Playden WI Hall has served the local community for many years and is currently used for meetings, local elections, workshops, parties, yoga classes, line dancing, puppy classes and fundraising events. Its closure would have a negative impact on many local residents, not least the mostly elderly members of the Playden Women's Institute.
We do not object to new housing in principle - we would certainly welcome new WI members and new hall users - however, without the required parking, there won't be a WI Hall to use, and there may not be a Playden WI.
The suggestion that any loss of parking provision would be replaced appears somewhat unrealistic when it is already hard to imagine how 25 new houses, and the 25-50 cars belonging to the residents of those new houses, would be accommodated in such a small space (hardly in keeping with the historic rural village setting).
At the landowners request, the WI car park is also used as an overflow car park by the Waterworks Brewery & Taproom, which is a very popular local venue, with regular live music events, so that's another local business that could be adversely affected by the loss of the existing car park.

I object to the inclusion of the site on New England Lane (PL2) in Playden. The site is directly opposite a field where planning was rejected very strongly by the planning inspectorate on appeal. One of the reasons given for the rejection was the importance of maintaining the green separation between Playden and Rye.

PL2 Land between Saltcote ...... The same objections as made for RR/2025/1849/FULL may well apply especially if this damaging application is given approval. If development in PL2 is to take place there should be robust protections to prevent subletting / Airbnb and non-primary homes to prevent them being investments that are to the detriment of retail footfall and empty properties for extended periods that do not lead to a sense of community.

Price points - any development should be within the affordability of first time buyers.

PL1 & PL2

My previous comments, submitted on 22/07/2024 to oppose application PLA0008 (now PL2), still stand. In summary:

I understand the need for more housing, but surely there are sites better suited to such proposals? The suggested size of both developments is completely out of proportion: a density of 15 properties on the PL2 site and 25 on PL1 site is without precedent when viewed against the existing built environment.

With regard to PL2 in particular, there is very limited vehicle access to New England Lane (a narrow historic single-track lane set in a hollow way). Services infrastructure is already inadequate, in particular drainage, which already fails to cope with the discharge from the existing dwellings on the lane. As access to Rye town and its amenities requires a car (public transport is very limited), hardstanding for upwards of 15 vehicles will only exacerbate this issue.

PL1: Land South of Poppyfields and Corner House

In the 'Policy Reference' and then the 'Policy Text' point 8 states:

"viii. Protect the setting of the Grade II listed building “Corner House” (also known as the Playden Oasts Hotel) to the north-west of the site".

1. The Corner House and the Playden Oasts Hotel are 2 separate properties approximately a third of a mile apart.

2.
The Corner House is NOT Grade II listed.
The Playden Oasts Hotel is Grade II listed.

In the 'Policy Reference' and then the 'Policy Text' point 8 states:

"viii. Protect the setting of the Grade II listed building “Corner House” (also known as the Playden Oasts Hotel) to the north-west of the site".

1. The Corner House and the Playden Oasts Hotel are 2 separate properties approximately a third of a mile apart.

2.
The Corner House is NOT Grade II listed.
The Playden Oasts Hotel is Grade II listed.

PL1 - I object to this proposed development for a number of reasons: -
Houghton Green Lane is a very narrow road that is already too busy with not enough passing spaces (it is single lane in a number of areas), in a badly kept state, floods in areas and also where it exits on to the A268 in a busy location (Iden road joins very nearby) where there are frequent near misses (horns heard / tyres skidding etc.) and also actual accidents. This development would result in a huge increase in traffic during construction and also from the new occupiers once complete.
Local amenities - none nearby.
Local schools full.
Water supplies and drainage concerns.
Doctors surgeries already struggling to cope.
A 25 home development would also be completely out of keeping with the rural nature of this area.

The Playden site, PL2, should not be earmarked for development. Planning permission for houses (24 and 9 respectively) has twice been sought and both times refused and the subsequent appeals dismissed. The reasons for this from the Planning Inspector were identical in each instance. Please see applications RR/2017/1450/P; APP/U1430/W/18/3210776 and RR/2020/339/PIP; APP/U1430/W/20/3271590. These reasons are still valid.

PL1
Houghton Green Lane is a narrow, winding lane that already experiences significant traffic due to the Primary School and as a cut through to Military Road. The lane has no footpath and very few passing places. A new development of houses would increase regular traffic (homeowners, visitors and delivery vehicles) and cause more damage to the condition of the lane. Furthermore, the junction at the top of the lane is narrow and difficult since it leads on to 2 busy main roads (A268 & B2082). Finally, the proposed entrance via the WI Car Park is not safe - the entrance is on a slope and the sightlines are very poor, particularly looking down the lane.

Parish Council Comments on proposed housing at PLA1.

Playden Parish Council objects to the proposed housing at this site for the following reasons:

• The proposed access onto Houghton Green Lane is unlikely to meet highway visibility requirements due to bend in the road. Currently there is a layby with cars parked which restricts the road width at the corner. These car spaces are required by local residents.
• The Lane joins the main A268 very close to the junction of the Iden Road and any increase in traffic will cause more confusion for signalling car drivers. The volume of traffic using the A268 during the weekends in summer increases considerably with tourists coming to Rye and the local beaches. There are monitoring cameras located at the brow of Rye Hill because of the traffic flow at this time of year.
• The Lane is narrow and can not be widened at the junction with the A268 due to the houses that abut the road either side.
• If houses are built the new residents will also drive towards Playden Primary School and the Military Road. The Lane is narrow and in most areas not a full two lanes width and will become more hazardous for children attending the school.
• The Lane has ditches down its length and there are deep ruts (very muddy in wet weather) off the tarmacked surface.
• The lane is prone to potholes which though regularly repaired soon appear again. This is in part due to water which can flow across the road but also due to the increasing and heavier cars and vans which use the lane to cut through between the A268 and the Military Road.
• The Lane is unrestricted (national speed limit 60) and the school users have complained regarding speeding cars going past the school. East Sussex County Council have been asked for a reduction of speed in the area of the school which has been refused.
• Street lighting. If street lighting was installed for the new housing, this would affect the dark traditional environment of the area and have an affect on wildlife.
• Water flow in heavy rain. In times of heavy rainfall the ditches and lower stream are full. Any new housing higher up the lane and the concreting over of fields will cause problems for housing further down the Lane.
• Unlike most local villages Playden is a dispersed village lying along several country lanes as well as along the A268. There is no modern estate development as newer housing has been dispersed throughout the parish. Therefore a development of houses of this number would be out of keeping with the existing settlement.
• If any development were to occur on this site the provision of parking for the WI Hall and at a distance no further than currently is most important. Due to the narrow Lane there is no alternative area for users to park. If the same provision was not provided the WI Hall could not survive and would cease to exist. It is the only social and assembly space in the parish used by a variety users. The car park is also used as an overflow car park at weekends for users of the Waterworks tap room - the microbrewery on the opposite side of the A268. A very successful local startup (an addition to the successful Waterworks pub in Rye) and employer. This would also be affected.
• Playden Oast Hotel to the South is a listed building and its setting will be affected by this development.

Parish Council Comments on proposed housing at PLA2

Playden Parish Council objects to the proposed housing at this site for the following reasons:

• New England Lane is a narrow lane and in parts sunken between steep boundaries and descends towards the cliff above the Military Road where the lane terminates.
• The proposed site will enter onto the top end of the lane, however sightlines would be restricted without having a widening of the road.
• The junction of the lane with the main road (A268) is close to several roads opposite. The Rye memorial Hospital site is a busy junction with the doctor’s surgery, the retirement complex and Hub on the Hill. This will become busier when the 60 bed nursing home is eventually completed on the same site.
• Street lighting. If street lighting was installed for the new housing, this would affect the dark traditional environment of the area and have an effect on wildlife.
• Water flow in heavy rain. In times of heavy rainfall the ditches and lane run with water. Any new housing higher up the lane and the concreting over of fields will cause problems for housing further down the Lane.
• Unlike most local villages Playden is a dispersed village lying along several country lanes as well as along the A268. There is no modern estate development as newer housing has been dispersed throughout the parish. Therefore a development of houses of this number would be out of keeping with the existing parish settlement and will visually decrease the green gap between Playden and Rye
• The additional population from the housing will put further strain on the local doctor’s surgery especially when the nursing home is completed.
• The site will impact the setting of Playden Church (a grade 1 listed building) which is set back from the A268 down a driveway. The development will be noticeable from the church being only a garden away and will affect its setting.
• This site is within an archaeological notification area and destruction of below ground deposits will occur if the site is developed.

Site PL1
Surface water drainage from this site is very likely to flow into the existing stream along the northern boundaries of fields TQ9222 5202, TQ9222 5425 and TQ9222 8320.
This stream is already at the limits of it's capacity in carrying all the natural drainage of the land to the south and west of Houghton Green Lane as well as a large land area extending over the hills to the east and north towards Iden. The outflow is into the tidal River Rother via a flap that closes during high water levels in the river, thus preventing any outflow from the stream.
Any sizeable increase in the rate of flow into the stream is likely to result in flooding along Houghton Green Lane, the Military Road and the adjoining agricultural land. This problem is very likely to get worse with climate change.

PL1
The proposed entrance to the potential development is not safe. Houghton Green Lane is a narrow road and basically a single track. The road is already in a bad condition and this will only get worse with the increase in traffic.
There is a primary school down the lane and an increase in traffic would be hazardous to the children.
There have already been several near misses on the bend near Houghton Green Lane and the road to Iden.
If the carpark is no longer in use, the community will lose the WI and the hall which is used for various community events.
I do not see how 25 houses can be built in a small area without damaging the rural nature of the area and local wildlife.
The schools are already full in the area.
Not sure the medical centre can accommodate an increase in population.

This is a terrible proposal. Light pollution on a dedicated rural area. The sewage system is already pushed. This is also a dedicated walkers area which would also be ruined by the building and over heavy development. We also have bats could be affected and historical monuments. It’s utterly ridiculous. Will reduce house prices and spoil the utterly beautiful rural area of rye. Also amenities are already pushed doctors etc and this would overload the area. Cars would cause pollution. There is only a bus an hour so car would be dominant. 3 times we’ve protested this. You would be foolish to destroy the beauty and precious countryside rye has become known for.

Overdevelopment: Playden is a historic Domesday Book listed semi-rural countryside village with no housing estates. Latter will destroy the settlement's unique character and close the vital "transition space" between Rye and Playden (see PINS decision 17/6/19). Lack of services and facilities in Playden, save for a doctor's surgery and small secondary-care hospital. Site PL1: difficult vehicular access onto narrow lane with no pavements, access constraints; no suitable location for replacement community carpark on Houghton Green Lane. Site PL2: neighbouring 'Shellfield' site refused for housing TWICE by RDC and TWO appeals dismissed by Planning Inspectorate in 2019/2021 as site deemed inaccessible to services and facilities and adverse impact on character and appearance of area. Contrary to Rye NP policy on preserving gaps between Rye and surrounding villages. Adverse impact on historic "holloway" (sunken lane) New England Lane. Proposed density for PL2 too high. Enforce affordable housing if building occurs.

PL1 I object to the proposed development for the following reasons:
The proposed entrance to the potential development is not safe. Houghton Green Lane is a very narrow and winding road containing a primary school a little further down the lane and an increase in traffic would be dangerous.
There have already been several near misses on the bend near Houghton Green Lane and the road to Iden and this turning is often congested as the road narrows sharply after the junction by the Corner House and Peace and Plenty. Traffic can be chaotic here. As there is little to no public transport, this development will certainly mean a considerable
Increase in local traffic which the infrastructure cannot support.
25 houses cannot be built in a small area with no supporting infrastructure - primary school is full, medical centre is stretched, minimal to non-existent public transport.

Playden is a well preserved historic village referenced in the Domesday Book, and is an area that has historic links to the Roman Empire and is therefore of significant archaeological interest which needs to be duly considered. The parish council and Rother have combined to retain and preserve Playden's uniqueness, however, this would be destroyed should the site PL2 be included within the proposals for this 2025-2042 local plan.

The Shellfield site, adjacent to PL2, has had 2 recent planning appeals for similar development projects dismissed for multiple reasons including maintaining a strategic gap between Playden and Rye, and protection of the setting for St Michaels Church, a grade one listed building with direct views across the PL2 site.

New England Lane, formerly Saltcote Street, is an example of a historic narrow single track hollowed passageway leading from the A268 downhill to a winding footpath followed by 30 or 40 steps down the cliff face to Military Road on the edge of Romney Marsh. From the PL2 entrance to the main road the lane is 12-15 feet wide. Any attempt to add a footpath or widen the carriageway would require significant and unacceptable change, destroying features of this historic single track lane.

The draft plan identifies water logging across the proposed site, a feature of surface water flooding. Having lived in a property to the north west of PL2 for 46 years I am aware of the unseen underground streams that flow beneath the ground throughout the area. In Autumn and Winter they cause the water table to rise close to the surface which leaves minimal drainage for rainfall and results in prolonged periods of water logged ground from November to April. The pond identified next to PL2 is dry through the summer and then at various levels, but full to overflowing from November to April. It is likely that developments on the higher ground in Rye Foreign parish has increased the water flow. Any development of PL2 would increase the water volumes travelling down the natural channels to the cliff face above Military Road where there have been multiple landslips in the past few years, adding significant risk of further slips.

The majority of properties within Playden are individually sited detached houses. An estate type development is not in keeping with the villages uniqueness and should be repelled. A 1986 application for 10 properties on PL2, when it included an additional 0.41ha, part of the field to the north, was rejected for reasons including overdevelopment within an unsuitable location. This has not changed and the proposed inclusion for a potential development of 14 properties within a site that is now little more than half its 1986 size should be vehemently opposed.

Please register our objection to any development on the PL2 site with a request that it is removed from the final plan proposals.

WRT PL1 in my opinion 25 dwellings on this site would be out of the question. However, a scheme for a maximum of 3 dwellings could be acceptable. These would need to be extremely well designed. A successful scheme would need to include improved parking for the WI hall and a large contribution would need to be applied improve the already over stretched school, health and water supply services (106 agreement). Visual screening from the A268 would also be a must to maintain the character of the village.
WTR PL2 my views are similar to my comments on PL1 but with a maximum of two dwellings. Access would need to be carefully designed for a safe and visually attractive result.

I object to developments PL1 and PL2. They will adversely change the character of a semi-rural area and more importantly there is insufficient infrastructure to support extra vehicular, pedestrian and other traffic. Vehicular access to PL1 cannot be via Houghton Green Lane which is already an exceptionally difficult road used by walking school children to access the school, horse-riders, cyclists and many vehicles. The narrow, blind corner and already dangerous junction on to Rye Hill will become a completely unacceptable risk.Your supporting text states: 'Houghton Green Lane is narrow with no footways and is unsuited for pedestrian use'. The path from the Corner House down Rye Hill into Rye is becoming almost impossible to negotiate and needs total overhaul just for existing usage, let alone extra usage. Additional public transport links to Rye and along Houghton Green Lane to the school are required for existing usage, let alone extra usage.

I object to housing at PL1, a semi-rural site, on safety grounds. The proposed access, through the car park of a community hall, is on a blind bend from a single track, poorly maintained lane opposite houses with no lighting or footpath. The lane is used, at considerable risk, by pedestrians, including families walking to St Michaels school, cyclists and horses, who are forced into muddy ditches to avoid fast-moving vehicles. The road junction into Houghton Green Lane from Rye Hill is hazardous. The footpath from Playden into Rye is not maintained and is only usable by sure-footed people able to tackle the steep hill, inadequate for pushchairs, cycles or mobility scooters. The development would increase traffic and light pollution in an area which lacks infrastructure, so would not be attractive for the intended demographic. The incentive of a new safe footpath to the school cannot ensure its future maintenance.

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.

The proposed developments are not in keeping with Playden‘s semi-rural character; scattered houses and low light pollution. Playden has no shops or other amenities, and there are very few employment opportunities in the vicinity. The infrastructure is already over stretched, with unacceptably long waits for GP appointments, interruptions to water supply, etc.

PL1: The junction with the A268 is already hazardous, especially for pedestrians who are frequently not seen by drivers as their full focus is needed for the roads.
The footpath from Houghton Green Lane into Rye is poorly maintained and definitely not suitable for anyone with mobility or visibility issues.
Although there are bus stops, the service is very limited, making cars essential for most residents.

Houghton Green Lane is, by necessity, regularly used by pedestrians, cyclists, horses, and farm vehicles. Visibility is limited and there are no speed restrictions. The lane is narrow, twisty, and already seriously over used. There are sections that cannot accommodate vehicles passing in opposite directions; a problem very much exacerbated by potholes.
Some properties close to the proposed site have little or no off road parking facilities, so passing places are often blocked by parked vehicles. The proposed access is close to a blind bend on a particularly narrow part of the lane, with houses directly opposite.

It’s hard to comprehend how the proposed site could accommodate 25 houses, as well as all the additional residents’ cars, whilst also replacing any parking provision lost as part of the site’s development, plus the stated ‘green infrastructure’ with ‘public open space and biodiversity net gain’.
The required ‘highway improvements to provide for access by pedestrians and cyclists’ seems impossible to achieve given the properties either side at the top of the lane, including an existing business which involves vehicles coming and going throughout the day.
There is no way to widen the lane, or have pavements or paths added, without destroying ancient trees and hedgerows. I believe there has been some suggestion of having a path running adjacent to the lane on the other side of the hedge, but I fail to see how this could actually be achieved without significantly altering the landscape. The cost would likely be prohibitive and it would require a lot of regular maintenance, which is unlikely to happen.

See attached.

PL1: As a long time member of the Playden Women’s Institute, I am worried about the increased traffic on the narrow twisty lane and the lack of parking for users of the WI Hall and local residents. The Hall is used by the local community for various activities, by Playden Parish Council for meetings and by Rother District Council as a polling station.
The disruption to normal traffic, local residents and the school, as well as users of the WI Hall, would be considerable, especially while the building work is in progress.

I think that the draft plan has been well thought out and fully appreciate that the targets that the authority is being asked to meet, together with local need, mean that development sites do need to be found.

As a resident in Playden I'm aware of the challenges we have in terms of the limited public transport connections and the narrow walking route into Rye cited in the plan. Also of the narrow lane access that affects many parts of the Parish.

Site PL1 - I'm always very saddened to see any green field site proposed for development. That said, this site is raised up and slightly secluded from the main road. The draft plan proposes soft edges to village developments so that there aren't rows of garden fences backing onto roads, this would help this site to sit in the landscape if developed. Access into any development from Houghton Lane I think would present challenges. The lane is slightly wider than many of the local lanes but the opening on to the A268 is between two properties that sit right out on their property boundaries. It can be difficult for two cars to pass at this point between the houses and at key busy times such as school drop off to St Michaels Playden, vehicles already queue out onto the A268 which is not safe. Additional traffic from up to 26 dwellings would compound this. The site itself is then partially tucked away and I think the main impact in terms of loss of amenity and noise would sadly be with the immediate neighbouring properties. Overall I feel that developing the site would be detrimental to near neighbours and in terms of traffic safety. The impact would be reduced the smaller the development was and by a well planned development that appreciates and seeks to add to the rural character of the parish.

Site PL2 - I object to this site on the grounds of the access and also the detrimental impact on the rural character of Playden parish. Various planning applications on the lane over the last decade have been refused on the basis of the extremely narrow lane access and also the need to preserve the rural feel of the parish and the distinct green spaces that separate the parish from Rye. This site is too close the the heritage and green space assets of the Playden. I do not feel it is appropriate for it to be developed.

I am concerned about the vehicular access to both PL1 and PL2. Sight lines on Rye Road are difficult as it is without many more vehicles gaining access.
New England Lane, at the point of PL2 is a very steep narrow lane with the proposal creating access issues on to A268.
The road past PL1 leads to Playden School and is a very narrow lane to have many vehicles gaining access at school times.

PL1 There is no indication of the type of housing that is planned, other than that 25 new dwelling will be shoehorned into an area of just over 1 hectare. This is completely out of character for the existing situation and surrounding area.
I also cannot understand why access is planned via Houghton Green Lane instead of the main road.
This proposal has not been thought through and will not sit well within the existing rural setting. Completely inappropriate.

the potential for 25 houses that is a huge percentage increase of properties in Playden, will the existing water / sewage infrastructure cope ? and the access road into this proposed development is on a blind dangerous corner, with no pedestrian pathways on Houghton Green Lane, a lot of traffic uses the lane already, along with cyclists and dogwalkers. 25 properties will no doubt come with an increase in vehicles which will just increase the accident risk onto an already dangerous junction from Houghton Green Lane onto the A268

Our principal concern is the additional traffic this will create on the whole length of Houghton Green Lane. Considering the very narrow lane and proximity to the Primary School proposed access from the Women’s Institute car park onto the narrow twisting lane will be dangerous. The lane already carries heavy traffic at school times from 8am to 9am and 2.30p to 4pm with vehicles, pedestrians, both adults and young children. Also dog walkers horse riders and cyclists at other times. There have already been accidents on the lane which already acts as a through road to the Military Road and a diversion route for Iden . Turning left from this access would enter the A268 on the already dangerous near junction leading to Iden and could also lead to congestion on the entrance to the lane.

Reference site PL2. This is far from a suitable site for development…

The site is on a quite rural, narrow and historic singe track lane.
Water drainage is already a problem.
Light pollution in this dark area would disturb the wildlife.
The nearby Doctors surgery already struggles to cope.
I do not feel this is the right place for any housing development.

I am sending this email to register my objections at the draft plan for housing at Playden opposite the WI Hall. As I have been a member of [redacted information] for [redacted information] years I've always thought that parking would be a problem if the facility was taken away. The lane is very narrow and as it leads down to the primary school there are enough cars going down there on a daily basis.



The general consensus is that if this development was allowed, the WI would have to close and other organisations would not have the facility of a lovely hall as parking would not be sufficient. The hall was renovated a few years ago and it should be used regularly.

I had big problems trying to register my thoughts on this proposed development and await the outcome.