I live in Burgh Hill, Etchingham, midway between Hurst Green and Etchingham. I have attended both the parish councils’ presentations on the proposed sites for our villages and spoken with councillors at both district and county council level.

ETCHINGHAM

As a general point Etchingham has no village shop, the butcher is closed, no public house . We do have the station with the Bistro and the Post Office which sells sweets and stationary. The bottom end of the village is in the flood plain and the fields and surrounding lanes often flood. Raw sewage on the field next to the houses at the bottom is the result as the pumping station has long been at capacity. Any further development in the village cannot be allowed until this is resolved.

The site in Church Lane sits on arable pasture some six feet above the road level and immediately at the dangerous bends over the narrow railway bridge. Access is highly compromised. The lane floods badly below the proposed site with normal runoff from the fields so further development here would drastically add to this problem. Further development here where the row of houses opposite have no driveways and residents park at right angles to the houses on their paved over frontages often causing overlap onto the highway would add to the danger of access to this site. I object to this site.

The site on the main A265 outside the village envelope and in an 60 mph speed limit is in the National landscape, AONB, and green belt . Totally unsuitable. I object.
The third site down the lane past the village club is in the flood plain with highly compromised access onto a dangerous narrow lane. I object.

HURST GREEN

This village already has approved permission for 75 units. Only one site has been started and finished, 26 units, the other two yet to begin even after 3 years!

Site HG3.
Provided this site uses the vehicular access through Foundary Close and not the fourth access onto the Station Road A21 junction which is undergoing highly contested restructuring I have no objection.

Site HG4
To suggest an extra 150 units here without due regard to the congestion and access onto the A21, capacity at the village school, drainage, power and water availability is totally irresponsible and demonstrates a disregard for local opinion, or a professional reasoned approach form government at all levels. I object.

EC2
Totally unsuitable development proposal. New dwellings would be subject to severe flooding from rising field behind. Drainage and sewerage impractical to upgrade and already overwhelmed. Major traffic increase along small country road and winding rail bridge totally impractical to navigate. Existing dwellings eastern aspect totally ruined in AONB.

EC3
Completely insensitive development in AONB. Huge increase in traffic along Straight Mile. Melding of Etchingham and Burwash into a town. Ruination of green belt land.

EC1 With careful consideration to flooding and low level development this site could accommodate houses on the northern part.
Need to replace existing parking spaces as well as sufficient to avoid further congestion on site.
EC2 The threat of flooding is very great in this position. The culverts under the railway are insufficient to allow water passage beyond. A narrow lane which cannot sustain further parking.
EC3 The community was led to believe thee would be no further development beyond the new woodland planting.
The proposal here is excessive. Although Etchingham has a station, school and small post office it no longer has shops making large numbers of houses unsustainable.

We are objecting to any proposed development for EC3 for the following reasons -
Currently inadequate school parking will be made much worse. At present cars park on the pavement for extended periods.
GP surgery already unable to provide good service - eg. 5 days to get prescription. Hard to see doctor within reasonable timescale.
Increased traffic levels - more pollution, parking problems, access to A265 will be difficult as this is a very busy road with many HGVs.
Can the current school cope with increased pupil numbers? Increase in costs to pupil transport going to secondary school.

Policy Reference EC3:
I live near the proposed site. My concerns are listed below:
Development will overlook adjacent properties.
The level of noise from the housing will be too much.
The storm water drains are not adequate. They already struggle with the level of housing by the new school.
The storm water will go into the River Dudwell contaminating it and the wildlife that live in it.
The foul water drainage is already overloaded and keeps having to be let out at the bottom of the village.
The general infrastructure just isn't there to be able to deal with this level of housing.
An alternative site for a small number of housing could be the lambing shed site, the other side of the school.

Etchingham is a small village with no facilities such as a shop, pub, doctors, only a post office that sells stationery and cards. the lower end of the village is prone to flooding and the drainage system is inadequate and often blocked due to lack of maintenance. The local primary school is full, the Doctors in Burwash is over subscribed, the high street is already very congested and there is no parking in the village apart from on the road, so any further development will increase all the problems we already have. and moving the 30 MPH limit further out of the village will not slow the traffic down as they are travelling at 60mph along the straight mile it will be hazardous trying to enter and exit the A265 from the new development EC3.
There must be a better place to build properties that already have the infrastructure in place such as larger villages or towns.

We live directly opposite the EC3 proposed site and have specific concerns regarding increased traffic and surface water run‑off, as the field already discharges significant volumes of water onto the road during periods of heavy rainfall, which would likely worsen if the land is developed.
More importantly, Etchingham has very limited infrastructure, particularly in relation to health services, with the nearest GP surgery already extremely busy and appointments difficult to obtain.
We also experience frequent unplanned interruptions to our electricity supply and are concerned that additional demand will exacerbate this.
Our water supplier has raised concerns about accommodating further housing growth, and residents of the recent Parsonage Croft development already report wastewater flooding due to inadequate sewerage capacity.
While we recognise the national need for additional housing, introducing over 200 new residents into a small village with such constrained infrastructure is likely to create significant and ongoing problems.

I object to the proposed EC2 development primarily due to the increased flood risk it is likely to create. Residents of Church Lane already face recurrent flooding threats throughout the year, which understandably causes considerable stress and anxiety. Significant flooding has occurred in recent years, and with climate change increasing the intensity and frequency of rainfall, further development on a floodplain appears inappropriate and disregards the lived experience of existing residents. They should not have to fear for their homes every time it rains.

In addition, Church Lane is a narrow road with no pavements and is already difficult and, at times, unsafe to walk along due to speeding or inconsiderate drivers. The introduction of construction traffic would pose a serious safety concern, and the longer‑term increase in vehicle movements associated with the development would further compromise pedestrian safety on this constrained lane.

I am Objecting to EC1, EC2 and EC3.

I have significant concerns regarding the adequacy of infrastructure planning within Rother District Council’s Draft Local Plan. In particular, the plan does not appear to clearly demonstrate how the proposed level of housing growth will be balanced with the services and infrastructure required to support it.

It is unclear whether the Draft Local Plan has fully accounted for dwellings that have already been granted planning permission but have not yet been built, or for land that is currently held by developers but remains undeveloped. Transparency regarding these existing commitments would help residents better understand the cumulative scale of development already anticipated within the district and surrounding rural communities.

More broadly, I am concerned that housing targets are being advanced ahead of the infrastructure required to sustain them. Local infrastructure across East Sussex is already under significant pressure, and further development without corresponding investment risks exacerbating existing challenges.

Water supply is a particular concern. South East Water has recently indicated, in relation to planned housing growth in nearby areas such as Tonbridge and Malling, that current infrastructure capacity may only support a proportion of the proposed housing numbers up to 2042. The company’s existing Water Resources Management Plan accounts for approximately 6,318 additional homes in the area, whereas local planning proposals identify significantly higher housing numbers.

This raises wider questions about the long term resilience of water infrastructure across Kent and East Sussex, particularly given that Bewl Water Reservoir serves both counties. Recent operational issues at Pembury Water Treatment Works have also highlighted vulnerabilities within the system. Residents in several locations, including parts of East Sussex such as Etchingham and Wadhurst, have experienced periods of water supply disruption in recent years. These events understandably raise concerns about the system’s ability to support further large scale development without significant investment and improvement.

Similarly, there are longstanding concerns regarding wastewater and sewerage infrastructure. Residents are already aware that the existing sewer network and wastewater treatment arrangements serving Etchingham experience operational challenges during periods of heavy rainfall, which can result in sewer surcharging and localised flooding. It is therefore important that Southern Water clearly demonstrate that future housing allocations within the Draft Local Plan — including the cumulative district target of 8,427 dwellings — have been fully incorporated into their long term Drainage and Wastewater Management Plans and capacity forecasts for the area.

Beyond utilities, several aspects of local infrastructure require careful consideration before significant housing growth is introduced. These include:

• Healthcare provision, including access to GP and dental services; the local GP already operates with long waiting times in nearby Burwash.
• Education capacity, particularly at Etchingham Village Primary School as already at full capacity, and would require a Secondary School.
• Transport and road infrastructure, including traffic management and safety along the A265 and through the village centre.
• Parking provision associated with new developments.
• Electricity supply resilience, given the frequency of power outages experienced locally.

Flood risk is another major issue for the village. Etchingham regularly experiences local flooding during periods of sustained rainfall, affecting fields, gardens, and sections of the main road, which can become temporarily impassable. Flooding also contributes to pressure on drainage and sewer systems.

For this reason, development on greenfield sites such as Croft Field (Re: EC3) requires particularly careful consideration. The proposed allocation of approximately 55 dwellings represents a substantial increase for a village of this size.

Development on such land may also have implications for local drainage patterns and agricultural use, as Croft Field currently supports nearby farming activity, including hay production for livestock.

I would also welcome clearer policy guidance within the Draft Local Plan regarding the type, scale, and quality of housing that may be delivered on allocated sites. This includes appropriate density, design standards, and adequate parking provision to ensure that developments are compatible with the character and capacity of rural communities, ensuring that Etchingham village always remains a village and not turned into a town (by joining up with Burwash).

In summary, I believe that housing growth should be accompanied by demonstrable commitments to the infrastructure required to support it. Greater clarity from infrastructure providers, alongside robust planning policies, will be essential to ensure that development is sustainable and that the needs of existing and future residents are appropriately balanced.

Objection to Proposed Housing Development in Etchingham

I have lived in Etchingham for 24 years and strongly object to the proposed development of 70 additional houses in the village.

Etchingham already met its housing allocation in 2015. Since that time, no corresponding improvements have been made to local infrastructure. The primary school has not been expanded, no additional GP surgery has been provided, and the village infrastructure has not been upgraded to accommodate further growth. The proposal for an additional 70 houses fails to address or mitigate the existing pressures already experienced by residents.

1. Flooding and Drainage Issues
Drainage within the village is already inadequate. During periods of heavy rain, manhole covers in the pavements are frequently forced up by water pressure and significant surface water runs down the High Street. Areas EC1 and EC2 are well-known flood zones to local residents. Building further housing, particularly on land that contributes to natural drainage and flood management, risks worsening an already serious problem.

2. Lack of Healthcare Capacity
There are no proposals to expand local healthcare provision. The Burwash GP surgery, which serves Etchingham and surrounding villages, is already operating at capacity and it is often difficult to obtain appointments. Adding hundreds of additional residents without increasing medical provision will place further strain on an already overstretched service.

3. School Capacity
There are no plans to increase the capacity of the village primary school. Additional housing will inevitably bring more families and children to the area, yet there is currently no provision to accommodate this growth.

4. Traffic, Congestion and Pollution
Traffic in Etchingham is already a significant issue due to the village’s location on a busy main road and the railway level crossing. When the crossing barriers are down, long queues of stationary vehicles build up along the High Street, with engines left running. This results in increased noise and air pollution within the village. Additional housing will inevitably increase traffic and exacerbate these existing problems.

5. Loss of Greenfield Land in an Area of Outstanding Natural Beauty
All of the proposed development sites are Greenfield land. No brownfield alternatives have been identified. Etchingham lies within an Area of Outstanding Natural Beauty, and development on these fields would result in permanent loss of open countryside, harm to local wildlife habitats, and damage to the rural character of the village.

For these reasons, I strongly urge the council to reject these proposals.

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.

I am Objecting to EC1, EC2 and EC3 making the following points:

EC3 would be a 'ribbon development' when urban sprawl is a direct violation of the National Planning Policy Framework and Town & Country Planning Act 1947.

The land in EC3 is agricultural grade 3 - "best and most versatile". It has not been proven as to whether any “lower grade” alternative sites exist.

The local sewerage system is already well over-capacity with constant problems during periods of high rainfall.

Etchingham Primary School has a capacity of 105 children, and the current roll is 100 - making it close to being oversubscribed.

The nearest Secondary school would be more than 3 miles away. Crucially that means that any child could request free transport to school - and they don't have to take the bus. The cost of taxis taking secondary school children to school is already a crippling cost for ESCC.

The local GP surgeries are already under-resourced and oversubscribed.
Fairfield Surgery Burwash is in the top 10 GP surgeries in Rother with the longest waits for appointments. (Sussex Express December 2022)

70 new houses will bring 120 new cars into the village (1.7 cars per household) and with no shop, an oversubscribed primary school, no secondary school and virtually no public transport there will be a significant increase in the number of extra vehicles on the village roads which are already very dangerous (Burwash Roads Survey).

Footpaths through Etchingham Village are extremely narrow and dangerous for pedestrians.

It should also be noted that the A265 “straight mile” - from which any development in EC3 would have direct access - is already used by motorcyclists as a racetrack.

I am Objecting to EC1, EC2 and EC3.
I have significant concerns regarding the adequacy of infrastructure planning within Rother District Council’s Draft Local Plan. In particular, the plan does not appear to clearly demonstrate how the proposed level of housing growth will be balanced with the services and infrastructure required to support it.
It is unclear whether the Draft Local Plan has fully accounted for dwellings that have already been granted planning permission but have not yet been built, or for land that is currently held by developers but remains undeveloped. Transparency regarding these existing commitments would help residents better understand the cumulative scale of development already anticipated within the district and surrounding rural communities.
More broadly, I am concerned that housing targets are being advanced ahead of the infrastructure required to sustain them. Local infrastructure across East Sussex is already under significant pressure, and further development without corresponding investment risks exacerbating existing challenges.
Water supply is a particular concern. South East Water has recently indicated, in relation to planned housing growth in nearby areas such as Tonbridge and Malling, that current infrastructure capacity may only support a proportion of the proposed housing numbers up to 2042. The company’s existing Water Resources Management Plan accounts for approximately 6,318 additional homes in the area, whereas local planning proposals identify significantly higher housing numbers.
This raises wider questions about the longterm resilience of water infrastructure across Kent and East Sussex, particularly given that Bewl Water Reservoir serves both counties. Recent operational issues at Pembury Water Treatment Works have also highlighted vulnerabilities within the system. Residents in several locations, including parts of East Sussex such as Etchingham and Wadhurst, have experienced periods of water supply disruption in recent years. These events understandably raise concerns about the system’s ability to support further largescale development without significant investment and improvement.
Similarly, there are longstanding concerns regarding wastewater and sewerage infrastructure. Residents are already aware that the existing sewer network and wastewater treatment arrangements serving Etchingham experience operational challenges during periods of heavy rainfall, which can result in sewer surcharging and localised flooding. It is therefore important that Southern Water clearly demonstrate that future housing allocations within the Draft Local Plan — including the cumulative district target of 8,427 dwellings — have been fully incorporated into their longterm Drainage and Wastewater Management Plans and capacity forecasts for the area.
Beyond utilities, several aspects of local infrastructure require careful consideration before significant housing growth is introduced. These include:
• Healthcare provision, including access to GP and dental services; the local GP already operates with long waiting times in nearby Burwash.
• Education capacity, particularly at Etchingham Village Primary School as already at full capacity, and would require a Secondary School.
• Transport and road infrastructure, including traffic management and safety along the A265 and through the village centre.
• Parking provision associated with new developments.
• Electricity supply resilience, given the frequency of power outages experienced locally.
Flood risk is another major issue for the village. Etchingham regularly experiences local flooding during periods of sustained rainfall, affecting fields, gardens, and sections of the main road, which can become temporarily impassable. Flooding also contributes to pressure on drainage and sewer systems.
For this reason, development on greenfield sites such as Croft Field (Re: EC3) requires particularly careful consideration. The proposed allocation of approximately 55 dwellings represents a substantial increase for a village of this size. Development on such land may also have implications for local drainage patterns and agricultural use, as Croft Field currently supports nearby farming activity, including hay production for livestock.
I would also welcome clearer policy guidance within the Draft Local Plan regarding the type, scale, and quality of housing that may be delivered on allocated sites. This includes appropriate density, design standards, and adequate parking provision to ensure that developments are compatible with the character and capacity of rural communities, ensuring that Etchingham village always remains a village and not turned into a town (by joining up with Burwash).
In summary, I believe that housing growth should be accompanied by demonstrable commitments to the infrastructure required to support it. Greater clarity from infrastructure providers, alongside robust planning policies, will be essential to ensure that development is sustainable and that the needs of existing and future residents are appropriately balanced.

See attached.

Development EC3 is ribbon development along the Straight Mile, losing the defining boundary to Etchingham village.
The village cannot cope with the extra traffic.
Infrastructure would be overwhelmed by this level of housing.
Would cause further issues with flooding.
This is a green field site within an Area of Outstanding Natural Beauty and would impact on the biodiversity in the area, loss of habitat for wildlife.

After the town hall meeting we found that the village can't cope with the extra traffic and footfall and don't have the infrastructure to cope with this many more houses. EC1 is part of the flood area and we already have massive sewage problems during the winter months along the valley. The increase from 8 to above 50 houses in EC3 will create massive parking and traffic issues. EC2 is on a steep hill and houses there will ruin that area in every way.

EC3 is RIBBON DEVELOPMENT. Unacceptable in an AONB.

EC1 is half in a flood zone. Access would be via the flood-zone onto a dangerously narrow road, and would destroy the necessary existing parking. These are glaring defects: less obvious is the ecological downside. The River Dudwell sustains a valuablely diverse but vulnerable ecosystem. Moths are an internationally recognised marker of biodiversity, and 920 species have been found within 150 metres of the site. 23 species of macro-moths found here have been classified as endangered, vulnerable or Nationally Rare/Scarce; 16 more are "nearly threatened". Of the micro-moths, 7 species are Red Data Book species, 46 Nationally Scarce. Morover, the moth data conclusively proves that the Dudwell is a vital wildlife corridor. Rare species that only breed at Rye regularly travel up the river to Etchingham. Buildings would disrupt connectivity, impoverishing sites upriver.

I would like to object to the proposed allocation of land highlighted in the Plan as EC1 as being for development for the following reasons (not in any particular order)
• The land in question is a greenfield site located in the Dudwell Valley which is an Area of Outstanding Natural Beauty. As such I don’t feel that there should be any development unless or until there are no brownfield sites available. At the present time there are brownfield sites located behind the village school (with easy access to the High Street), the old school building located just outside the village (which has been unused for several years) together with a small car parking area. There is also an additional area in the center of the village at the junction of Church Lane and the High Street - This area is severely overgrown through neglect and could easily the repurposed for housing.
• The land is on a flood plain and is liable to see greater flooding impact as global warming becomes greater and rainstorm more severe.
• There is a question mark as to the ability of the water companies to provide a full supply to the number of new houses to be built in the South East. In addition as things stand today they are unable to provide for full sewerage handling (not just after heavy rains) and often rely on releasing sewerage into local rivers and sea.
• Access to the proposed site is to be through a new entrance to be built off Oxenbridge Lane by repurposing the existing small car park by the narrow bridge over the River Dudwell. This access road will bring far greater numbers of cars turning off/onto Oxenbridge Lane. While in itself this in not necessarily a problem on the face of it, any access will have very limited line of sight of the existing road for vehicles leaving the development due to the positioning and construction of the bridge over the Dudwell.
• With the removal of the existing car park, which is currently used by residents of Oxenbridge Row, those residents will have no alternative but to park on the narrow Oxenbridge Lane (while additional parking is proposed as part of the development it is highly probable that these slots will be utilized by residents of the development given we live in an age of multiple cars per family, especially in the rural areas. This causes two distinct problems – a further narrowing of the lane which would be an issue for lorry’s and farm vehicles using the lane and further disrupting the vision of traffic leaving the development (and Park Farm Close).
• This site was looked at a few years ago as part of a village plan and rejected by the village as not appropriate (I’m not sure if this plan was ever finalized but a copy should be reviewed as part of your considerations)
• The houses on Oxenbridge Lane and Park Farm Close currently have stunning views over the valley. The affected properties will have their right to quiet enjoyment of their gardens taken away due to the loss of view, becoming overlooked by the new development and the loss of light the development will cause. In addition the loss of views over the valley will have a significant negative impact on the value of the affected properties.
• Finally, I live in one of the affected houses and we have a bat nursery in our eaves. A development like this will cause the bats distress at best and complete loss at worse.

I am Objecting to EC1, EC2 and EC3.
I have significant concerns regarding the adequacy of infrastructure planning within Rother District Council’s Draft Local Plan. In particular, the plan does not appear to clearly demonstrate how the proposed level of housing growth will be balanced with the services and infrastructure required to support it.
It is unclear whether the Draft Local Plan has fully accounted for dwellings that have already been granted planning permission but have not yet been built, or for land that is currently held by developers but remains undeveloped. Transparency regarding these existing commitments would help residents better understand the cumulative scale of development already anticipated within the district and surrounding rural communities.
More broadly, I am concerned that housing targets are being advanced ahead of the infrastructure required to sustain them. Local infrastructure across East Sussex is already under significant pressure, and further development without corresponding investment risks exacerbating existing challenges.
Water supply is a particular concern. South East Water has recently indicated, in relation to planned housing growth in nearby areas such as Tonbridge and Malling, that current infrastructure capacity may only support a proportion of the proposed housing numbers up to 2042. The company’s existing Water Resources Management Plan accounts for approximately 6,318 additional homes in the area, whereas local planning proposals identify significantly higher housing numbers.
This raises wider questions about the long term resilience of water infrastructure across Kent and East Sussex, particularly given that Bewl Water Reservoir serves both counties. Recent operational issues at Pembury Water Treatment Works have also highlighted vulnerabilities within the system. Residents in several locations, including parts of East Sussex such as Etchingham and Wadhurst, have experienced periods of water supply disruption in recent years. These events understandably raise concerns about the system’s ability to support further large scale development without significant investment and improvement.
Similarly, there are longstanding concerns regarding wastewater and sewerage infrastructure. Residents are already aware that the existing sewer network and wastewater treatment arrangements serving Etchingham experience operational challenges during periods of heavy rainfall, which can result in sewer surcharging and localised flooding. It is therefore important that Southern Water clearly demonstrate that future housing allocations within the Draft Local Plan — including the cumulative district target of 8,427 dwellings — have been fully incorporated into their long term Drainage and Wastewater Management Plans and capacity forecasts for the area.
Beyond utilities, several aspects of local infrastructure require careful consideration before significant housing growth is introduced. These include:
• Healthcare provision, including access to GP and dental services; the local GP already operates with long waiting times in nearby Burwash.
• Education capacity, particularly at Etchingham Village Primary School as already at full capacity, and would require a Secondary School.
• Transport and road infrastructure, including traffic management and safety along the A265 and through the village centre.
• Parking provision associated with new developments.
• Electricity supply resilience, given the frequency of power outages experienced locally.
Flood risk is another major issue for the village. Etchingham regularly experiences local flooding during periods of sustained rainfall, affecting fields, gardens, and sections of the main road, which can become temporarily impassable. Flooding also contributes to pressure on drainage and sewer systems.
For this reason, development on greenfield sites such as Croft Field (Re: EC3) requires particularly careful consideration. The proposed allocation of approximately 55 dwellings represents a substantial increase for a village of this size. Development on such land may also have implications for local drainage patterns and agricultural use, as Croft Field currently supports nearby farming activity, including hay production for livestock.
I would also welcome clearer policy guidance within the Draft Local Plan regarding the type, scale, and quality of housing that may be delivered on allocated sites. This includes appropriate density, design standards, and adequate parking provision to ensure that developments are compatible with the character and capacity of rural communities, ensuring that Etchingham village always remains a village and not turned into a town (by joining up with Burwash).

I am Objecting to EC1, EC2 and EC3.
I have significant concerns regarding the adequacy of infrastructure planning within Rother District Council’s Draft Local Plan. In particular, the plan does not appear to clearly demonstrate how the proposed level of housing growth will be balanced with the services and infrastructure required to support it.
It is unclear whether the Draft Local Plan has fully accounted for dwellings that have already been granted planning permission but have not yet been built, or for land that is currently held by developers but remains undeveloped. Transparency regarding these existing commitments would help residents better understand the cumulative scale of development already anticipated within the district and surrounding rural communities.
More broadly, I am concerned that housing targets are being advanced ahead of the infrastructure required to sustain them. Local infrastructure across East Sussex is already under significant pressure, and further development without corresponding investment risks exacerbating existing challenges.
Water supply is a particular concern. South East Water has recently indicated, in relation to planned housing growth in nearby areas such as Tonbridge and Malling, that current infrastructure capacity may only support a proportion of the proposed housing numbers up to 2042. The company’s existing Water Resources Management Plan accounts for approximately 6,318 additional homes in the area, whereas local planning proposals identify significantly higher housing numbers.
This raises wider questions about the long term resilience of water infrastructure across Kent and East Sussex, particularly given that Bewl Water Reservoir serves both counties. Recent operational issues at Pembury Water Treatment Works have also highlighted vulnerabilities within the system. Residents in several locations, including parts of East Sussex such as Etchingham and Wadhurst, have experienced periods of water supply disruption in recent years. These events understandably raise concerns about the system’s ability to support further large scale development without significant investment and improvement.
Similarly, there are longstanding concerns regarding wastewater and sewerage infrastructure. Residents are already aware that the existing sewer network and wastewater treatment arrangements serving Etchingham experience operational challenges during periods of heavy rainfall, which can result in sewer surcharging and localised flooding. It is therefore important that Southern Water clearly demonstrate that future housing allocations within the Draft Local Plan — including the cumulative district target of 8,427 dwellings — have been fully incorporated into their long term Drainage and Wastewater Management Plans and capacity forecasts for the area.
Beyond utilities, several aspects of local infrastructure require careful consideration before significant housing growth is introduced. These include:
• Healthcare provision, including access to GP and dental services; the local GP already operates with long waiting times in nearby Burwash.
• Education capacity, particularly at Etchingham Village Primary School as already at full capacity, and would require a Secondary School.
• Transport and road infrastructure, including traffic management and safety along the A265 and through the village centre.
• Parking provision associated with new developments.
• Electricity supply resilience, given the frequency of power outages experienced locally.
Flood risk is another major issue for the village. Etchingham regularly experiences local flooding during periods of sustained rainfall, affecting fields, gardens, and sections of the main road, which can become temporarily impassable. Flooding also contributes to pressure on drainage and sewer systems.
For this reason, development on greenfield sites such as Croft Field (Re: EC3) requires particularly careful consideration. The proposed allocation of approximately 55 dwellings represents a substantial increase for a village of this size. Development on such land may also have implications for local drainage patterns and agricultural use, as Croft Field currently supports nearby farming activity, including hay production for livestock.
I would also welcome clearer policy guidance within the Draft Local Plan regarding the type, scale, and quality of housing that may be delivered on allocated sites. This includes appropriate density, design standards, and adequate parking provision to ensure that developments are compatible with the character and capacity of rural communities, ensuring that Etchingham village always remains a village and not turned into a town (by joining up with Burwash).

I wish to strongly object to plans for building 55 new homes in Croft field Etchingham known as development EC3.
The reasons are as follows:
The existing infrastructure to support these additional properties is not currently available regarding healthcare, schools, water system supply and electrical supplies which are repeatedly interrupted with outage interruptions. The village has one post office and no shops. What is the point of building additional houses where there are no facilities. No consideration has been given to the additional volume of additional traffic that the extra housing would cause.
The straight mile sits in an area which is supposed to be protected as being a place of outstanding natural beauty which will not be the case if the area becomes over developed. My house sits directly opposite the field EC3. I can’t emphasise strongly enough how this development proposal should be stopped from damaging the village

I object to development at any of the proposed sites (EC1, EC2 & EC3). There is a severe and chronic issue with the capacity of the existing sewage infrastructure in the village that needs to be addressed before any further development is considered. Since the development of Parsonage Croft and the former Bracons site, even moderate levels of rainfall overload the sewer causing it to illegally discharge raw sewage directly into the Dudwell, and from High Street inspection covers onto the road and pavements. It is a completely unacceptable environmental and public health hazard which has been reported to Southern Water on multiple occasions. This under-capacity also causes the sewer to back up into residential property drainage at the lower end of the village leaving occupants unable to do such basic things as laundry and flush the toilet. Southern Water's consistent response is that the sewer itself and and the pumping station adjacent to the railway line are simply not capable of dealing with the demands routinely being placed on it*. Placing any additional demand on this hopelessly broken system in the form of more housing and run-off from developed land would be absolutely catastrophic and a complete dereliction of duty.

Until this issue is comprehensively resolved and the local infrastructure is fit for purpose, no development that will only exacerbate the problem should be considered.

* please note that recent repairs carried out in the field opposite the church HAVE NOT resolved the issue, and they have been advised of this.

My objection relates to all three proposals - EC1, EC2 and EC3.
In my opinion, any further building work in the village of Etchingham, be it 7 or 70 dwellings, will surely cause a major environmental risk of flooding to an area already well documented as being a flood plain area. Speaking as a person directly affected by serious flooding in our new-build house (which should never have been granted planning) in the year 2000. I cannot believe these plans are even being considered in Etchingham. Thank you for taking our views into consideration.

The Parish Council considers that insufficient weight has been given to the duty to conserve and enhance the High Weald National Landscape. The Local Plan would benefit from a clearer articulation of the defining characteristics of this landscape and the translation of the High Weald Management Plan into specific development policies. Etchingham sits within a particularly sensitive location at the confluence of the Rivers Limden, Rother and Dudwell, where landscape character, biodiversity, and historic features are closely interrelated and highly vulnerable to change.

Infrastructure remains a significant constraint. There are known issues within the parish relating to drainage and sewage capacity, including instances of overspill, which raise both environmental and public health concerns. In addition, highway safety (particularly on the Straight Mile), and pressures on local medical services, require further consideration and investment before additional development can be accommodated.

We object to the omission of the Lambing shed site

Etchingham is a small village with almost no infrastructure. We already have constant issues with power supply (regular power cuts and sudden unplanned outages, and issues with trees falling on overhead power cables etc), water supply (SE Water is simply not fit for purpose and is increasingly overwhelmed by issues such as the problems around Tunbridge Wells before Christmas 2025), potholes everywhere, and ongoing flooding risk in the Rother valley. Services are also overwhelmed, schools are full, doctors are full, dentists are full and so on. To attempt to build another 70 houses in Etchingham, 145 in Robertsbridge, 185 houses in Hurst Green, 137 houses in Flimwell, 64 in Burwash, 54 in Ticehurst is simply ridiculous, the infrastructure in TN19 7PB will be completely overwhelmed and unable to cope. And where will the new residents send their children to school, or go to the doctors? While I recognise that this is all part of the government's drive to build 1.5 million new houses by 2030, swamping rural areas with new houses which simply cannot be accommodated is not achievable or sustainable, and will create huge issues for existing residents. This policy needs to be properly planned in conjunction with increases in accompanying infrastructure and services, but there is no indication that this is the case. I therefore strongly object to this proposed local plan.

I am Objecting to EC1, EC2 and EC3.
There is a complete inadequacy of infrastructure planning within Rother District Council’s Draft Local Plan. In particular, the plan does not appear to clearly demonstrate how the proposed level of housing growth will be balanced with the services and infrastructure required to support it.
I am concerned that housing targets are being pushed ahead of the infrastructure required to sustain them. Etchingham now only has a small part time Post Office, no other shops, no Pub and a small playground that in Winter is partially flooded. The Primary school is small & largely at capacity even with the current village demographic. Local secondary schools are small & over subscribed The village has Electricity supplied by overhead cables & is not always reliable even within the small existing village.
Drainage in the village is appalling, surrounded by floodplains with totally inadequate blocked road-drains resulting in the main road being a torrent in even slightly heavy rain. Water supply is a particular concern. South East Water has recently indicated, in relation to planned housing growth in nearby areas such as Tonbridge and Malling, that current infrastructure capacity may only support a proportion of the proposed housing numbers up to 2042. Residents in several locations, including parts of East Sussex such as Etchingham and Wadhurst, have experienced periods of water supply disruption in recent years. These events understandably raise concerns about the system’s ability to support further large scale development without significant investment and improvement.
Similarly, there are longstanding concerns regarding wastewater and sewerage infrastructure. .
Beyond utilities, several aspects of local infrastructure require careful consideration before significant housing growth is introduced. These include:
• Healthcare provision, including access to GP and dental services; the local Burwash GP already operates with long waiting times as do Hawkhurst & Ticehurst.
• Education capacity, particularly at Etchingham Village Primary School as already at full capacity, and Secondary Schools have no plans for expansion.
• Transport and road infrastructure, including traffic management and safety along the A265 and through the village centre, already dangerous with speedlimits largely ignored.
• Electricity supply resilience, given the frequency of power outages experienced locally.
Flood risk is another major issue for the village. Etchingham regularly experiences local flooding during periods of sustained rainfall, affecting fields, gardens, and sections of the main road, which can become temporarily impassable. Flooding also contributes to pressure on drainage and sewer systems.
Linear expansion in of small Village is counter to Planning Guidance particularly with no expansion to Health, commerce or educational assets.
For these reasons, development on greenfield sites such as Croft Field (Re: EC3) requires particularly careful consideration. The proposed allocation of approximately 55 dwellings represents a substantial increase for a village of this size. Development on such land may also have implications for local drainage patterns and agricultural use, as Croft Field currently supports nearby farming activity, and rankly Green Fields should remain green.
In summary, I believe that housing growth should be accompanied by demonstrable commitments to the infrastructure required to support it. Greater clarity from infrastructure providers, alongside robust planning policies, will be essential to ensure that development is sustainable and that the needs of existing and future residents are appropriately balanced.
EC1 & EC2 are wholey unsuitable as both are on regularly flooded land with incredibly poor access on narrow lanes, already used as rat-runs to neighbouring Villages that will only become dangerous with increased traffic.

I object to all three proposals EC1, EC2 and EC3.
All three sites are on greenfield land. The infrastructure in the village is already woefully inadequate, particularly drainage and the sewer system. Without upgrade building any volume of new development would be irresponsible. Church Lane at the site of EC2 for example, already floods regularly each winter, increased run off here would be catastrophic for the existing dwellings and road users. The flood plain that the village sits around is only just coping. As the climate crisis progresses, increased winter rainfall, extra run off as a result of development up river, and sea level rises will push it beyond manageable limit. This would directly effect site EC1. Whilst I agree that affordable and social housing is desperately needed the volume proposed cannot be supported. To increase the village population by around 25% without any prior investment in infrastructure of all kinds, lets down not only the existing residents but those you wish to accomodate. A small brown field site has previously been submitted as an option for an appropriate development and yet Rother chose not to include it here.

I write as a ward member in the High Weald. Like many of those seeking to answer the questionnaire it forces onto object where one might offer qualified support and does not always allow one to raise issues that do not quite fit the frame. I hope therefore that you will accept this memorandum as a response. I note also that I am a member of Etchingham Parish Council and am supportive of their answers to the questionnaire.
Rother has been asked (by algorithm) to find sites for 911 a year and even if all the sites in the draft Local Plan were agreed would fall well short of the figure. In large part that is because 83% of our Land area is protected as an historic Landscape and 90% in all is protected by that and other designations. Bewl Bridge reservoir may well be an SPA before the Local Plan is considered by the Inspector.
It follows that Rother will have to make a strong case for a lower annual number and in that regard it would seem helpful to set out in some detail what as a planning authority we see as entailed by the duty to conserve and enhance the Historic Landscape. This is all the more important as the way the new NPPF is structured could (without any apparent intention to do so) suggest that a case can be made for circumventing those protections.
It is essential therefore that there should be a section or full Chapter in the Local Plan detailing what features/characteristics of the High Weald should be preserved and identifying specific policies to achieve that end. While many of the policies relevant to development in the countryside apply, more is required. That is because we are dealing with the best surviving late mediaeval landscape in Europe. Were it a listed building it would be graded One. In effect we need to translate the High Weald Management Plan into specific policies.
Of particular importance to Etchingham is its position just to the west oft the confluence of three rivers, the Limden, Eastern Rother and Dudwell. All three are largely unspoilt and rich in biodiversity. They have much to contribute to the new nature conservation strategy. In addition both the Limden and Rother valleys include important features of the once prevalent iron working industry, not least the Hammer Ditch which provided barge access to the Etchingham site.
I note in passing that the potentially important fortification at Burgh Hill seems to have escaped attention hitherto.
Specific policies are required to preserve the unspoilt character of these valleys, together with others like the Brede Valley.
It is possible that the flood plains themselves are of some historic importance.
The second important consideration that Etchingham and other parishes wish to advance is the need to deal with a major problem with our infrastructure before any further development takes place. The current drainage system is inadequate and will not support the development proposed. This is particularly true of Shrub Lane in Burwash and of Etchingham more generally. For example at several points in Etchingham this leads to a regular n overspill of raw sewage, not only unpleasant but a potential public health problem.
Further infrastructure investment is required to reduce speeds on the Straight Mile and increase GP services in the area and these should be addressed in Rother’s infrastructure plan and submitted to the Sussex Mayor when s/he comes into office. The Parish Council also has an interest in seeing the Hurst Green bypass built.
Commenting specifically on five potential development sites, two of which are not currently included in the draft Local Plan, I am taking it that design, dark skies and other issues will be subject to specific policies for the High Weald.
EC1 Land off Oxenbridge Lane. 10 dwellings. Although this is bound to have some adverse effect on existing properties, one of them to the west of the site listed, the site has long been identified for development, and is in the draft Neighbourhood Plan, The Parish Council has no objection therefor, but would note that the access designated for the site has been known to flood.
EC2 Land at Church Lane. 5 dwellings. Again this is in the draft Neighbourhood Plan, but in this case consent should be subject to an agreed layout that minimises the effect on the cottages on the other side of the lane, which is substantially lower. Hence the number should be restricted to five and be in two groups, one at the NW end of the site and the other at south corner. This will mean that they do not overtop the existing houses. An architect’s plan was prepared for the draft Neighbourhood plan and the Council suggest that that Local Plan should indicate that approval will not be given to an outline plan. No objection in principle.
EC3 Croft Field. This is a major development in terms of paragraph 190 of the NPPF and this on its own indicates that it should be rejected. This is a field traceable to the mediaeval period, valuable pasture in agricultural terms, visually open and relatively high. Development here would have a visual impact on the Rother valley in particular. When consenting to the development of Parsonage croft, the Parish Council looked to ensure that it would end block the village and to that end, the Jubilee Wood was created in 2012 The new development would eat significantly into the green wedge between settlements and in a form that is wholly out of keeping with settlement edges in the High Weald. An estate of small houses at a high density is an unnatural extension of Etchingham and to be resisted for the harm it will do the High Weald. Even within the Parish there are small settlements that could be somewhat extended and do less harm to the historical character of the landscape. It should be noted that while the landowners support some development here, they were aghast at the suggestion that it should amount 55 houses.
However, the claims of two further sites for inclusion should not be overlooked :
1. The Lambing Shed. At least 6 starter homes. Already in the draft Neighbourhood Plan. This is a brownfield site and the Council fails to understand why it has been ruled out. It is possible that there has been some misinformation about the location of ancient woodland. The track accessing the site is already in use as an access and while the architect’s suggestion of ten may be excessive, at least half a dozen small properties would help meet one of the village’s principal needs. Sight lines at the access would need attention.
2. land behind Ladyfield. Six houses. Included in the draft Neighbourhood plan. This is not a site that is visually intrusive on the AONB, more particularly the Rother Valley and the furthest property would be no further from the High Street than those in Oaks Close. While the access is closer to Oxenbridge Lane on the south side of the High Street than is really desirable, the traffic is already slowing radically and access for a relatively small number of vehicular movements would seem achievable. Further assessment of the site is warranted.

I write as a ward member in the High Weald. Like many of those seeking to answer the questionnaire it forces onto object where one might offer qualified support and does not always allow one to raise issues that do not quite fit the frame. I hope therefore that you will accept this memorandum as a response. I note also that I am a member of Etchingham Parish Council and am supportive of their answers to the questionnaire.
Rother has been asked (by algorithm) to find sites for 911 a year and even if all the sites in the draft Local Plan were agreed would fall well short of the figure. In large part that is because 83% of our Land area is protected as an historic Landscape and 90% in all is protected by that and other designations. Bewl Bridge reservoir may well be an SPA before the Local Plan is considered by the Inspector.
It follows that Rother will have to make a strong case for a lower annual number and in that regard it would seem helpful to set out in some detail what as a planning authority we see as entailed by the duty to conserve and enhance the Historic Landscape. This is all the more important as the way the new NPPF is structured could (without any apparent intention to do so) suggest that a case can be made for circumventing those protections.
It is essential therefore that there should be a section or full Chapter in the Local Plan detailing what features/characteristics of the High Weald should be preserved and identifying specific policies to achieve that end. While many of the policies relevant to development in the countryside apply, more is required. That is because we are dealing with the best surviving late mediaeval landscape in Europe. Were it a listed building it would be graded One. In effect we need to translate the High Weald Management Plan into specific policies.
Of particular importance to Etchingham is its position just to the west oft the confluence of three rivers, the Limden, Eastern Rother and Dudwell. All three are largely unspoilt and rich in biodiversity. They have much to contribute to the new nature conservation strategy. In addition both the Limden and Rother valleys include important features of the once prevalent iron working industry, not least the Hammer Ditch which provided barge access to the Etchingham site.
I note in passing that the potentially important fortification at Burgh Hill seems to have escaped attention hitherto.
Specific policies are required to preserve the unspoilt character of these valleys, together with others like the Brede Valley.
It is possible that the flood plains themselves are of some historic importance.
The second important consideration that Etchingham and other parishes wish to advance is the need to deal with a major problem with our infrastructure before any further development takes place. The current drainage system is inadequate and will not support the development proposed. This is particularly true of Shrub Lane in Burwash and of Etchingham more generally. For example at several points in Etchingham this leads to a regular n overspill of raw sewage, not only unpleasant but a potential public health problem.
Further infrastructure investment is required to reduce speeds on the Straight Mile and increase GP services in the area and these should be addressed in Rother’s infrastructure plan and submitted to the Sussex Mayor when s/he comes into office. The Parish Council also has an interest in seeing the Hurst Green bypass built.
Commenting specifically on five potential development sites, two of which are not currently included in the draft Local Plan, I am taking it that design, dark skies and other issues will be subject to specific policies for the High Weald.
EC1 Land off Oxenbridge Lane. 10 dwellings. Although this is bound to have some adverse effect on existing properties, one of them to the west of the site listed, the site has long been identified for development, and is in the draft Neighbourhood Plan, The Parish Council has no objection therefor, but would note that the access designated for the site has been known to flood.
EC2 Land at Church Lane. 5 dwellings. Again this is in the draft Neighbourhood Plan, but in this case consent should be subject to an agreed layout that minimises the effect on the cottages on the other side of the lane, which is substantially lower. Hence the number should be restricted to five and be in two groups, one at the NW end of the site and the other at south corner. This will mean that they do not overtop the existing houses. An architect’s plan was prepared for the draft Neighbourhood plan and the Council suggest that that Local Plan should indicate that approval will not be given to an outline plan. No objection in principle.
EC3 Croft Field. This is a major development in terms of paragraph 190 of the NPPF and this on its own indicates that it should be rejected. This is a field traceable to the mediaeval period, valuable pasture in agricultural terms, visually open and relatively high. Development here would have a visual impact on the Rother valley in particular. When consenting to the development of Parsonage croft, the Parish Council looked to ensure that it would end block the village and to that end, the Jubilee Wood was created in 2012 The new development would eat significantly into the green wedge between settlements and in a form that is wholly out of keeping with settlement edges in the High Weald. An estate of small houses at a high density is an unnatural extension of Etchingham and to be resisted for the harm it will do the High Weald. Even within the Parish there are small settlements that could be somewhat extended and do less harm to the historical character of the landscape. It should be noted that while the landowners support some development here, they were aghast at the suggestion that it should amount 55 houses.
However, the claims of two further sites for inclusion should not be overlooked :
1. The Lambing Shed. At least 6 starter homes. Already in the draft Neighbourhood Plan. This is a brownfield site and the Council fails to understand why it has been ruled out. It is possible that there has been some misinformation about the location of ancient woodland. The track accessing the site is already in use as an access and while the architect’s suggestion of ten may be excessive, at least half a dozen small properties would help meet one of the village’s principal needs. Sight lines at the access would need attention.
2. land behind Ladyfield. Six houses. Included in the draft Neighbourhood plan. This is not a site that is visually intrusive on the AONB, more particularly the Rother Valley and the furthest property would be no further from the High Street than those in Oaks Close. While the access is closer to Oxenbridge Lane on the south side of the High Street than is really desirable, the traffic is already slowing radically and access for a relatively small number of vehicular movements would seem achievable. Further assessment of the site is warranted.

I write as a ward member in the High Weald. Like many of those seeking to answer the questionnaire it forces onto object where one might offer qualified support and does not always allow one to raise issues that do not quite fit the frame. I hope therefore that you will accept this memorandum as a response. I note also that I am a member of Etchingham Parish Council and am supportive of their answers to the questionnaire.
Rother has been asked (by algorithm) to find sites for 911 a year and even if all the sites in the draft Local Plan were agreed would fall well short of the figure. In large part that is because 83% of our Land area is protected as an historic Landscape and 90% in all is protected by that and other designations. Bewl Bridge reservoir may well be an SPA before the Local Plan is considered by the Inspector.
It follows that Rother will have to make a strong case for a lower annual number and in that regard it would seem helpful to set out in some detail what as a planning authority we see as entailed by the duty to conserve and enhance the Historic Landscape. This is all the more important as the way the new NPPF is structured could (without any apparent intention to do so) suggest that a case can be made for circumventing those protections.
It is essential therefore that there should be a section or full Chapter in the Local Plan detailing what features/characteristics of the High Weald should be preserved and identifying specific policies to achieve that end. While many of the policies relevant to development in the countryside apply, more is required. That is because we are dealing with the best surviving late mediaeval landscape in Europe. Were it a listed building it would be graded One. In effect we need to translate the High Weald Management Plan into specific policies.
Of particular importance to Etchingham is its position just to the west oft the confluence of three rivers, the Limden, Eastern Rother and Dudwell. All three are largely unspoilt and rich in biodiversity. They have much to contribute to the new nature conservation strategy. In addition both the Limden and Rother valleys include important features of the once prevalent iron working industry, not least the Hammer Ditch which provided barge access to the Etchingham site.
I note in passing that the potentially important fortification at Burgh Hill seems to have escaped attention hitherto.
Specific policies are required to preserve the unspoilt character of these valleys, together with others like the Brede Valley.
It is possible that the flood plains themselves are of some historic importance.
The second important consideration that Etchingham and other parishes wish to advance is the need to deal with a major problem with our infrastructure before any further development takes place. The current drainage system is inadequate and will not support the development proposed. This is particularly true of Shrub Lane in Burwash and of Etchingham more generally. For example at several points in Etchingham this leads to a regular n overspill of raw sewage, not only unpleasant but a potential public health problem.
Further infrastructure investment is required to reduce speeds on the Straight Mile and increase GP services in the area and these should be addressed in Rother’s infrastructure plan and submitted to the Sussex Mayor when s/he comes into office. The Parish Council also has an interest in seeing the Hurst Green bypass built.
Commenting specifically on five potential development sites, two of which are not currently included in the draft Local Plan, I am taking it that design, dark skies and other issues will be subject to specific policies for the High Weald.
EC1 Land off Oxenbridge Lane. 10 dwellings. Although this is bound to have some adverse effect on existing properties, one of them to the west of the site listed, the site has long been identified for development, and is in the draft Neighbourhood Plan, The Parish Council has no objection therefor, but would note that the access designated for the site has been known to flood.
EC2 Land at Church Lane. 5 dwellings. Again this is in the draft Neighbourhood Plan, but in this case consent should be subject to an agreed layout that minimises the effect on the cottages on the other side of the lane, which is substantially lower. Hence the number should be restricted to five and be in two groups, one at the NW end of the site and the other at south corner. This will mean that they do not overtop the existing houses. An architect’s plan was prepared for the draft Neighbourhood plan and the Council suggest that that Local Plan should indicate that approval will not be given to an outline plan. No objection in principle.
EC3 Croft Field. This is a major development in terms of paragraph 190 of the NPPF and this on its own indicates that it should be rejected. This is a field traceable to the mediaeval period, valuable pasture in agricultural terms, visually open and relatively high. Development here would have a visual impact on the Rother valley in particular. When consenting to the development of Parsonage croft, the Parish Council looked to ensure that it would end block the village and to that end, the Jubilee Wood was created in 2012 The new development would eat significantly into the green wedge between settlements and in a form that is wholly out of keeping with settlement edges in the High Weald. An estate of small houses at a high density is an unnatural extension of Etchingham and to be resisted for the harm it will do the High Weald. Even within the Parish there are small settlements that could be somewhat extended and do less harm to the historical character of the landscape. It should be noted that while the landowners support some development here, they were aghast at the suggestion that it should amount 55 houses.
However, the claims of two further sites for inclusion should not be overlooked :
1. The Lambing Shed. At least 6 starter homes. Already in the draft Neighbourhood Plan. This is a brownfield site and the Council fails to understand why it has been ruled out. It is possible that there has been some misinformation about the location of ancient woodland. The track accessing the site is already in use as an access and while the architect’s suggestion of ten may be excessive, at least half a dozen small properties would help meet one of the village’s principal needs. Sight lines at the access would need attention.
2. land behind Ladyfield. Six houses. Included in the draft Neighbourhood plan. This is not a site that is visually intrusive on the AONB, more particularly the Rother Valley and the furthest property would be no further from the High Street than those in Oaks Close. While the access is closer to Oxenbridge Lane on the south side of the High Street than is really desirable, the traffic is already slowing radically and access for a relatively small number of vehicular movements would seem achievable. Further assessment of the site is warranted.