informed the proposed allocations.

For any sites within, or affecting the setting of the National Landscapes, site assessment work needs to take into account the impact of those potential sites on the purposes of the designation, taking into account the HWNL (AONB) Management Plan. Planning Principle 1 of the High Weald AONB Management Plan 2024-2029 gives advice on the type of assessments that should inform local plans.

Decisions on allocating sites within or affecting the setting of National Landscapes requires a robust understanding of landscape including the history and settlement patterns of the wider landscape. Site-specific landscape sensitivity studies and landscape and visual assessments and are an important part of this, to inform the principle of allocation, the appropriate quantum and location of development, the extent of site coverage, any mitigation strategies, e.g. landscape buffers and their appropriate location and size, and to consider any other site-specific issues.

A key concern is that we note that for a number of the proposed site allocations, the ‘site specific development requirements’ in the draft local plan mention the need for development to be informed by a landscape sensitivity assessment. However, this is too late in the process, the Landscape Sensitivity Study needs to be completed first, to inform the allocation process, not post-allocation. Moreover, the LSS needs to be prepared objectively by the LPA.

No allocation should be being proposed until the above work is completed -it is wholly insufficient to simply include a reference in the policy supporting text (as in the current draft) that ‘”It is within the High Weald National Landscape and therefore a sensitive form of development is required in line with Local Plan policies”– in order to align with the requirements of NPPF para 189, impacts on the setting of the HWNL need to be robustly considered prior to allocating a site; firstly regarding the principle of the allocation; the location and scale of development in relation to the HWNL, and secondly to inform/test the quantum of development that might be appropriate in such a location.

Additionally, any site allocations proposed for grassland sites in the HWNL should also be subject to grassland surveys, and if found to be unimproved grassland these should not continue to be allocated for development in the Reg 19 version, since this is an important habitat type within the HWNL, and an important part of its landscape character and natural beauty.

We consider there therefore needs to be considerable further site-specific work undertaken to inform the next iteration of the draft local plan. We understand that the next iteration is intended to be a Reg 19 version with consultation scheduled for the autumn, for submission in December under the current Local Plans regime. However, in view of the additional work needed in relation to the proposed sites, and our comments on the site allocations below, we consider this would be premature, and the timescale to be unrealistic, and instead we consider a further Reg 18 consultation would be more appropriate.

Densities

We note that para 5.16-5.26 of the draft Local Plan deal with the matter of densities in residential development. Whilst in principle we have no issue with higher densities – High Weald settlements are typically fairly high density in village cores- it is important to recognise that this is through their being populated with tight-knit streetscapes of smaller dwellings. In order to meet Settlement Objectives S1 and S2 of the High Weald AONB Management Plan, we consider that guidance, either in a general density policy and/or the site-specific policies, will need to clarify this, so as to manage developer expectations and avoid scenarios where schemes are submitted consisting of high numbers of detached/semi-detached buildings packed in close proximity to each other, as that would constitute an approach and grain that would be discordant with High Weald settlement pattern and streetscape character.

Site Specific Policies

Further to the site specific assessment work, and to ensure that clear and realistic expectations for each site are set, with regard to the High Weald AONB Management Plan, and the Council’s duty under section 85 of the CRoW Act, we advise that the site-specific policies for all those sites proposed within the HWNL (and those affecting its setting) included in the next iteration of the draft Local Plan should:

• include maps/plans setting guiding principles/parameters for development (including extent of site coverage, building heights, and the retention of any existing wooded boundaries, and enhancement of these where appropriate for mitigation measures), and
• refer to the HWNL in the ‘Site specific development requirements’, and include in those requirements that proposals need to reference the principles in the HW Housing Design Guide, and that lighting proposals (including highways lighting) to be based on the HWNL Dark Skies Planning Advice Note.

Individual proposed sites comments

In the light of the absence of a detailed landscape evidence base, the appended table represents our initial comments on the draft proposed sites; however, with some we are able to recognise significant harms to the HWNL even without the further work, and these are highlighted red in the table as sites that, at this stage, we object to being allocated for development.

Overall, you will see that we consider a number of sites would cause significant harm to the natural beauty of the High Weald National Landscape, would conflict with objectives of the HW AONB Management Plan 2024-2029, and would conflict with policy 189 of the NPPF, resulting in the plan being unsound, and therefore should not be allocated for development in the next iteration of the draft plan. These are: BT1 (in part), BT8, BT10, BC1, BR3, BW3, BW4, BWC1, EC2, EC3, FW2, GU6, HG4, IK1, IK2, NR2, PE1, PL1, SD11, SC2, and TC1. A summary of our reasons for arriving at these conclusions is included in the appended table. This list includes a number of sites that we consider should be considered ‘major development’ in the HWNL under the provisions of NPPF para 190, and for which there do not appear to be exceptional circumstances (see our earlier general comments in this response). However, the absence of red highlight on other sites in the table (or that they are not included in the above list) does not mean that we support the allocation, rather that at this stage we are unable to provide a definitive view on either the principle of development or the quantum proposed, without the further landscape assessment work being carried out (and we set this out for those sites).

Legislative Requirements

Lastly I would also draw to your attention Section 85 of the CRoW Act (as amended by the Levelling-Up and Regeneration Act in December 2023) sets out that ‘relevant authorities’, in exercising or performing any function that affect National Landscapes in England, “must seek to further the purpose of conserving and enhancing the natural beauty of the Area of Outstanding Natural Beauty.”3

Within the planning context, ‘relevant authorities’ are the Local Planning Authorities and the Planning Inspectorate, along with Parish Councils producing Neighbourhood Plans, and the duty applies to all aspects of the planning process, including decisions relating to site allocations in Local Plans etc. More information for LPAs on complying with the new duty in the planning policy plan-making process is available at CRoW-s.85-duty-guidance-for-LPAs_NLA-Briefing-Nov-24.pdf

Conserving and enhancing the natural beauty of the High Weald National Landscape (HWNL) will normally mean avoiding harm, and conserving and enhancing the character components identified in the AONB Management Plan; supporting the Management Plan Objectives as set out for each of these; and following any Management Plan Actions set out for each.

It is therefore important that this new duty is reflected in the language and content of the Local Plan throughout, including in the commitment to any particular housing requirement figure, the spatial strategy, policy direction and ambition, and the evaluation of any proposed site allocations.

The above comments are advisory and are the professional views of the HWNL Unit’s Planning & Design Advisor on the potential impacts on the High Weald landscape. They are not necessarily the views of the HWNL Joint Advisory Committee.


Please see attached documents including HWNL response letter and Appendix 1.

Dear Planning Policy Team,
Re: Draft Rother Local Plan (2025–2042) – Regulation 18 Consultation
Policy BT7 – Land at Almonry Farm, Battle
I write to formally object to the proposed allocation of Land at Almonry Farm (Policy BT7) for residential development of approximately 80 dwellings.
In my view, this allocation fails the tests of soundness set out in the National Planning Policy Framework (NPPF). It is not justified, not effective, and is not consistent with national policy relating to protected landscapes, heritage assets, biodiversity and infrastructure.
Impact on the High Weald National Landscape
The site lies wholly within the High Weald National Landscape. Under Section 85 of the Countryside and Rights of Way Act 2000, the Council has a statutory duty to conserve and enhance the natural beauty of this nationally protected landscape.
The site comprises undeveloped greenfield land forming part of an intact historic field system defined by mature hedgerows and trees — characteristic features of the High Weald. The proposed suburban development at approximately 35 dwellings per hectare would introduce urban form into a sensitive rural landscape, resulting in permanent harm.
The allocation does not demonstrate exceptional circumstances or overriding public interest sufficient to justify development within this protected landscape.
Heritage Significance and Setting
The site lies in close proximity to nationally significant heritage assets, including:
• The Registered Battlefield (1066 Battle of Hastings)
• Battle Abbey Gatehouse Scheduled Monument
• Battle Conservation Area
• Grade II listed Lower Almonry Farmhouse
The land forms part of the historic agricultural setting associated with Battle Abbey and contributes to the wider battlefield landscape. Even where development does not directly affect designated assets, the NPPF requires great weight to be given to the conservation of their setting.
There is also recognised archaeological potential in this area, with local historical evidence suggesting nearby Manser’s Shaw may correspond to the “Malfosse” episode of the 1066 battle. Allocation at this stage, prior to comprehensive archaeological assessment, is premature.
Development would suburbanise part of the Abbey’s wider landscape context and erode the rural character that contributes to the significance of these nationally important assets.
Ancient Woodland and Biodiversity
Ancient Woodland and Priority Habitat lie immediately adjacent to the eastern boundary of the site.
While a 15-metre buffer is proposed, national guidance often recommends greater separation to prevent long-term degradation caused by light spill, recreational pressure, domestic pets and hydrological change.
The site supports wildlife including deer, bats and other protected species. The cumulative ecological impact of development in this sensitive location has not been adequately demonstrated at plan-making stage.
The allocation therefore risks conflict with national policy requiring protection of irreplaceable habitats and delivery of genuine biodiversity net gain.
Surface Water and Flood Risk
The supporting text acknowledges that parts of the site are at risk of surface water flooding. Development of greenfield land increases hard surfacing and run-off, potentially exacerbating flood risk to neighbouring properties and downstream systems.
The Local Plan should not allocate sites where flood risk mitigation remains uncertain.
Highway Safety and Infrastructure Capacity
Vehicular access is proposed via Tollgates, with impacts on North Trade Road and the A2100. The Plan itself acknowledges that further junction capacity assessments are required.
Given existing congestion and the proximity to Claverham Community College, there are legitimate concerns regarding pedestrian safety and traffic conflict. Allocation prior to confirmed modelling and mitigation measures renders the proposal unjustified and potentially ineffective.
In addition, Battle’s healthcare provision, school capacity and local services are already under pressure. The allocation does not secure clear, deliverable infrastructure improvements aligned with the scale of growth proposed.
Cumulative and Precedent Effects
Almonry Farm currently contributes to the rural character of the southern edge of Battle. Allocation of this parcel risks incremental erosion of the wider landscape and may create pressure for further development across remaining farmland.
The cumulative impact of multiple allocations around Battle must be properly assessed to avoid gradual suburbanisation of a town of exceptional historic importance.
Conclusion
For the reasons outlined above, Policy BT7 is not justified by robust evidence, fails to give appropriate weight to nationally protected landscape and heritage assets, and does not adequately address infrastructure and environmental constraints.
I respectfully request that Policy BT7 – Land at Almonry Farm – be removed from the next iteration of the Draft Local Plan.
Yours faithfully,

Please see attached: East Sussex County Council Representations on the Rother Local Plan ‘Development Strategy and Site Allocations Draft (Regulation 18) Version’ consultation

To: Rother District Council Planning Department Re: Formal Objection to Proposed Allocations BT1, BT8, and BT10 (Land south of Hastings Road) | Draft Rother Local Plan (2025–2042)

To the Planning Department,
As a resident of Hastings Road, I am writing to express my strong opposition to the proposed development of site BT1 and its adjacent parcels. I live with the daily realities of this specific stretch of road, and I believe that the scale of the proposed allocation—a minimum of 250 new dwellings—is fundamentally at odds with the safety of our community and the protected status of our landscape.

My objections are based on the following material considerations:

1. Severe Traffic Risks and Junction Safety
The A2100 is already struggling to cope with current volumes. Adding a massive new development here is not just an inconvenience; it is a safety hazard.
• The "Double Junction" Conflict: The proposed entrance for BT1 sits less than 200 metres from the Blackfriars development. This creates a "staggered" conflict zone where turning traffic will constantly be obstructed by tailbacks from the other junction. This is a recipe for side-swipe and rear-end accidents.
• The Speed Transition Zone: The site sits exactly where the limit shifts from 30mph to 40mph. Outbound drivers are accelerating, while inbound drivers are often still carrying 40mph speeds into the 30mph zone. Placing a high-volume residential entrance in this "acceleration corridor" fails the NPPF Paragraph 115 requirement for safe and suitable access.

2. Destruction of National Landscape (AONB)
This site is part of the High Weald National Landscape. Under current national policy, these areas deserve the highest level of protection.
• Density vs. Character: Proposing 40 dwellings per hectare is an urban-style density that has no place in a rural AONB.
• Loss of Habitat: This project would wipe out 11 hectares of greenfield land, including wildflower meadow habitats and established wildlife corridors. No amount of "buffer zone" can compensate for the total loss of this natural drainage and ecosystem.
• Flooding Concerns: The southern boundaries of BT1 are already flagged as surface water flood risks. Replacing 11 hectares of absorbent field with tarmac and concrete is reckless and directly threatens the properties located downhill.

3. Failure of Infrastructure and "The Blackfriars Lesson"
Battle’s infrastructure is currently failing to meet the needs of its existing residents, let alone 250+ new households.
• Medical and Schooling: Our local GP and NHS dentistry services are at a breaking point. Furthermore, the Council’s own assessment admits this site is far from primary schools; expecting families to rely on "active travel" on a steep, congested A-road is simply unrealistic.
• Broken Promises: We have seen how the Blackfriars development was "value-engineered" and redesigned when costs rose, leading to a watering down of original promises. I have zero confidence that the "landscape-led" vision for BT1 will survive the reality of developer profit margins once the plan is approved.

Conclusion
The Battle Neighbourhood Plan was democratically adopted to prevent exactly this kind of unsustainable sprawl. Expanding development to this scale on a Greenfield National Landscape site—during an infrastructure and climate crisis—is unsound and unjustified. I urge the Council to remove these allocations from the Local Plan.

See attached document setting out objections primarily on highways matters and landscape impact to site BT8.

I am writing to you as a resident of Battle to submit a formal objection regarding the proposed Rother Local Plan 2025-2042. While I understand the necessity of a structured planning framework, the current proposals for the Battle area represent an unsustainable and disproportionate level of growth that threatens the unique heritage, ecology, and infrastructure of our historic town.

My objections, structured by the relevant consultation questions, are as follows:

Overall Strategy (Q1 & Q2)

The proposed Development Strategy is fundamentally flawed in its approach to the High Weald National Landscape. The plan fails to provide sufficient justification for such intensive development within a protected landscape, which should be afforded the highest level of protection under the National Planning Policy Framework (NPPF). I strongly object to the strategy's reliance on greenfield expansion when a more rigorous 'brownfield first' approach is required to protect our natural assets. The current strategy risks the permanent loss of the very character that defines our region.
+2

Housing Targets (Q3)

The housing targets allocated to Battle are entirely disproportionate to the town's existing scale and its capacity for growth. Our local infrastructure—specifically GP surgeries, oversubscribed schools, and our already congested road network—cannot sustain a population increase of this magnitude. To impose these figures without guaranteed, front-loaded infrastructure delivery is negligent and will significantly diminish the quality of life for all current residents.
+3

Site Allocations (Q36)

Objection to Site BT7: Land at Lower Almonry Farm

I wish to register my strongest possible objection to the allocation of site BT7. This site is of immense historical and environmental significance, and its development would be an act of administrative vandalism.

Heritage and History: The site is adjacent to the historic 1066 Battlefield and includes the Grade II Listed Lower Almonry Farmhouse. Development here would irrevocably damage the setting of these irreplaceable national assets.

Landscape and Ecology: The site sits within the High Weald National Landscape and contains Ancient Woodland. The loss of character and the impact on biodiversity would be catastrophic.
+2

Flooding and Environment: There are significant surface water flooding risks associated with this land. Developing on this site will only exacerbate run-off issues, potentially endangering existing properties and further straining local drainage systems.
+1

Objection to Site BT1: Land south of Hastings Road

I also strongly object to the allocation of site BT1. The scale of 220 dwellings at a density of 40 dwellings per hectare (dph) is entirely inappropriate for a sensitive location within the High Weald.
+2

Traffic and Safety: The A2100 (Hastings Road) is already a bottleneck. The addition of hundreds of vehicle movements will lead to severe congestion and raises serious safety concerns regarding junction visibility and speed transitions at the town's entrance.

Urbanization of the High Weald: A density of 40 dph is an urban density being forced onto a rural fringe. This layout ignores the landscape sensitivity assessment required for the National Landscape and would result in a generic housing estate that ignores Battle's distinct "sense of place."
+2

Environmental Impact: The site contains High Weald Wildflower Meadow Priority Habitat and is adjacent to ancient woodland. A 15-metre buffer is insufficient to protect these delicate ecosystems from the cumulative impact of such a high-density development.
+2

In conclusion, I urge the Council to remove sites BT1 and BT7 from the Local Plan and to radically reassess the housing targets for Battle to align with the actual capacity of our infrastructure and the legal protections afforded to our National Landscape.

I am objecting to the proposed allocation of Land at Breadsell (BT2) for housing as part of the RDC Local Plan as I do not consider this a site that is suitable for development.
Development of the land would become probably only take place as part of a larger development occurring in Hastings Borough. That land contains ancient woodland. The development would, as your supporting text suggests, become an extension of Hastings rather than Battle.
The site lies in the Strategic Gap between Battle, Hastings and Crowhurst. This has been designed to protect the countryside and prevent merging of settlements. Building housing would be detrimental to that separation.
The land forms part of open countryside on higher ground next to the High Weald National Landscape. Development would destroy the rural character of the area. Access to the site is from the A2100 which is a busy fast road. Development would require construction of pedestrian and cycling infrastructure making this site totally unsuitable
The question of Marline Valley Woods SSSI remains unresolved. Rother Council’s own information confirms that eco-hydrological monitoring is still needed to understand the effects of development. This site should not even be considered until this work is concluded.
The woodland and hedgerow habitats around Breadsell and the nearby Marline Valley Woods SSSI are known to support protected species including hazel dormice, bats, and great crested newts. Any development here will disrupt or destroy important habitat and wildlife corridor. How will these species and many others be protected?
For the reasons detailed above I strongly object to this site's proposal. I do not consider this site should be included in RDC’s plans.

I want to object to the proposals for the allocation of Land at Breadsell (BT2) for housing as part of the RDC Local Plan.
I feel it would have a huge impact on Marline Valley Woods (SSS1). We don’t know the ecological effects of such a development on this site. There is a Strategic Gap between Battle, Crowhurst and Hastings, to prevent settlements merging and to protect the countryside between them. Any house building would weaken this separation. The policy is linked to the developments in Hastings Borough, threatening the ancient woodland which is of great concern. This land is outside of Rother District Council’s control and there is no guarantee the wider scheme will happen. It will affect the open countryside and landscape. It will increase car use
and destroy hedgerow habitats around Breadshell and also the nearby Marline Valley Woods SSSI which support protected species. This development will destroy the wildlife there, perhaps for ever. I strongly protest against these plans.

I am a resident of Asten fields and I am very concerned about more houses being built on near by fields. We are having many houses built in battle and once the land is built on it’s lost forever. We have lovely surrounding fields and woodlands that we use for walking, dog walking and it’s an area we like to just go to get away from stress of work. We also have wildlife that will be destroyed and trees that will be cut down. Also I am concerned about the size of the population we have a small doctors surgery that is struggling, schools that are almost full and we have a problem with water usage. It seems that you are just building for the sake of building with out looking at the long term damage it will cause to our small historical town.
Resident of Asten fields

I object to all proposed new developments in Battle. The town does not have the infrastructure to support these new developments schools, drs, especially. B7 & B11 being sited on fields would be criminal to the wildlife and beauty of nature.

I object to bt11 because of safety element so close to primary school, more traffic, more people. Battle has no infrastructure to support all this housing, doctors surgeries struggle now, how do they cope with 200 new homes? The High Street can nit cope with more traffic, and what about pollution from 100's more cars. I live on the High Streetband cracks appear every day in my home either large vehicles passing. This is a place of history and tourists make up the income from shops , these tourists park in market square car parks, where do they go if you build on it, they will stop supporting Battle commerce. Market road will become a motorway with all the extra cars, how is that safe for children walking to the primary school? Nit practical to build there at all.

BT1 - With the new houses already just finishing being built opposite, we haven't even seen the impact these will have to the current traffic flow, safety of the area and children walking around as well as ability to get on or off the main road out of the dead end roads. Adding another settlement so close is irresponsible and not regarding the wellbeing of the area, just what money can be brought in when we're already failing to provide resources and consistent water and power to the residents of the area.

The objection opposes proposed allocations BT1, citing significant concerns over traffic, environmental harm, and infrastructure capacity. Hastings Road (A2100) already experiences severe congestion, and adding around 220 dwellings would worsen traffic flow, increase collision risks, and create unsafe conditions due to closely spaced junctions and a nearby speed limit transition zone.

The development would result in loss of Greenfield land within the High Weald National Landscape, conflicting with planning policy protections and the Battle Neighbourhood Plan. It would harm local habitats, wildlife corridors, and landscape character, while increasing surface water flooding risks due to impermeable surfaces.

Local infrastructure, including healthcare and schools, is already under strain and unable to support additional demand. Previous developments have failed to deliver promised infrastructure. Overall, the proposal is considered unsustainable, unsafe, and contrary to national and local planning policies.

Subject: Objection to Proposed Site Allocation BT10 – Draft Rother Local Plan 2025–2042
Dear Sir/Madam,
I write to formally object to the proposed allocation of Site BT10 for residential development
within the Draft Rother Local Plan 2025–2042 Development Strategy and Site Allocations
document.
The proposed allocation of approximately 25 dwellings at this location raises significant
concerns in relation to highway safety, landscape impact, loss of green space, infrastructure
pressure and harm to neighboring residential amenity.
1. Highway Safety and Access
The proposed site would require access onto a road with a 40mph speed limit. The creation
of a new junction serving a residential development on a road of this nature raises significant
concerns regarding highway safety.
Introducing additional turning movements, slowing vehicles and residential traffic accessing
the development could create conflict points with fast-moving traffic. This increases the risk
of collisions and may pose dangers to both motorists and pedestrians.
This issue appears inconsistent with the principles of safe and suitable access required by
national planning policy, including the need for developments to provide safe and
appropriate access arrangements.
2. Impact on the High Weald National Landscape (AONB)
Battle and the surrounding countryside are entirely located within the High Weald National
Landscape. The landscape is nationally designated for its natural beauty and historic
character.
The draft Local Plan itself recognises that Battle sits in a visually exposed ridge-top
landscape within the High Weald National Landscape and that growth is constrained by
these environmental sensitivities.
Development of currently open land would urbanise a rural landscape that contributes to the
character and setting of Battle. The introduction of housing, roads, lighting and associated
infrastructure would harm the rural character and tranquillity of the landscape.
National planning policy gives great weight to conserving and enhancing landscape and
scenic beauty in designated landscapes such as National Landscapes (formerly AONBs).
Allocating additional greenfield development within this sensitive landscape risks
undermining this national policy objective.
3. Loss of Green Space and Countryside
The site currently forms part of the open countryside which contributes positively to the
character of the area and provides an important green buffer within the landscape.
Development of this land would result in the permanent loss of green space and contribute
to the gradual erosion of countryside surrounding Battle. Incremental development of
greenfield land can cumulatively damage the character of rural settlements and lead to
suburbanisation of the countryside.
The protection of countryside and landscape character should remain a key priority when
considering site allocations within the Local Plan.
4. Pressure on Local Infrastructure and Services
Battle is a historic town with existing infrastructure constraints. Additional residential
development will place further pressure on local roads, schools, healthcare services and
other community facilities.
The draft Local Plan itself acknowledges that accessibility and infrastructure limitations
constrain growth within Battle. Allocating additional housing sites without clear evidence
that infrastructure improvements will accompany development risks creating unsustainable
development patterns.
5. Loss of Privacy and Harm to Residential Amenity
Development on this site has the potential to overlook neighbouring properties, particularly
where existing homes currently enjoy open outlooks across the site.
The construction of new dwellings overlooking neighbouring properties could significantly
reduce privacy and residential amenity for existing residents. Such impacts should be
carefully considered when allocating sites for housing within close proximity to established
residential areas.
6. Overall Suitability of the Site
Given the combination of constraints affecting this location – including its position within the
High Weald National Landscape, highway safety concerns, infrastructure limitations and
impacts on neighbouring amenity – the suitability of Site BT10 for residential development is
highly questionable.
7. Flood Risk and Surface Water Flooding
The Council’s own evidence identifies flood risk as a constraint affecting Site BT10 (Land
adjoining Little Brans). Within the Interim Sustainability Appraisal (January 2026), the site is
scored “–” (significant adverse effect) against Sustainability Appraisal indicator SA5b
(surface water flood risk). This classification indicates that the site contains land identified
as being at high surface water flood risk, defined within the appraisal methodology as areas
with a greater than 3.3% annual probability of flooding from surface water runoff.
This finding is concerning because surface water flooding typically results from intense
rainfall events, overland flow routes, and drainage exceedance, and such risks are likely to
increase with climate change. Development on land affected by surface water flooding can
interrupt natural drainage patterns and increase runoff, potentially exacerbating flood risk
both within the site and in surrounding areas.
Given the increasing importance of climate resilience and the requirements of national
planning policy to direct development away from areas at risk of flooding where reasonably
possible, the identification of high surface water flood risk within Site BT10 raises serious
questions about the suitability of the site for residential development. The Sustainability
Appraisal itself therefore highlights a clear environmental constraint that should be given
significant weight when considering the allocation of this site within the Local Plan.
Conclusion
For the reasons set out above, the proposed allocation of Site BT10 for residential
development is not considered appropriate or sustainable.
The development would introduce highway safety concerns, harm the character and
appearance of the High Weald National Landscape, result in the loss of valuable green
space, increase pressure on already constrained local infrastructure and negatively affect
the amenity of neighbouring residents.
I therefore respectfully request that Rother District Council reconsider the allocation of Site
BT10 and remove the site from the Draft Rother Local Plan.

I strongly object to the proposed development strategy for Battle, which relies almost entirely on greenfield sites, including the highly sensitive site at (BT7) Almonry Farm, despite the clear availability of more appropriate brownfield alternatives within the town.
The BT7 development would not only damage historic and biordiverse land that has NEVER been built on but it will add a risk to surrounding schools who use these roads to access the very large intake at Claverham college by footpath that as a result of the contruction will be closed and parking in the surrounding roads that will not cope with the addtional traffic.
The inclusion of (BT7)Almonry Farm is particularly concerning and wholly inappropriate. This site forms part of the rural and historic setting of Battle and lies close to nationally important heritage assets, including the 1066 Battlefield and Battle Abbey. Development here would fundamentally alter the character of the area, urbanise a currently open landscape, and cause lasting harm to the setting of these important sites. The introduction of additional roads and housing in this location would further erode the historic and visual integrity of the town.
This approach is especially difficult to justify given the existence of viable brownfield opportunities within Battle, particularly around the station and St John's Cross. These areas are already developed or underused, benefit from existing infrastructure, and are located in sustainable positions with direct access to public transport. They represent the most appropriate locations for development and align with national planning policy, which prioritises the reuse of previously developed land.
Rather than focusing on these opportunities, the plan appears to favour greenfield expansion, which is both environmentally damaging and strategically flawed. It also risks delivering the wrong type of housing. Large-scale greenfield developments are more likely to result in high-cost, market-driven housing, rather than the genuinely affordable homes that are needed locally.
Brownfield sites near the station would be far better suited to providing affordable housing for first-time buyers, young people, and older residents wishing to downsize. This would support a more balanced and sustainable community while reducing reliance on cars and making better use of existing services.
In conclusion, the proposed development strategy for Battle is unsustainable and unjustified. The inclusion of (BT7)Almonry Farm is particularly harmful and should be removed from the plan. Greater priority must be given to brownfield redevelopment within the town especially around the station before any consideration is given to building on greenfield land. Development should be proportionate, infrastructure-led, and aligned with the need to protect Battle’s unique landscape, heritage, and community.

I as a resident in Battle most strongly object to the proposed housing at Almonry Farm for the following reasons:
- This land forms part of the historic setting of Battle Abbey and the 1066 battlefield.
Development here would interfere with part of the most historic landscapes in Britain!
- The site lies within nationally protected countryside and once built upon is gone forever. Ancient woodland borders this site and as such supports the habit of wildlife.
- Access via Tollgates would add significant traffic to an already incredibly busy North Trade Road,also due to the close proximity of Claverham College would increase congestion and endanger the safety of children where many walk daily!
- There is also a flood risk. Parts of the site are identified as being at risk of surface water flooding and thus could impact neighbouring areas.
- Infrastructure pressure: Battle’s GP surgeries, schools and local services are already stretched. There is no firm guarantees of infrastructure improvements alongside this proposal.
Thus as a resident of Battle I most strongly object to this proposal and would urge Rother planning to think again and NOT allow this proposal to proceed. Surely there are other sites that could be considered. I appreciate people need houses but NOT on this particular national heritage site. This land sits within the High Weald National Landscape, close to the 1066 Registered Battlefield, Battle Abbey, Battle Conservation Area and the Grade II listed Lower Almonry Farmhouse.
These are not just fields. They are part of the historic landscape that make Battle unique.

To: Rother District Council Planning Department

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

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


1. Traffic Congestion and Safety on North Trade Road

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

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

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

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


2. Environmental Impact and Air Quality

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

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

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


3. Infrastructure Deficits and Delivery Failures

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

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


CONCLUSION

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