This level of planned housing expansion is completely disproportionate for a town setting such as Battle. There appears to be no provision for or proposals to improve, upgrade and expand the existing supportive infrastructure of the town (schools / doctors etc) that would be required to service this level of influx of people into the area.
Considering the the historic importance of the town little consideration seems to have been given to the importance of the visitors and tourists footfalls that bring with them income to the town.

I object to BT2 this Woodland is an area of outstanding Beauty With bluebells, wooden enemies, wild bees orchid badgers bats owls wood mice field mice I have lived in this area for 24 years this little Woodland has so much to offer it’s wildlife. It has oak trees in it as well which helped with our environment. You take away all the trees which lessons are oxygen being cleaned there are also snakes in there and we have also seen Wild bore and dear The impact of our infrastructure would be huge.

This is adjoining a nature reserve and should be classed as part of it. It is home to protected bluebells, newts and orchids, additionally there is no infrastructure (GP etc) to support additional housing, these are ancient woodlands which are used daily to promote exercise and mental health

I am writing to submit my formal objection to the proposed Rother Local Plan 2025–2042. As a resident of Battle, I am deeply concerned that the current proposals represent an unsustainable level of growth that will irreparably damage the historic character, landscape integrity, and infrastructure of our market town.
My specific objections, referenced by the relevant consultation questions, are outlined below:
Q2: Proposed Housing Target (Policy 3.24 / Figure 2)
I strongly object to the proposed housing target of 8,427 dwellings. The move to a “standard method” calculation of 912 units per year — a threefold increase over previous targets — is fundamentally incompatible with a district where 83% of the land is protected within the High Weald National Landscape.
The plan fails to demonstrate how Battle’s infrastructure, which is already under significant pressure, can accommodate this increase. GP surgeries, schools, and our narrow historic road network are not equipped to support this level of growth. The Council should prioritise a lower, locally derived target that reflects the constraints of our protected landscape, in line with national planning policy.

Q8: Overall Development Strategy and the High Weald National Landscape
The strategy to focus growth within the High Weald National Landscape contradicts the Council’s duty to conserve and enhance natural beauty. While the plan refers to prioritising brownfield land, the proposed allocations rely heavily on greenfield development.
The justification that housing need constitutes “exceptional circumstances” for major development in a protected landscape is not convincing. This approach risks eroding the distinct character of Battle and surrounding settlements.

Q36: Proposed Site Allocations in Battle (Policies BT1 to BT11)
Objection to Site BT1: Land south of Hastings Road, Battle
I strongly oppose the allocation of this site for 220 dwellings.
• Traffic and safety: Additional access onto the A2100 and surrounding roads will worsen congestion and increase accident risk.
• Density: A density of 40 dwellings per hectare is inappropriate for this rural edge-of-town location.
• Environmental impact: The proximity to ancient woodland and priority habitats means development would cause significant ecological harm.

Objection to Site BT7: Land at Almonry Farm, Battle
I object in full to the proposed development of this site for 80 dwellings.
• Heritage impact: The site lies close to the 1066 Battlefield and Battle Abbey, and development would harm their setting.
• Listed buildings: The proposals would negatively affect the setting of the Grade II listed Lower Almonry Farmhouse.
• Landscape and biodiversity: The site contributes significantly to the character of the area and supports valuable habitats.
• Flood risk: Development may increase surface water runoff and exacerbate local flooding.
• Safety concerns: Increased traffic near busy junctions and disruption to footpaths used by Claverham students raises additional risks.

Conclusion
The Council must reconsider this scale of development. Our National Landscape and historic heritage should be protected for future generations, not compromised by unsustainable housing targets. I urge the Council to remove sites BT1 and BT7 from the Local Plan

I am writing to submit my formal objection to the proposed Rother Local Plan 2025–2042. As a resident of Battle, I am deeply concerned that the current proposals represent an unsustainable level of growth that will irreparably damage the historic character, landscape integrity, and infrastructure of our market town.
My specific objections, referenced by the relevant consultation questions, are outlined below:
Q2: Proposed Housing Target (Policy 3.24 / Figure 2)
I strongly object to the proposed housing target of 8,427 dwellings. The move to a “standard method” calculation of 912 units per year — a threefold increase over previous targets — is fundamentally incompatible with a district where 83% of the land is protected within the High Weald National Landscape.
The plan fails to demonstrate how Battle’s infrastructure, which is already under significant pressure, can accommodate this increase. GP surgeries, schools, and our narrow historic road network are not equipped to support this level of growth. The Council should prioritise a lower, locally derived target that reflects the constraints of our protected landscape, in line with national planning policy.

Q8: Overall Development Strategy and the High Weald National Landscape
The strategy to focus growth within the High Weald National Landscape contradicts the Council’s duty to conserve and enhance natural beauty. While the plan refers to prioritising brownfield land, the proposed allocations rely heavily on greenfield development.
The justification that housing need constitutes “exceptional circumstances” for major development in a protected landscape is not convincing. This approach risks eroding the distinct character of Battle and surrounding settlements.

Q36: Proposed Site Allocations in Battle (Policies BT1 to BT11)
Objection to Site BT1: Land south of Hastings Road, Battle
I strongly oppose the allocation of this site for 220 dwellings.
• Traffic and safety: Additional access onto the A2100 and surrounding roads will worsen congestion and increase accident risk.
• Density: A density of 40 dwellings per hectare is inappropriate for this rural edge-of-town location.
• Environmental impact: The proximity to ancient woodland and priority habitats means development would cause significant ecological harm.

Objection to Site BT7: Land at Almonry Farm, Battle
I object in full to the proposed development of this site for 80 dwellings.
• Heritage impact: The site lies close to the 1066 Battlefield and Battle Abbey, and development would harm their setting.
• Listed buildings: The proposals would negatively affect the setting of the Grade II listed Lower Almonry Farmhouse.
• Landscape and biodiversity: The site contributes significantly to the character of the area and supports valuable habitats.
• Flood risk: Development may increase surface water runoff and exacerbate local flooding.
• Safety concerns: Increased traffic near busy junctions and disruption to footpaths used by Claverham students raises additional risks.

Conclusion
The Council must reconsider this scale of development. Our National Landscape and historic heritage should be protected for future generations, not compromised by unsustainable housing targets. I urge the Council to remove sites BT1 and BT7 from the Local Plan

BT1, BT2 BT7. Battle cannot sustain more development on this scale. Biodiversity, historical protected area of national importance. Infrastructure cannot support increase of population by 30%. No reference to building supporting services.

BT10 should be deleted - Whilst some of the sites within or close to town area could be ok, the allocation of BT10 is completely unsuitable and should not be allocated for housing or any kind. It is a semi-rural location, highly sensitive and visible in a rural landscape and is remote from services and facilities, public transport is limited (bus contributions would not assist in any meaningful way) and cycling is not suitable as confirmed in the East Sussex Highway response. It is notable the High Weald Unit object on landscape grounds without any qualification and that is it unsuitable for any development. Thus this should be deleted from the plan and this would be consistent with past comments on this site

See separate document

I believe that houses should not be built at this site as they will ruin the views of the area, and that the road is too narrow to allow cars, and ambulances in both directions at once, as it is a single lane. Also the site is a long way from the town so people will nearly always use their cars to travel to the town centre and shops.

Please see comments erroneously posted under Q2. I wish to comment on BT2. I would like to add the site also abuts an Ancient Woodland.

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

I am writing to formally object to the proposed allocations of the above sites. My
property is near the proposed site BT1 and as such I am very familiar with the land and the factors that will affect any development at this proposed allocation.
There are several vital points that I wish to draw your attention to, as follows.

Site BT1
Location. Boundaried to the north by the A2100 a fast moving (despite the 40mph speed limit) and very busy cross-county road. To the east is Loose Farm and Cedarwood House Care Home. To the south are protected ancient woodland and ponds. And to the west is the Glengorse Estate which is also protected. This area falls within the High Weald National Landscape and designated as an AONB. Only separated by a railway line from the Battle Conservation Area and Registered Battlefield. It is also home to all manner of wildlife (deer, foxes, grass snakes, bats, owls, even nesting pairs of buzzards, and other species) many of which are protected species.
Off Hastings Road is a private lane with houses numbered from 10 to 30 Hastings Road (10 houses in total) most of which back directly onto this parcel of land. The terrain slopes steeply downwards from the northeast and south boundaries into a valley and local water catchment comprising two ponds and virgin ancient woodland. A stream flows out in the valley to the west towards Powdermill. There is no easy access or footpaths into this wooded area and thus a sanctuary for the protected wildlife.
Any road access into this parcel of land could only be gained via an extension to Glengorse or the Marylands Boarding House entrances, both on the A2100 and both impractical and dangerous.

Access and Safety. The A2100 has a 40mph speed limit which sadly is not often adhered to and subject to much debate. It has a pavement on only one side of the road which is comfortably less than 1m wide in several places. Barely wide enough for a mobility scooter, pram/buggy, or walking more than one dog. Residents on the south side of the A2100 HAVE TO cross this dangerous road in order to walk in any direction on the safety of a narrow pavement. There are no schools on the southeast side of Battle but with the new Blackfriars development (200 houses) about to be released time will only tell the increased volume of pedestrian traffic. The pavement CANNOT be widened as several (ancient) properties were built right up to the curb line of the road. Should any development, heaven forbid, be allowed to proceed on site BT1 the only access points for pedestrians or vehicles will be approx. 400m apart, onto a road with no pavement, a 40mph speed limit, and immediately opposite the new Blackfriars (Tapestry) development too. With well over 400 proposed houses over these two developments it will vastly increase the flow onto, and across, an already dangerous road.
The entrances to Marylands, and Hastings Road (lane) both share a Bus Stop layby on the A2100. This in itself has a history of becoming congested at times. It is sited approx. 75m from a blind corner to the right (east) when exiting. Visibility is poor, traffic is normally at maximum permitted speed, and often from the left (Battle) too. Given that the BT1 proposal will generate the flow of an extra 400 vehicles per day, each way, it will add to the expected 400 vehicles per day, each way from the Blackfriars development too. Plus pedestrians crossing the busy road. This is the proverbial “Accidents waiting to happen” scenario. (Both developments are primarily “family homes”, and applying the Laws of Average each home will own two vehicles. If 50% of the vehicles will make at least one journey out, then back, each day this equates to 200 homes, 400 vehicles, and half of which are used daily = 400 journeys).
The road between the Marley Lane level crossing up to the roundabout junction with the A2100 is a notorious bottleneck. Delays at the level crossing, parked cars in the road creating a single lane for all traffic, and poor road surface, have resulted in frustration and anger. As a result the likelihood of the new road through Blackfriars between the Marley Road access and Hastings Road access points will become a “rat-run” will also become a safety hazard and nuisance to residents. It will obviously increase the additional flow of traffic onto and off the A2100 Hastings Road at an already dangerous point.

Having only the one pavement, on only one side of the road (A2100) from Telham to Battle, there are also no cycleways or footpaths. There do not appear to be any plans or intention, or even possibility, in widening the road or pavement. In its current state the road is a danger and unfortunately carries a history of fatalities. To increase traffic flow is neither safe nor good for the environment with the added pollution.

Adjacent Land. Also applies to sites BT8 and BT10. To the North of this proposed allocation is referenced at BAT0021
of the HELAA 2026 and states:
“The site comprises land within two adjoining residential gardens (18 and 20 Hastings Road) adjacent to the development boundary in the southern part of Battle. It was previously assessed through the SHLAA (2013) as being potentially suitable for residential development alongside adjoining land at Glengorse (part of which,
site BAT0110, is now allocated for housing). Its availability was investigated
through the Battle Neighbourhood Plan and the site was at that time found to
be unavailable for development. There is no evidence that this situation has
changed. Furthermore, the site is heavily treed in parts, including a significant
tree belt between it and the adjoining allocated site, which would constrain
any potential developable area. Together these factors mean the site is not
suitable for further consideration.”
It remains true that this land is not available for development, but this parcel of land is less heavily treed than the parcel of land identified in this proposal so one assumes the same rational should exist.

Geology. Geological and Hydrogeological surveys on the land adjacent to the proposed site considered it to be representative of the Tunbridge Wells Sand Formation deposits indicated to underlie the site on the published geological map. This might explain why the HELAA states:
“The eastern part of the site is at risk of surface water flooding which would constrain its development potential’ and the flooding risk across the whole site will be compounded by run off from impermeable surfaces like concrete and asphalt”.

Local infrastructure. Other than minimal shopping (Esso/Tesco), leisure (2 pubs) and the railway station there are few other amenities on the East side of Battle town centre. All schools, health centres, doctors, dentists, shopping, and sport facilities etc are situated from the town centre and to the west. The two main and largest, areas of proposed development are located on the opposite (east) side of the town. This will only drive more traffic through the already tight and congested High Street (A2100) causing more and permanent disruption. Battle is of great historical interest, a centre for tourism, located in a conservation area and AONB. Hence parking is a major problem. Car parks are at capacity, street parking is congesting the side roads and High Street, and addition parking or road widening is impossible. During rush-hour periods the roads into and out of Battle are regularly at a standstill due to excess traffic.
The proposed developments in sites BT1 to BT11 are calling for over 660 properties to be built. Many of which are to be “family homes” with up to 5 bedrooms. This could potentially increase to population (in just this area alone) by 1200 to 1500 people. This excludes any developments currently being built. ie: Blackfriars (200 homes and an additional population of approx. 400). The most recent government survey (2021 census) gives the population of Battle as 6800, which includes an electorate of approx. 5000.

In conclusion, why try to increase the town’s population by approx. 20% within an infrastructure that can hardly cope with what it already has, and on land that is predominantly a “conservation area”, an Area of Natural Beauty (AONB), and a Greenfield national landscape? Furthermore with little regard to human safety.
The proposal of this allocation is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove these proposed allocations.

Yours sincerely

My big concern regarding policy BT7 traffic coming out of Tollgates now with added houses already built is bad enough.
To added traffic of another 80 houses to my mind is crazy. Claverham college near by with the amount of children going
to and fro past Tollgates to me it not safe. The was an incident recently concerning a pupil from Claverham. College
Congestion now is bad enough. The schools dentist and doctors can’t cope now with this proposal

,

Objection to proposed allocation policy BT10
Hastings Road is already struggling with the volume of traffic on this 40mph road. Traffic is backed up throughout the day and drivers regularly exceed the speeding limit. There is a lack of infrastructure. Doctors, dentists, hospitals and local schools are already under extreme pressure. The bus service mentioned is a very limited rural service. The times do not coincide with the start of the school day and it is too far out for pupils to walk on a daily basis in all weathers.
Situated in Telham we are well away from the town, the station and any amenities. The proposed plan will not benefit any residents in this hamlet. The field in question has numerous streams bubbling underneath the ground and runs down to a stream at the bottom of the hill.
Building houses on this site will create a flood risk and replace natural drainage with impermeable road surfaces. This will also impact the existing flora and fauna in the vicinity as well as the environmental impact and the permanent loss of greenfield space. The erection of 65 houses will have a direct impact on Hastings Road especially if they are crowded in towards the top end of the field. The topography of the site does not lend itself to be sympathetic to the surrounding neighbourhood.
Interesting that you propose a footpath and cycle path in the plans. Currently you can only walk along the pavement in single file as there is not enough room on the path and the traffic is extremely fast as it passes by. Especially on this part of Hastings Road where cars accelerate along this section of the A2100.
I went along to the Memorial Hall to view the plans and on the ordnance survey the Blackfriars development is missing from the map, this gives a false impression of the building work currently underway. 200 dwellings in total. That doesn’t take into consideration the proposed plans of 220 properties at Glengorse or 145 at Breadsell Lane.
As you can see I oppose these plans most strongly.

BT8 should not be developed as it provides limited housing (5), but would significantly alter the rural character of the lane which has a listed building, stone barns, and associated 18th century farm cottages (all designated as having historic interest in the Battle Neighbourhood Plan).

Sites much closer to the town (eg BT7, 5-10min walk from the high street) if developed more intensively would remove the need to develop BT8. Developing BT8 would encourage driving, as the site is 1hr 10min walk round trip to the high street with its shops, and more to reach Battle's schools. To walk to the nearest shop (Tesco) is a 50min round trip.

The site should not be developed without a new road provided, as it is too narrow with no separate provision for pedestrians, and the sightlines on to Hastings Road are poor considering traffic speed and volume.

I am writing to formally object to the council’s proposed development of housing on Green Belt land surrounding Battle.
The Green Belt serves a vital purpose in preserving the character, heritage, and environmental integrity of the area. The land around Battle is not only of significant natural beauty but also holds historical importance, contributing to the unique identity of the town and its surrounding countryside. Developing this land would result in irreversible damage to the landscape and undermine the principles of sustainable planning.
Furthermore, the loss of Green Belt land would have serious environmental consequences. These areas provide essential habitats for wildlife, support biodiversity, and act as natural buffers against climate change impacts such as flooding and overheating. Replacing them with housing would increase pressure on already strained ecosystems and local infrastructure.
There are also practical concerns regarding infrastructure capacity. Local roads, schools, healthcare services, and public transport in and around Battle are already under pressure. Additional large-scale housing developments would exacerbate congestion, reduce quality of life for existing residents, and place unsustainable demands on public services.
National and local planning policies emphasise that Green Belt boundaries should only be altered in exceptional circumstances. It is not clear that such circumstances have been demonstrated in this case, particularly when alternative brownfield sites may be available for development without sacrificing protected land.
I strongly urge the council to reconsider this proposal and to prioritise development strategies that protect the Green Belt while addressing housing needs in a sustainable and responsible manner.
Thank you for considering my objection

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

1. Traffic Congestion and Safety on Hastings Road
Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites BT1, BT8 & BT10). The Battle Neighbourhood Plan (Battle NP) explicitly identifies congestion as a critical weakness of the parish. Adding a major junction to this congested stretch without significant infrastructure upgrades is negligent.
Junction Interference and “Staggered” Conflict
At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (250 dwellings) will frequently be blocked up by “tailback” traffic entering or exiting Blackfriars (210+ dwellings). This creates a high risk of “rear‑end” collisions and “side‑swipe” accidents as drivers attempt to navigate merging traffic from two major hubs in such a short span.
The 30mph to 40mph Transition Danger
The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
• Acceleration Risk: Vehicles travelling outbound (towards Hastings) are legally accelerating exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.
Placing two high‑volume junctions in a high‑speed transition zone is fundamentally unsafe. The NPPF Paragraph 115 requires that “safe and suitable access to the site can be achieved for all users.” Given the topography and speed transition here, this requirement cannot be met.
2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT1 proposes building on 11.10 hectares of Greenfield land. This directly contradicts the Battle NP’s vision to prioritise brownfield sites and protect the countryside.
• National Landscape (AONB) Impact:
The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection. A density of 40 dwellings per hectare is urban, not rural, and is entirely out of keeping with the character of the High Weald. Major development should only occur in exceptional circumstances (NPPF Paragraph 189).
• Wildlife and Trees:
The proposal threatens “fields, paddocks” and “High Weald Wildflower Meadow Priority Habitat”. The construction of a minimum of 250 new homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of “buffer zone” promises.

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

3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools)
The town lacks the capacity to support this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out the infrastructure required (education, health, transport, flood and water supply).
• 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 report similarly reporting “increasing demand” and workforce challenges that make future expansion difficult to secure.
• Schools:
The Council’s own supporting text for BT1 admits the site is “some distance from secondary schools” and implies a reliance on “active travel” which is unrealistic given the geography and major traffic conditions.
• Precedent:
We have seen this failure before. The Blackfriars development was approved with promises of infrastructure that have been slow to materialise or insufficient.

The Blackfriars Precedent: “Watered Down” Commitments
We have no confidence in the “policy compliant” assurances for BT1 because we have watched the Council fail to deliver on similar promises at Blackfriars. That development is still awaiting the GP expansion and highway improvements it was promised. The Council, having accepted an £8 million funding bid, later “revised” and downgraded these commitments.
If the flagship Blackfriars project had to be “value‑engineered” due to market pressures, the high‑quality landscape‑led masterplan promised for BT1 is likely to be similarly watered down once development is granted.
Conclusion
This proposal expands development to 250 units on a Greenfield National Landscape site amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove development pressure from this area before progressing the plan further.
Yours faithfully,

I am writing to formally object to the proposed allocations of the above sites. My property borders the proposed site BT1 and we are, therefore, very familiar with the land and the factors that will affect any development at this proposed allocation.
This is a large site at the rear of a ribbon development and is made up of a network of historic sloping fields and scattered woodland located on the southern side of Battle. It forms part of the countryside within the High Weald National Landscape and is an AONB. Its proximity to
heritage assets including the Battle Conservation Area and Registered Battlefield, and a Listed Building are of considerable concern as are the historic field boundaries, ancient woodland and the risk of surface water flooding and compromise of an existing pond. This area provides
a safe environment for a mix of wildlife some of which are protected; badgers, grass snakes, buzzards, newts, bats and owls. The scale of the proposed development would be at odds with the existing, largely linear development pattern and would constitute a large encroachment into the countryside, harming the wildlife, landscape and character of Battle.
Access to the site would be via the Glengorse estate and a proposed new access onto the A2100 Hastings Road through land currently belonging to Marylands Boarding House. Despite the completion of the Bexhill/Hastings Link Road traffic volumes, speeds and congestion along
with the consequential pollution levels remain of significant concern. Furthermore, the new access onto Hastings Road and its close proximity to a blind summit would be a significant hazard. As residents of Hastings Road, we have direct, daily experience of the site conditions. This
development is unsupportable based on material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies).

1. Traffic Congestion and Safety on Hastings Road
Hastings Road (A2100) is already at breaking point. Traffic is backed up every morning and evening, creating a bottleneck that cannot accommodate the additional vehicle movements generated by a minimum of 250 new dwellings (sites mentioned above). The Battle Neighbourhood Plan (Battle NP) explicitly identifies traffic congestion as a critical weakness of the parish. Adding a major junction to this existing chaos without significant infrastructure upgrades is negligent. Junction Interference and "Staggered" Conflict At a distance of less than 200 metres, these two major junctions will interfere with one another. Turning movements into BT1 (250
dwellings) will frequently be blocked by "tailback" traffic existing or entering Blackfriars (210+ dwellings). This creates a high risk of "rear-end" collisions and "side-swipe" accidents as drivers attempt to navigate emerging traffic from two major hubs in such a short span.
The 30mph to 40mph Transition Danger The sites sit at a critical transition point where the speed limit increases from 30mph to 40mph.
• Acceleration Risk: Vehicles traveling outbound (towards Hastings) are legally
accelera2ng exactly where the BT1 entrance is proposed.
• Braking Distance: Vehicles entering the 30mph zone from the south (inbound) often carry higher speeds before decelerating.
Placing two high-volume junctions in a high-speed transi2on 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 transi2on here, this requirement cannot be
met.
2. Environmental Impact and Air Quality
Unjustified Harm to the National Landscape (AONB) and Greenfield Land
• Greenfield Loss: BT1 proposes building on 11.09 hectares of Greenfield land. This
directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the
countryside.
• National Landscape (AONB) Impact: The site is within the High Weald National
Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are
afforded the highest level of protection. A density of 40 dwellings per hectare is urban,
not rural, and is entirely out of keeping with the character of the High Weald. Major
development should only occur in exceptional circumstances (NPPF Paragraph 189).
• Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald
Wildflower Meadow Priority Habitat". The construction of a minimum of 250 homes
will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer
zone" promises.
• Flooding Risk and Surface Water (NPPF Paragraph 170) The policy text for BT1
explicitly acknowledges a "surface water flooding risk to the southern boundaries of
the site". Replacing natural drainage (fields) with impermeable surfaces
(housing/roads) on 11 hectares of land already identified as a flood risk is reckless
planning that endangers existing properties downhill, contradicting NPPF Paragraph
170 and failing the current Climate Resilience tests.
3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools) The town lacks the capacity to support
this population increase. The NPPF (Para 35 and 20) requires Local Plans to set out other
infrastructure required (Education, health, transport, flood and water management)
• Medical: East Sussex is currently facing a documented "dentistry crisis" with reports
indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are
similarly reporting "increasing demand" and workforce challenges that make
appointments difficult to secure.
• Schools: The Council’s own supporting text for BT1 admits the site is "some distance
from primary schools" and implies a reliance on "active travel" which is unrealistic
given the topography and traffic conditions.
• Precedent: We have seen this failure before. The Blackfriars development was
approved with promises of infrastructure that have been slow to materialise or
insufficient.
The Blackfriars Precedent: "Watered Down" Commitments We have no confidence in the
"policy compliant" assurances for BT1 because we have seen the Council fail to deliver on
similar promises at Blackfriars. That development was sold as a "gold standard" of green, hightech
housing. However, documents show it faced an £8 million funding gap and underwent
"redesign" to "better align with market demand" and "improve efficiencies" due to rising costs.
If the flagship Blackfriars project had to be value-engineered due to market pressures, the
high-quality, landscape-led masterplan promised for BT1 is likely to be similarly watered down
once permission is granted.
Conclusion
This proposal expands development to 220 units on a Greenfield National Landscape site
amidst an infrastructure crisis. The plan is unsound as it ignores statutory environmental
duties and local experience. I urge the Council to remove development pressure from this area
before progressing the plan further.

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

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

This development is unsupportable based on many aspects including material planning considerations, the democratically adopted Battle Neighbourhood Plan (BNP), and the National Planning Policy Framework (NPPF) 2024/25 (and the subsequent 2025/26 updates regarding National Decision-Making Policies). This site has been rejected in the past on three occasions, so it is unfathomable as to why it is now deemed as a suitable site.

I list below my objections and reasoning below:

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

On review of the Draft Rother Local Plan online and at the recent meeting held at Battle Memorial hall meeting I noticed that the map included in the Draft Rother Local Plan does not include the already built Blackfriars development.
To anyone resident in the local area Blackfriars development is a significant housing project providing 200 new homes, covering 16 hectares of our town. The Rother District Council website itself has maps of the Blackfriars development and detailed information about the development yet it is not included in the very important Rother Draft Plan. This is deceiving and dishonest.
To any lay person or government decision maker who views the Draft Rother Local Plan this lack of clarity and honesty is deceiving and could lead to decisions being made on factually incorrect information. This development already provides over 200 homes and is already adding to the burden faced by local residents in terms of infrastructure and local amenities.
The Draft Rother Local Plan should not have been published with this inaccurate map as it does not show the current level of development in our historic town that has already taken place and the difficulties already being faced by current residents in terms of additional housing, inadequate infrastructure and stretched services.
I have raised this concern to our local MP. It is hoped he will raise this further in upcoming meetings to be the voice of his constituents where I have raised this as a concern.

2. Traffic Congestion and Safety on Hastings Road

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

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

Cycle path and improvements to pedestrian infrastructure If any member of Rother District Council has walked along Hastings Road (A2100) in recent times they will notice the narrow nature of the existing pavements and the road itself. How improvements could be made to the pavement including a cycle path gives me great cause for concern. Local residents currently have to walk single file at some points along this road whilst on the pavement due to the narrow path and overgrown hedges. Cars speed along the road at times perilously close to pedestrians and dangerously overtake along this section of road. In addition to this, there is also detail in the plan suggesting improved or creating cycle links. Where this cycle path would fit along the A2100 in a safe and sustainable way is beyond me. As a local resident who walks along this road frequently it is a hazard and not a safe area. There must be other sites that would already have space for cycle paths, better links or already be closer to amenities.
Crossing BT10 proposes to “include a crossing point” along Hastings Road. This is quite frankly a ludicrous suggestion and one that could cause major issues for vehicles and pedestrians alike. As mentioned above this is a 40mph stretch of road and is quite unsuitable for any proposed installation of this kind. The suggestion of including a crossing at this point on the A2100 in line with this proposed development could pose a risk to life.
3. Environmental Impact
Unjustified Harm to the National Landscape (AONB) and Greenfield Land

Greenfield Loss: BT10 proposes building on 5.75 hectares of Greenfield land. This directly contradicts the Battle NP's vision to prioritise brownfield sites and protect the countryside.
National Landscape (AONB) Impact: The site is within the High Weald National Landscape (formerly AONB). Under NPPF Paragraph 190, National Landscapes are afforded the highest level of protection – much like that of a national park so why is this location even included in the plan? In addition, the suggestion of 30 dwellings per hectare is surely urban in nature, not rural, and is entirely out of keeping with the character of the High Weald and the local surroundings. Major development should only occur in exceptional circumstances and this proposal is not exceptional.
Wildlife and Trees: The proposal threatens "fields, paddocks" and "High Weald Wildflower Meadow Priority Habitat". The construction of a minimum of 65 homes will inevitably sever wildlife corridors and destroy hedgerows, regardless of "buffer zone" promises. It is also interesting to note that there is much wildlife in this area including bats, deer, badger sets, foxes, hedgehogs and other small mammals. We cannot afford for natural habitats in a rural setting to be destroyed.
Ancient woodland BT10 is edged by ancient woodland and hedgerows that would be destroyed with any building on this land despite promises made. Ancient woodland should remain. Battle is a historic town and we have a right now and for future generations to protect our green areas.
Flood Risk and Surface Water (NPPF Paragraph 170) The policy text for BT10 explicitly acknowledges this as an “area at risk of surface water flooding". Replacing natural drainage (fields) with impermeable surfaces (housing/roads) on hectares of land already identified as a flood risk is reckless planning that endangers existing land and homes. On this particular site there is a central natural stream and underground water table. This is heard underfoot at all times of year and poses a significant risk to any potential development on this site. The topography of this piece of land is sloping and not suitable for building.
3. Infrastructure Deficits and Delivery Failures
Critical Lack of Infrastructure (GP, Dentistry, Schools) Our historic town lacks the capacity to support this population increase which would be inevitable with the level of proposed sites in Battle and the surrounding area. The NPPF (Para 35 and 20) requires Local Plans to set out other infrastructure required (Education, health, transport, flood and water management). None of which have been documented in detail in this plan.

Hospitals: Local NHS Organisations are at breaking point with demand far exceeding capacity. I work in the local NHS Trust and have for over 20 years. I have first-hand experience of the difficulties faced in terms of demand on the services and lacking capacity to care for our local population as it currently stands, not withstanding any influx of people moving into our historic town and using local facilities.
Schools: The Council’s own supporting text for BT10 does not even broach the significant distance from our towns primary schools and secondary schools BT10 as a development site is located. This implies a reliance on "active travel" which is unrealistic given the topography and traffic conditions along Hastings Road. The site is location over 1.5 miles away from any local amenities therefore requiring substantial investment to be made in pavements, cycle lanes, improved transport links and better roads which are just not suitable when there are other sites in the town that are closer to amenities and already have been placed links for the residents.
Medical: East Sussex is currently facing a documented "dentistry crisis" with reports indicating 8 in 10 NHS dentists are not accepting new patients. GP practices are similarly reporting "increasing demand" and workforce challenges that make appointments difficult to secure.
Transport links: BT10 is also “some distance from Battle train station”. There are sites much closer to our local schools and with better transport links. A bus stop is documented as being close to the entrance of the site of BT10. This bus service is far from frequent and does not provide wide links to the surrounding area. It is also an extremely limited service. With increased traffic in the area this will not be a suitable solution for any prosed additional population.
Further concerns about the proposal for site BT10 is the suggestion of “limiting development to the north-eastern section (closest to existing ribbon development) will serve to limit the effect on the settlement pattern”. This will involve building along the eye line of current homes which is not in keeping with this area and surely a concern for planners. This is more of an issue when you consider how this development site can be seen from other roads in the area, including Telham Lane. Most houses along this stretch of the A2100 are built since 1930 onwards and any development on BT10 would be most out of keeping and not subtle to the local area or home owners along this road, who take great pride in their homes and gardens.
BT10 presents me with further grave concerns that larger scale identified locations within Battle and surrounding areas may not proceed, but a ‘smaller’ development like the one proposed for BT10 would then be given the green light to proceed, as smaller in scale and decision makers would suggest less impact. For all the reasons stated above this is not the case and the impact of 65 houses on this small agricultural field would be huge from all aspects that I have mentioned in this correspondence.
Summary of objection:
This proposal expands development on a Greenfield National Landscape site amidst an infrastructure crisis.
There are other sites outside of our historic town of Battle that would be much more suitable with better access to existing infrastructure and sites that would have less environmental impact on the surrounding areas. There are even areas that should be considered outside of Battle and the surrounding area that would be suitable to East Sussex residents rather than ruining our beautiful historic town for us and future generations.
The Draft Rother Local Plan is unsound as it ignores statutory environmental duties and residents lived experience. I urge the Council to remove development pressure from the plan specifically BT10 before progressing the plans any further.

We are concerned about the Draft Local Plan for Battle, specifically regarding BT10, as our property is centrally located (No124) within the proposed designated area and is at risk from substantial reduction in marketability.
Key issues include increased traffic from the development, impact on local wildlife, flood risk, and detrimental effects on local amenities due to overdevelopment.
The BT10 development of 65+ dwellings will markedly increase the traffic on Hastings Road, and our historic town.
The overdevelopment that has been identified in the Draft Local Plan will clearly have a detrimental impact on the local amenity and the environment. This is not a few houses but a large increase in housing stock on a small town.
There is a lack of detail in the Draft Local Plan about additional infrastructure needed to support the proposed zones, such as schools, health centres, and roads.
For the above reasons, we object.

I am formally objecting to the council’s proposed development of housing on Green Belt land around Battle.
The Green Belt serves a vital purpose in preserving the character, heritage, and environmental integrity of our countryside. This land is not only of significant natural beauty but also is of historical importance, contributing to the unique identity of the area. Developing it would result in irreversible damage to the landscape and undermine the principles of sustainable planning.
The loss of Green Belt land would have serious environmental consequences. These areas provide essential habitats for wildlife, support biodiversity, and act as natural buffers against climate change impacts such as flooding and overheating. Replacing them with housing would increase pressure on already strained ecosystems and local infrastructure.
There are also practical concerns regarding infrastructure capacity. Local roads, schools, healthcare services, and public transport in and around Battle are already under pressure. Additional large-scale housing developments would exacerbate congestion, reduce quality of life for existing residents, and place unsustainable demands on public services.
National and local planning policies emphasise that Green Belt boundaries should only be altered in exceptional circumstances. It is not clear that such circumstances have been demonstrated in this case, particularly when alternative brownfield sites may be available for development without sacrificing protected land.
I strongly urge the council to reconsider this proposal and to prioritise development strategies that protect the Green Belt while addressing housing needs in a sustainable and responsible manner.
Thank you for considering my objection

I object wholeheartedly to this planned development at site BT10.
This is not a brownfield site - should be dismissed.
This is a rural landscape and should remain - not urbanised.
This field is not suitable for a medium scale residential development.
Additional vehicular access points (two of which are drawn on the diagram - not just one that is mentioned in the text) will be dangerous to road users and pedestrians. Along with the impact additional vehicles will have on local residents on the A2100 and road users through the town.
This proposal will complete destroy the local hedgerows and an area of ancient woodland. Any development will also have a disastrous effect on our local wildlife.
The site is already highlighted as a risk of surface water flooding. It would be negligent to proceed with the proposal at BT10 because of the environmental impact on the local area and also any subsequent impact on already existing properties along the existing development.
BT10 is nowhere near local town facilities or amenities. It is well outside of the historic town of Battle, in a small hamlet type area known as Telham. Telham has no amenities and is not therefore suitable for development.
The train station, shops, schools, Doctors surgery and key facilities are more than 1.5 miles away.
The suggestion of a crossing to be included and cycle path is farcical given the narrow nature of the pavements and road and in addition the 40mph speed of the A2100 at this section. In the past there have been fatal accidents along this road and the suggestions made in the text for BT10 have been made without good research or review by the relevant companies.
Inaccurate graphs and maps included in the plan. No mention of the Blackfriars development on any of the maps of Battle included in the plan. This does not allude development already underway in our historic town which should also be taken into consideration when any of these sites are discussed. Summary text of BT10 and other proposed sites, does not match with the diagrams (2 vehicle access points on the diagram (BT10) only 1 access point discussed in the text).
I strongly object to this proposed development site.

I am writing to formally object to the proposed allocations of the above sites. My property borders the proposed site BT1 and we are, therefore, very familiar with the land and the factors that will affect any development at this proposed allocation.
This is a large site at the rear of a ribbon development and is made up of a network of historic sloping fields and scattered woodland located on the southern side of Battle. It forms part of the countryside within the High Weald National Landscape and is an AONB. Its proximity to heritage assets including the Battle Conservation Area and Registered Battlefield, and a Listed Building are of considerable concern as are the historic field boundaries, ancient woodland and the risk of surface water flooding and compromise of an existing pond. This area provides a safe environment for a mix of wildlife some of which are protected; badgers, grass snakes, buzzards, newts, bats and owls. The scale of the proposed development would be at odds with the existing, largely linear development pattern and would constitute a large encroachment into the countryside, harming the wildlife, landscape and character of Battle.
Access to the site would be via the Glengorse estate and a proposed new access onto the A2100 Hastings Road through land currently belonging to Marylands Boarding House. Despite the completion of the Bexhill/Hastings Link Road traffic volumes, speeds and congestion along with the consequential pollution levels remain of significant concern. Furthermore, the new access onto Hastings Road and its close proximity to a blind summit would be a significant hazard.
Land adjacent and to the North of this proposed allocation is referenced at BAT0021 of the HELAA 2026 and states:
‘The site comprises land within two adjoining residential gardens adjacent to the development boundary in the southern part of Battle. It was previously assessed through the SHLAA (2013) as being potentially suitable for residential development alongside adjoining land at Glengorse (part of which, site BAT0110, is now allocated for housing). Its availability was investigated through the Battle Neighbourhood Plan and the site was at that time found to be unavailable for development. There is no evidence that this situation has changed. Furthermore, the site is heavily treed in parts, including a significant tree belt between it and the adjoining allocated site, which would constrain any potential developable area. Together these factors mean the site is not suitable for further consideration.’
It remains true that this land is not available for development but this parcel of land is less heavily treed than the parcel of land identified in this proposal so one assumes the same rational should exist.
This proposed site is further from the Town’s amenities and given there are no cycle paths and public transport and footpaths are limited, more private vehicles would be used to access these amenities thereby adding to already unacceptable congestion and pollution.
Furthermore, anyone wishing to walk to town would have to cross the busy highway as the
footpath is to the North of Hastings Road. Some parts of the footpaths narrow to barely a meter with no simple remedy making it only suitable for single file usage and exceedingly dangerous for wheelchair users and parents escorting young children. This is compounded further by vehicles parking on the footpaths to try and avoid adding to the traffic congestion.
There is no footpath on the South Side of Battle Hill and Hastings Road and all residents living along this part of road need to cross this very busy road to walk anywhere. Sadly, this has already resulted in fatalities. The addition of around 220 houses to the South of the A2100 would significantly increase the crossing risk.
Geological and Hydrogeological surveys on my neighbours land adjacent to the proposed site considered it to be representative of the Tunbridge Wells Sand Formation deposits indicated to underlie the site on the published geological map. This might explain why the HELAA states ‘The eastern part of the site is at risk of surface water flooding which would constrain its development potential’ and the flooding risk across the whole site will be compounded by run off from impermeable surfaces like concrete and asphalt.
In conclusion, this proposed site expands development to 220 units on a Greenfield National Landscape site amidst an infrastructure crisis. The proposal of this allocation is unsound as it ignores statutory environmental duties and local experience. I urge the Council to remove this proposed allocation.

I object to the allocation of Policy BT2 (Land at Breadsell, Battle) as it is unsound and premature. The Council acknowledges that development may harm the Marline Valley Woods SSSI, with impacts currently uncertain pending further ecohydrological monitoring. Allocation without this evidence conflicts with national policy protecting designated sites.

The site is environmentally constrained, adjoining the High Weald National Landscape, ancient woodland, and local wildlife sites, creating a high risk of irreversible harm. It is also acknowledged to be in an unsustainable location, poorly related to services and reliant on uncertain cross-boundary development with Hastings, undermining deliverability.

Development would erode the Strategic Gap between Battle, Crowhurst, and Hastings, harming settlement identity. In addition, access via the A2100 raises highway safety concerns and is not conducive to sustainable transport.

The site is therefore unjustified, undeliverable, and inconsistent with sustainable development principles and should be removed from the Plan.

Subject: Formal Objection to the Rother Local Plan 2025–2042 (Regulation 18 Consultation)

To the Planning Strategy Team,

I am writing to submit my formal objection to the proposed Rother Local Plan 2025–2042. As a resident of Battle, I am deeply concerned that the current proposals represent an unsustainable level of growth that will irreparably damage the historic character, landscape integrity, and infrastructure of our market town.

My specific objections, referenced by the relevant consultation questions, are outlined below:

Q2: Proposed Housing Target (Policy 3.24 / Figure 2)
I strongly object to the proposed housing target of 8,427 dwellings. The move to a “standard method” calculation of 912 units per year — a threefold increase over previous targets — is fundamentally incompatible with a district where 83% of the land is protected within the High Weald National Landscape.

The plan fails to demonstrate how Battle’s infrastructure, which is already under significant pressure, can accommodate this increase. GP surgeries, schools, and our narrow historic road network are not equipped to support this level of growth. The Council should prioritise a lower, locally derived target that reflects the constraints of our protected landscape, in line with national planning policy.

Q8: Overall Development Strategy and the High Weald National Landscape
The strategy to focus growth within the High Weald National Landscape contradicts the Council’s duty to conserve and enhance natural beauty. While the plan refers to prioritising brownfield land, the proposed allocations rely heavily on greenfield development.

The justification that housing need constitutes “exceptional circumstances” for major development in a protected landscape is not convincing. This approach risks eroding the distinct character of Battle and surrounding settlements.

Q36: Proposed Site Allocations in Battle (Policies BT1 to BT11)

Objection to Site BT1: Land south of Hastings Road, Battle
I strongly oppose the allocation of this site for 220 dwellings.

Traffic and safety: Additional access onto the A2100 and surrounding roads will worsen congestion and increase accident risk.

Density: A density of 40 dwellings per hectare is inappropriate for this rural edge-of-town location.

Environmental impact: The proximity to ancient woodland and priority habitats means development would cause significant ecological harm.

Objection to Site BT7: Land at Almonry Farm, Battle
I object in full to the proposed development of this site for 80 dwellings.

Heritage impact: The site lies close to the 1066 Battlefield and Battle Abbey, and development would harm their setting.

Listed buildings: The proposals would negatively affect the setting of the Grade II listed Lower Almonry Farmhouse.

Landscape and biodiversity: The site contributes significantly to the character of the area and supports valuable habitats.

Flood risk: Development may increase surface water runoff and exacerbate local flooding.

Safety concerns: Increased traffic near busy junctions and disruption to footpaths used by Claverham students raises additional risks.

Conclusion
The Council must reconsider this scale of development. Our National Landscape and historic heritage should be protected for future generations, not compromised by unsustainable housing targets. I urge the Council to remove sites BT1 and BT7 from the Local Plan.

BT11 I welcome the addition of additional affordable dwellings, possibly above a supermarket, but not at the expense of reduced car parking facilities, currently at a premium in the town, for local community or visiting tourists. Current supermarket is very convenient, assessable by car and foot for locals. No "convenient" parking or trolley service at other supermarket.
Centre of market site and band stand should be open access for local community for many activities or everyones enjoyment. Do not destroy the site by creating more commercial and residential units which will inevitably encroach on the current facilities provided.
Delivery, Coach, school, visitor parking essential for commercial, local and tourist trade. Sufficient parking and a doctors surgery should be included in any future plans.

Any proposed planning should be in keeping with RDCs Working towards Excellence Part 5 General development Considerations.
5. GENERAL DEVELOPMENT CONSIDERATIONS. 5.1 to 5.40

The proposed sites at B1,8 and 10 will increase traffic on an already very busy road through Battle. Important wildlife habitats will be destroyed. Pressure on local services such as medical and educational would increase. Battle's character as an historic market town and tourist attraction, vital to its economic health, would be at risk. The effect of recent developments such as Blackfriars has yet to be assessed.

The proposed Rother Plan for Battle is absolutely ridiculous!! No thought has gone into the infrastructure of roads, schools, doctors or hospital!! All of these are already overwhelmed and causing distress to our residents!! Environmental impact studies are necessary on all respective sites! More consultation with residents, East Sussex Council Highways and landowners is necessary. As a community we need to have the option to see and discuss all these plans at a public meeting!

[personal details redacted]

We have no idea what is planned for the Bt11 site. How can the businesses within the area plan our futures with this hanging over them.You must have an idea as to what is going into the site. You are possibly taking the car parks to build on, what about coach parking? It’s really mean to have this hanging over a site without informing the businesses involved about their future. How many actual local families will be allocated the new homes? What’s going to happen to the businesses within the BT11 site? At what point will they be informed?

Fails to demonstrate safe and suitable highway access Would increase traffic and highway safety risks on Hastings Road Would cause harm to the High Weald National Landscape Places additional pressure on already constrained infrastructure Is located in a position that is not sustainably connected to services For these reasons, the allocation does not meet the requirements of national planning policy, statutory landscape protection duties, or the tests of soundness.

We are writing on behalf of Miskin Land Bare Trust (“MLBT”), in conjunction with Wates Developments, in response to Rother District Council’s Regulation 18 consultation on the emerging Local Plan 2025-2042. Our submission concerns land proposed to be allocated under Policy BT2, Land at Breadsell, Battle, which lies immediately north of a wider area of land within Hastings Borough to the south, identified as a ‘Potential Development Area’ within the emerging Hastings Local Plan.

Our Client’s landholding forms the northern component of Breadsell Farm which spans the administrative boundary between Rother District Council (“RDC”) and Hastings Borough Council (“HBC”). Both sites are identified as prospective development sites, as set out below:

• Emerging Rother Local Plan Policy BT2 identifies an indicative capacity of “some 145” dwellings on c. 6.95ha, at around 35 dph across a developable envelope of c. 4.17 ha, based on comprehensive delivery with adjoining land to the south.
• HBC’s Regulation 18 draft (February 2026) identifies the adjoining land as Policy D1 which identifies a ‘Development Potential Area’ of 12.03ha (net developable) with a minimum indicative capacity of 360–540 dwellings at 30 - 45dph, subject to masterplanning, in liaison with RDC.

We submit that BT2 should be allocated within the Rother Local Plan as an integral part of the wider Breadsell Farm area. This would make an important contribution to Rother’s housing land supply and assist Hastings in meeting its identified need, consistent with national policy and the authorities’ emerging strategies.

We fully endorse the comments made by Wates in relation to BT2.

Housing Need and the Extent of Shortfall

RDC’s emerging Local Plan confirms that its housing requirement as set out by the Standard Method 2024 is 912 dwellings per annum (dpa), equating to an identified need of 15,504 dwellings over the plan period between 2025–2042. Against this, the Council’s emerging Local Plan Development Strategy proposes provision for a minimum of 7,881 dwellings to 2042, leaving a shortfall of some 7,623 homes. On any view this is a significant gap that requires every suitable, available and achievable site to be retained in the supply.

HBC’s Regulation 18 draft proposes a housing requirement baseline of 3,141 - 3,373 net new homes to 2041 against a Local Housing Need as calculated using the 2024 Standard Method of c. 697 dpa (equivalent to 12,546 over the lifetime of the plan). This represents a substantial shortfall of 73% which has resulted in Matthew Pennycook writing to HBC asking that they ensure that ‘no stone is left unturned in its efforts to identify land that is suitable for development’.

Whilst not a matter for RDC we note that HBC have identified the area of land within their District as being a ‘Development Potential Area’ rather than a formal allocation. With RDC only meeting 50% of its housing need and HBC only 27%, clearly both Councils should be using all available means to increase supply. The easiest means to achieve this would be for HBC to formally allocate D1 to immediately contribute to its housing land supply. This underlines the need for a coordinated approach at Breadsell Farm, where capacity and delivery will be most efficiently unlocked through allocation of BT2.

Policy BT2 – Land at Breadsell

It is submitted that land at Breadsell is suitable for allocation.

Site Context

Breadsell Farm is located within the northwestern fringes of Hastings, south of Hastings Road and can currently be accessed off Breadsell Lane. At present the site comprises predominantly arable land with a small area of woodland and individual trees located along a field boundary. The area to the north of the site (on the opposite side of Hastings Road) comprises the Beaufort Park Golf and Country Club (which lies within the High Weald AONB), the areas to the south and west are further agricultural land, and the area to the east comprises the built-up area of Hastings.

Environmental Characteristics

The site is not subject of any landscape or environmental designations. There are no designated or undesignated heritage assets in proximity to the site. The site lies wholly within Flood Zone 1, i.e. it has the lowest probability of flooding. It is noted that the Marline Valley Site of Special Scientific Interest (SSSI) is located south of the Site, this designation is discussed further below. With regards to the site’s environmental characteristics, we therefore note as follows:

• The site is not within any ecological protection area other than for the impact risk zone of the Marline Valley Woods SSSI (discussed below)
• The site is not located within an area designated for its landscape value (although it does sit adjacent to and within the setting of the High Weald National Landscape)
• The site does not include heritage assets, nor would its development likely affect the setting of any heritage assets.
• The site has very few landscape features other than a block of woodland to the southeast and trees and hedgerows to the site boundaries. It is anticipated that development of the site would wholly retain these landscape features other than need for hedgerow removal to facilitate a site access. There will be ample opportunities within the site to provide replacement hedgerow planting.
• The site is not located within an area designated for its ecological interest. It is anticipated that a 10% net gain in biodiversity would be achieved on site as part of a future development.
• The site is located within Flood Zone 1 and is within an area of low risk to surface water flooding.
• An access strategy has been developed by Wates (see Wates Vision Document), confirming that a suitable access on to the A2100 could be achieved.

As set out above, the site is currently accessed from Breadsell Lane which comprises a Public Right of Way providing connectivity through the Site to Queensway and the Castleham Industrial Estate. There are two bus stops located close to the access of the site along Hastings Road (reachable from the site along a footpath), which provide hourly services to shops and facilities, both locally and within Bexhill, Battle, Hastings, and St. Leonards. The site is also within a 5 km cycle distance to Battle and Crowhurst Railway Stations, with Battle Railway Station providing regular mainline services to London. The site is also a 2.5 km cycle to retail facilities within Hastings Retail Park, Sedlescombe Road. From a transport perspective it can be concluded that new residents will have opportunities to reach facilities and services by means other than private motor car, which will be further enhanced by the proposed development.

Marline Valley Wood SSSI

The site lies adjacent to the Marline Valley Woods SSSI, this led to the proposed strategic allocation west of Hastings not being progressed during the last Local Plan examination due to concerns raised by Natural England. The SSSI is designated primarily due to the area featuring steep sided gill woodlands and Bryophyte plants. The main concerns raised by Natural England relate to potential impact on watercourses within the SSSI because of alterations to natural drainage patterns within its catchment area.

The Vision Document submitted by Wates confirm that they are working with both RDC, HDC and Natural England on a programme of ecohydrological monitoring, undertaken by Hilson Moran, to establish the baseline hydrological conditions supporting the SSSI. This data will inform a drainage strategy designed to maintain existing surface water and sub-surface flow patterns, demonstrating that development can proceed without adverse impacts on the SSSI.

Highways and Sustainability

Land at Breadsell Farm lies just to the west of the built-up area of Hastings and can be accessed directly from Hastings Road. It is noted that a good bus service operates within walking distance from the site offering hourly services to Battle and Crowhurst railway stations, as well as to the town centres of Battle and Hastings. The site is also within cycling distance to areas of employment. The development of additional housing in this area could support the sustainability of existing and additional shops and services within the local area. There are opportunities to provide connectivity from the site to the PRoW network to provide pedestrian access to Hastings, in addition to the existing connectivity along Hastings Road.

The Vision Document submitted by Wates demonstrates how a Sustainable Transport Strategy would be adopted for the site which will enhance local transport and public access infrastructure for existing and proposed residents. Therefore, our view is that development of the site for housing would be acceptable from both a highway and transport perspective. It can be concluded that development of the Site would be supported by a range of sustainable transport modes that would provide accessibility to a range of shops and services within Hastings and Battle. Consequently, it is considered that there would be no transport and access grounds that would prohibit delivery of the Site for housing.

Landscape Impacts

Whilst the site is located adjacent to the High Weald National Landscape the site is well contained by existing development and hedgerows to its western boundary. The Landscape Visual Impact Assessment prepared for previous submissions to past versions of plan preparation confirms that the site is well contained and that its development for housing would only have significant negative impacts from a single viewpoint close to the site (as expected for any proposal introducing development to a greenfield site). However, providing that a suitable landscaping scheme is utilised, the site would be suitable for residential development.

It should be noted that Land at Breadsell lies within a small area of the District that is not constrained by the High Weald National Landscape, or by other locally or nationally recognised designations. The proposal for developing this site would be considerably less harmful than many other locations within Rother. Consequently, delivery of this Site for housing would assist in reducing the pressure to develop more sensitive sites in the District.

Conclusion and Summary

Given the scale of identified housing need in both authorities and the substantial shortfall between need and planned provision, BT2 makes an important contribution to housing land supply within Rother. Importantly it will also assist in the delivery of land within Hastings. Our Client has an agreement with Wates to promote this site as part of a comprehensive development at Breadsell Farm.

As set out in the Vision Document submitted by Wates, BT2 is not subject to any landscape, heritage or ecological designation, lies wholly within Flood Zone 1, and is capable of being served by a satisfactory vehicular access from the A2100 Hastings Road. An initial landscape appraisal (see Wates Vision Document) has confirmed that, subject to an appropriate landscaping scheme, the site can accommodate residential development without giving rise to unacceptable landscape harm. Critically, the site lies within one of the few areas of Rother District that is not constrained by the High Weald National Landscape or other nationally recognised designations, meaning that its development would be considerably less harmful than many alternative locations.

In summary, the allocation of BT2 is strongly supported by national policy and the emerging evidence base of both local planning authorities. The site is suitable, available and achievable. It would deliver much-needed housing in a sustainable location, assist both Rother and Hastings in addressing their acute housing shortfalls, and represents a logical and efficient use of land that is less constrained than the vast majority of the District. Our Client supports the allocation of BT2 within the Rother Local Plan 2025–2042 and looks forward to continuing to work proactively with Hastings Borough Council to ensure the comprehensive and coordinated delivery of the wider Breadsell Farm site.

Please see attached the original letter version of the submission with full formatting.

BT8 - Fails to demonstrate safe and suitable highway access Would increase traffic and highway safety risks on Hastings Road Would cause harm to the High Weald National Landscape Places additional pressure on already constrained infrastructure Is located in a position that is not sustainably connected to services For these reasons, the allocation does not meet the requirements of national planning policy, statutory landscape protection duties, or the tests of soundness. I therefore respectfully request that Site BT8 be removed from the Local Plan.